## San Joaquin Valley

Air Pollution
Control District



# 2009 RACT SIP

Reasonably Available Control Technology (RACT) Demonstration for Ozone State Implementation Plans (SIP)



## April 16, 2009San Joaquin Valley Unified Ai r Pollution Control District 1990 E. Gettysburg Avenue

Fresno, California 93726

(559) 230-6100

www.valle y

air.or gSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Table of Contents

RACT Demonstration for Ozone SIP i 

## Table of Contents

Table of Contents

Acknowledgements

Chapter 1: Overview

1.1 Introduc tion........................................................................................................ 1-1

1.2 Reason For Th is Projec t .................................................................................... 1-2
1.2.1 One-Hour Oz one Requirem ents................................................................ 1-2 1.2.2 Eight-Hour Ozo ne Requirem ents .............................................................. 1-3

1.2.3 Additional Requirement s ........................................................................... 1-3 1.3 Eight-hour Ozone RACT De monstration El ements............................................ 1-4 1.4 Process for Developing This RACT Demonstr ation SI P .................................... 1-5
1.4.1 RACT Demonstr ation Proc ess .................................................................. 1-5 1.4.1.1 Federal Applic ability of RACT ......................................................... 1-5

1.4.1.2 Definition and Stringency of RACT.................................................. 1-6 1.4.1.3 Purpose of Federal RACT............................................................... 1-6

1.4.1.4 RACT Guidance from EPA Regi on IX ............................................. 1-8 1.4.1.5 Issues Regarding Fede ral Expectations for RACT .......................... 1-8
1.4.2 RACT Demonstr ation Proc ess .................................................................. 1-8

1.4.3 Public Process ........................................................................................... 1-9
1.5 Glo ssary ............................................................................................................ 1-9

Chapter 2: CTG Source Categories and Applicable District Rules 2.1 District Implement ation of EPA CTGs................................................................ 2-1

2.1.1 CTG S ources............................................................................................. 2-1
2.1.2 CTGs Without S ubject Facilit ies ................................................................ 2-5

2.1.2.1 Surface Coating Operations at Ship Building and Ship Repair Facilities .. 2-5

2.1.2.2 Pharmaceutical M anufacturing Oper ations ..................................... 2-6
2.1.2.3 Refe rences ...................................................................................... 2-7

Chapter 3: Major Sources and Applicable RACT Rules 3.1 Major Source Listin g .......................................................................................... 3-1

Chapter 4: Rule Analysis 4.1 Rules Analyze d for RA CT.................................................................................. 4-1 4.2 Rules On A Schedule to Implem ent RACT/CTG Requi rements .................... 4-376 4.2.1 Rules Implementing RACT Requirem ents............................................. 4-376 4.2.2 Rules Implementing CTG Requirem ents............................................... 4-376San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

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RACT Demonstration for Ozone SIP ii 

## Appendices

Appendix A: Comments and Responses

A.1 EPA Comm ents...............................................................................A-1
A.2 ARB Co mments ..............................................................................A-5
A.3 Stakeholder Comments ...................................................................A-5

Appendix B: Rule 4570 BACT AnalysisSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

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RACT Demonstration for Ozone SIP iii 

## List of Tables

Table 2-1 Control Tec hniques Guid elines ........................................................ 2-2

Table 3-1 Major Sources and Ap plicable RACT Rules ..................................... 3-2

Table 4-1 District Rules A nalyzed and Rule History ......................................... 4-2
Table 4-2 District NOx and VO C Rules Not A nalyzed...................................... 4-6
Table 4-3 Schedule for District Rules Needing Am endments....................... 4-377San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

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RACT Demonstration for Ozone SIP iv This page intentionally blank.

# AcknowledgmentsSan Joaquin Valley Unified Air Pollution Control District April 16, 2009

Acknowledgments
RACT Demonstration for Ozone SIP ACKNOWLEDGMENTS

The District wishes to acknowledge t he leadership and effort of those

who contributed to the RACT Demonstration for Ozone SIP Report

.

Project Management and Supervision

Rick McVaigh, Deputy Air Pollution Control Officer Scott Nester, Director of Planning Dave Warner, Director of Permit Services Errol Villegas, Planning Manager Jim Swaney, Permit Services Manager Sheraz Gill, Supervising Air Quality Engineer

Contributors

Ross Badertscher, Air Quality Specialist Sandra Lowe-Leseth, Air Quality Engineer Joe Nazareno, Senior Air Quality Engineer Brian Clements, Senior Air Quality Engineer

Kamaljit Sran, SeniorAir Quality Engineer Derek Fukuda, Air Quality Engineer Jonah Aiyabei, Air Quality EngineerRACT Demonstration for Ozone SIP 

## Chapter 1

OverviewRACT Demonstration for Ozone SIP This page intentionally blank.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 1: Overview

RACT Demonstration for Ozone SIP 1-1 

## Chapter 1: Overview

1.1 INTRODUCTION

The San Joaquin Valley Air Basin (SJVAB) is an inter-mountain valley comprised of eight counties in California’s San Joaquin Valley: Fresno, Kings, Madera, Merced, San Joaquin, Stanislaus, Tulare, and the Vall ey portion of Kern. The SJVAB is approximately 250 miles long, averages 80 mile s wide, and is partially enclosed by the Coast Range on the west, the Tehachapi M ountains on the south, and the Sierra Nevada on the east. These surrounding mountai ns trap pollution. The region’s low wind speeds, combined with low-level temper ature inversions in the winter, are conducive to trapping particulates, and the region’s hot, sunny, and dry summers are

conducive to ozone formation. Due to the topography and meteorol ogical conditions, the SJVAB faces air quality challenges unmatched by any other air basin.

The SJVAB is currently designated as nonatta inment for the PM2.5 (Particulate Matter 2.5 microns or less in diameter) Nationa l Ambient Air Quality Standard (NAAQS) and extreme nonattainment for the eight-hour oz one NAAQS. Prior to the United States Environmental Protection Agency’s (EPA’s) implementation of the eight-hour ozone standard, the SJVAB was also classified as an extreme nonattainment area for the onehour ozone NAAQS. Although EPA revo ked the one-hour ozone NAAQS, the San Joaquin Valley Air Pollution Control District ( District) is still required to meet certain related requirements mandated by the federal Clean Air Ac t. In addition to being designated as nonattainment of federal air standards, SJVAB is designated as

nonattainment for the California ozone air quality standards and nonattainment for the California PM10 and PM2.5 air quality standards.

Since its formation in 1992, the San Joaquin Va lley Unified Air Pollution Control District (District) has adopted about 500 rules and ru le amendments. The District was the

nation’s first air distri ct to adopt a progressive Indirect Source Review (ISR) program, and was the first air district to adopt rules to control emissions of volatile organic compound (VOC) from wine production and storage operations and residential fireplaces. In addition, the District leads t he nation with its stringent oxides of nitrogen (NOx) emission limits on engines, boilers, tu rbines, and glass-melting furnaces.

Air quality improvements evidence the success of the District’s innovative and effective rules. Significant progress has been made towards the attainment of the ozone and PM2.5 NAAQS and the EPA has redesignat ed the SJVAB from nonattainment to
attainment for the PM10 NAAQS.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 1: Overview

RACT Demonstration for Ozone SIP 1-2 1.2 REASON FOR THIS PROJECT

Despite the progress towards attainment, the SJVAB remains in nonattainment for ozone and Sections 182(b)(2) and 182(f) of the federal Clean Air Act require ozone nonattainment areas to implement RACT fo r sources that are subject to Control Techniques Guidelines (CTG) documents i ssued by EPA and for “major sources” of volatile organic compounds (VOCs) and oxid es of nitrogen (NOx), which are ozone precursors. RACT requirements are include d in the Clean Air Act to assure that significant source categories at major sour ces in the nation’s non attainment areas are

controlled to a “reasonable” extent.

This document demonstrates that all federal RACT requirements have been satisfied in

the SJVAB.

1.2.1 One-hour Oz one Requirements

In June of 2004, United Stat es Environmental Protection Agency (EPA) designated San Joaquin Valley Air Basin as nonattainment for the new 8-hour ambient air quality standard for ozone. Subsequently, in June of 2005, EPA revoked the previous 1-hour ambient air quality standard. However, prio r to EPA's revocation of the 1-hour ozone standard, in October 2004, t he District had submitted an Extreme Ozone Attainment Demonstration Plan (EOADP) for the 1-hour oz one standard. Within the EOADP, was a RACT discussion (Section 4.2.5) which sa tisfied all the requirements that EPA had specified at the time.

In November 2005, EPA changed its policy for RA CT in SIPs, as outlined in their Final Rule to Implement the 8-hr Ozone National Ambient Air Quality Standard-Phase 2 (70 FR 71612). In 2008, EPA notified the District that the 2004 EOADP RACT discussion did not meet the requirements of the new policy. District staff, in discussions with EPA staff, determined that the mo st prudent course of action to address this discrepancy was to formally withdraw the RACT discussion from the 2004 EOADP, thereby removing it from EPA's review and approval process for the 1-hr ozone SIP requirements.

Therefore, on August 21, 2008, the District’s Governing Board approved agenda item

“ Adopt the Clarifications and Document ation Regarding the 2004 Extreme Ozone

Attainment Demonstration Plan for the Revoked Federal I-Hour Ozone Standard ”, which provided EPA with the necessary documentati on and clarification needed to take final action on the 2004 1-hour ozone plan. Contained within this Governing Board item was the withdrawal of the RACT por tion of that plan (Section 4.2.5) and a commitment to replace it with a new RACT analysis.

Then on January 21, 2009, EPA published in the Federal Register a “ Finding of Failure to Submit a Required State Implementation Plan Revision for 1-Hour Ozone Standard, California--San Joaquin Valley – Reas onably Available Control Technology ”. This action triggered sanction "clocks" under the Clean Air Act. The first sanction clock runs for 18 months and, if not stopped, imposes a 2:1 ratio on offsets for new majorSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 1: Overview

RACT Demonstration for Ozone SIP 1-3 stationary sources. The second sanction runs for 24-months and, if not stopped, would

restrict the use of federal hi ghway funds in the area, with t he exception of certain safety and air quality projects. The District can avoid sanctions by submitting a completed RACT plan that meets t he federal expectations.

This RACT demonstration repor t will satisfy the commitment for a new RACT analysis for the 1-hour ozone plan and prevent all sa nctions that could be imposed by the “finding of failure to submit”.

1.2.2 Eight-hour Ozone Requirements

According to the EPA’s Final Rule to Implement the Eight-Hour Ozone NAAQS (70 FR 71612, November 29, 2005), areas classified as moderate nonattainment or higher

must submit a demonstration t hat their current rules fulfill eight-hour ozone RACT for all CTG categories and all major, non-CTG sour ces. This demonstration would be a revision to their State Implementation Plan (SIP ). States can demonstrate that RACT is being fulfilled with either a new RACT determi nation or a certificat ion that previously required RACT controls also represent RACT for eight-hour ozone. Areas may rely on previous analyses written for one-hour ozone plans and EPA guidance documents.

On August 17, 2006 the District Governing Board adopted a RACT SIP analysis for its eight-hour ozone serious nonattainment classi fication. Per Section 182 (c) of the federal Clean Air Act, areas classified as seri ous nonattainment have a 50 tons per year (tpy) major source definition. The Va lley did not, however, experience a 50 tpy

threshold because of state law and the f ederal revocation of the 1-hour ozone

standard. 1 The August 2006 RACT SIP analysis showed that the District’s rules met or exceeded RACT requirement s for all applicable EPA source categories. The final eighthour ozone attainment plan ( 2007 Ozone Plan), adopted on April 30, 2007, requested

an extreme nonattainment classifi cation for the District. For ar eas classified as extreme nonattainment, the major source definition is 10 tpy VOC or NOx (Section 182 (e) of the federal Clean Air Act).

To assess the District’s rules based on the adjus ted major source definition of 10 tpy, on December 28, 2007 the District published a revised RACT SIP analysis for public comment. The analysis also evaluated District rules against four new CTGs promulgated between August 2006 and Decem ber 2007 and reviewed additional rules
and rule amendments for RACT that were adopted by the District’s Governing Board between August 17, 2006 and December 2007. The District received comment letters from EPA and Earthjustice which suggested that the District conduct a more thorough analysis for each rule to address RACT and evaluate how emission limits found reasonable in other areas have changed since EPA approval of the District’s rules.

1 Section 42504 of the California Health and Safety Code stip ulates that any major source threshold in effect as of December 30, 2002 cannot be relaxed to a higher thres hold. On December 30, 2002 the Valley was classified as
severe nonattainment for 1-hour ozone, so the threshold remained at 25 tpy. This stat e law prevented the Valley’s major source threshold from rising to 50 tpy upon classifyin g the Valley as serious nonattainment for 8-hour ozone.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 1: Overview

RACT Demonstration for Ozone SIP 1-4 This RACT demonstration repor t therefore, replaces both the original August 17, 2006 RACT SIP analysis and the December 28, 2007 revised RACT SIP analysis as it assesses the District’s rules based on the adjus ted major source definition of 10 tpy, evaluates District rules against new CTGs promulgated since August 2006, and also

reviews additional rules and rule amendments for RACT that have been adopted by the District’s Governing Board since August 17, 2006.

1.2.3 Additiona l Requirements

As part of the August 2006 RACT SIP analysis, District staff identified eight rules 2 that were not previously submitted to EPA for incl usion into the SIP. In May 2007, District
staff submitted the rules to the California Air Resources Board (A RB) for transmittal to

EPA for inclusion into the SIP. On J anuary 2, 2008, EPA published in the Federal Register (73 FR 48) a direct final approval of the rules into the SIP. The direct final action was published without pr ior proposal because EPA anticipated no adverse

comment. The direct final rule stated that if adverse comments were received by February 1, 2008, EPA would publish a timely removal in the Federal Register. EPA received a timely adverse comment which s uggested that the rules did not meet the federal Clean Air Act, Secti on 172(c)(1) requirements fo r RACT and consequently removed the direct final approval of the ru les. It should be noted that the EPA did not determine that these rules do not satisfy RACT.

This RACT demonstration report also addresses EPA’s request for additional information regarding the eight rules proposed for direct final approval

1.3 EIGHT-HOUR OZONE RACT DEMONSTRATION ELEMENTS

A letter from EPA, Region IX outlined a possi ble RACT SIP submittal strategy. The strategy included five main points:

3⁄4 A description of efforts to identify all s ource categories within the District requiring RACT, including CTG sources (i.e., covered by an EPA Control Technique Guideline document) and major non-CTG sources.

3⁄4 A submission of negative declarations where there are no facilities (major or minor) within the District subject to a CTG.

3⁄4 A list of the state/local regulation that implements RACT for all categories needing RACT, including the date EPA approved thes e regulations as fulfilling RACT.

2 Rule 4104 (Reduction of Animal Ma tter); Rule 4402 (Crude Oil Production Sumps); Rule 4404 (Heavy Oil Test Station – Kern County); Rule 4453 (Refinery Vacuum Prod ucing Devices or Systems); Rule 4454 (Refinery Process Unit Turnaround); Rule 4625 (Wastewater Separators); Rule 4641 (Cutback, Slow Cure, and Emulsified Asphalt, Paving and Maintenance Operations); and Rule 46 72 (Petroleum Solvent Dry Cleaning Operations)San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 1: Overview

RACT Demonstration for Ozone SIP 1-5 3⁄4 A description of the basis for concludi ng that the regulations fulfill RACT. Documents useful in establishing RACT include CTGs, Alternative Control Technique guidelines (ACT), Maximum Achievable Control Technology (MACT) standards, New Source Performance Standards (NSPS), California Suggested Control Measures (SCM) and RACT/Best Av ailable Retrofit Control Technology (BARCT) determinations, regulations adopted in other Districts, and guidance and rules developed by other st ate and local agencies.

3⁄4 If a district uses CAPCOA’s September 2003 Potential All Feasible Measures (AFM) Report to help demonstrate RACT, the RA CT SIP should certify that local regulations are equivalent to AFM, justif y the assumption that the AFM fulfilled RACT in 2003, and include some sort of certification/dem onstration that no

additional controls have become more reasonably available since then.

Pursuant to EPA’s guidance, this RACT Dem onstration report is composed of several

main elements:

• A demonstration that EPA’s CTGs are being implemented appropriately in the SJVAB, and a discussion of two CTG categorie s that do not exist in the SJVAB. (See Chapter 2)

• A demonstration that all major sources in the SJVAB are covered by RACT rules. (See Chapter 3)

• A demonstration that the District’s ru les for ozone precursors (NOx and VOC) satisfy RACT levels of stringency, applic ability, and enforceability. (See Chapter 4)

1.4 PROCESS FOR DEVELOPING TH IS RACT DEMONSTRATION SIP

1.4.1 Review Of Federal RACT Requirements

1.4.1.1 Federal Ap plicability of RACT

The Clean Air Act (CAA) Secti on 182(b)(2) states that ozone at tainment plans shall assure
that RACT for volatile or ganic compounds (VOC) is app lied at certain sources.

“The State shall submit a revision to the applicable implementation plan to include provisions to require the implementation of reasonably available control technology under section 172(c)(1) of this title with respect to each of the following:

(A) Each category of VOC sources in the area covered by a CTG document issued by the Administra tor between November 15, 1990, and

the date of attainment.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 1: Overview

RACT Demonstration for Ozone SIP 1-6 (B) All VOC sources in the area covered by any CTG issued before November 15, 1990.

(C) All other major stationary sources of VOCs that are located in the

area.”

Section 182(f) extends federal RACT requirements to NOx rules and major NOx sources. Because the San Joaquin Valley Ai r Basin is classified as an extreme ozone area, “major sources” are thos e that generate more than 10 tons per year of NOx or

VOC.

1.4.1.2 Defini tion and Stringency of RACT

Although the Clean Air Act itself does not define Reasonably Available Control Technology, 40 CFR 51.100(o) defines RACT as:

”devices, systems, process modifications , or other apparatus or techniques that are reasonably availa ble, taking into account (1) the necessity of imposing such controls in order to a ttain and maintain a national ambient air quality standard; (2) the social, envir onmental, and economic impact of such controls; and (3) alternative means of providing for attainment and

maintenance of such a standard.”

The foregoing definition applies to a specific federal provision regarding approval of extension requests for attainment plans fo r secondary air quality standards, but in the absence of a more definitive regulatory description, it is concise and useful. EPA also
defined RACT in the Strelow memorandum 3 as:

“the lowest emission limitation that a par ticular source is capable of meeting by the application of control technol ogy that is reasonably available, considering technological and economic feasibility”.

1.4.1.3 Purpose of Federal RACT

The Clean Air Act requires RACT for certain sources in all nonattainment areas nationwide, regardless of the seve rity of the ozone problem.

“172(c) Nonattainment plan provisions

The plan provisions (including plan items) required to be submitted under this part shall comply wit h each of the following:

(1) In general

3 The Strelow RACT Memorandum, published in BNA Envi ronmental Reporter, December 9, 1976, pages 1210-1212San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 1: Overview

RACT Demonstration for Ozone SIP 1-7 Such plan provisions shall provide fo r the implementation of all reasonably available control measures as expediti ously as practicable (including such

reductions in emissions from existi ng sources in the area as may be obtained through the adoption, at a minimu m, of reasonably available control technology) and shall provide for attainm ent of the national primary ambient air quality standards.”

From this section, it is clear that RACT is intended as the minimum level of control that

all ozone nonattainment areas must achieve for ex isting sources. It is also clear that RACT is not intended as the only level of co ntrol needed for all nonattainment areas to attain the ozone standard. Two key conclusi ons are drawn from the section above: first, states must adopt RA CT for existing sources regardless if they are needed for attainment, and second, states may need addi tional measures beyond RACT to attain

the standard. This second conclusion lead s to the understanding that RACT is not intended to be the most stringent level of cont rol in an area’s attainment strategy.

In the greater context of air pollution contro l levels, RACT is understood as the “floorlevel” of air pollution controls, not the “ceilin g-level.” More effective levels of emissions

control are termed Best Ava ilable Control Technology (BAC T) and Lowest Achievable Emission Rate (LAER). BACT and LAER are r equired for new sources, and for existing sources undergoing modification. Under stat e and federal air pollution programs, new facilities face more stringent pollution contro l requirements than existing facilities, with the understanding that better controls can be more easily implemen ted before a facility is built, than after it is built. Ne w sources must generally implement BACT 4 and existing sources must implement a less stringent level of control such as Reasonably Available Control Technology (RACT). Additionally, Ca lifornia law establishes an intermediate

level of control that is the “ best available” for “retrofit” to existing sources (entitled Best

Available Retrofit C ontrol Technology – BARCT 5 ), recognizing that the state’s worst ozone problems demands more effective po llution control than what is usually considered “reasonably available.”

As discussed above, the purposes of BACT, RACT, and BARCT are different. BACT is designed to minimize the growth in futu re stationary source emissions with the installation of best available controls; RA CT is designed to reduce current stationary source emissions from existing sources with the application of reasonably available controls; and BARCT is designed to reduce cu rrent stationary source emissions even further with the application of best available retrofit controls. BACT is identified and prescribed in the permitting process on a case -by-case administrative basis. RACT and

4 Federal regulations for permitting new facilities require Best Available Control Technology (BACT) for new sources
in attainment areas, and Lowest Achievable Emission Rate (LAER) – a generally more stringent level –for new

sources in nonattainment areas. LAER diffe rs from BACT in that economic costs are not considered for candidate

LAER controls that are considered “Achieved in Practice.” Under California state law, the District is required to apply “BACT” for new sources under essentially the same requirements as federal LAER. The District’s “BACT”

determinations thus fulfill the f ederal LAER requirements.

5 California Health and Safety Code (CH&SC) 40406: ... "b est available retrofit control technology" means an emission limitation that is based on the maximum degree of r eduction achievable, taking into account environmental, energy, and economic impacts by each class or category of source.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 1: Overview

RACT Demonstration for Ozone SIP 1-8 BARCT are developed on an industry-wide basis in the rule development process, which concludes with quasi-legislative ac tion by the District Governing Board.

1.4.1.4 RACT Guidance from EPA Region IX

A letter from EPA, Region IX 6 outlined documents that could be useful in establishing RACT. Those documents include EPA’s Control Techniques Guidelines (CTGs), Alternative Control Techniques (ACTs), New Source Performance Standards (NSPS),

National Emissions Standards for Hazar dous Air Pollutants (NESHAPs), EPA Best Available Control Technology (BACT) Cl earinghouse, California Suggested Control Measures (SCM) and RACT/Best Available Retrofit Control Technology (BARCT) determinations, regulations adopted in ot her Districts, and guidance and rules developed by other state and local agencies.

1.4.1.5 Issues Regarding Federal Expectations for RACT

RACT is inherently a “moving target.” Tec hnology considered to meet RACT at the time of SIP-approval is generally rendered obsolete by more e ffective technology that is

introduced at a later date. This view of moving-target RACT requirements precludes comparing District rules only to CTGs/ACTs or simply relying on E PA SIP-approval of rules as satisfying RACT r equirements; theref ore, other adopted air pollution control requirements, such as other distri cts’ rules, must be considered.

It should also be noted that since District rules usually fulfill BARCT requirements for state purposes, and the control technology estab lished by a BARCT rule is by definition

the most effective retrofit c ontrol for the source category; it can be assumed to, at a minimum, satisfy RACT require ments, if not go beyond RACT.

1.4.2 RACT Demonstration Process

The preparation of this repor t required intensive effort by numerous District staff including engineers and s pecialists from the Plann ing and Permit Services Departments. The analysis requi red careful and wide-ranging ex amination of individual rules against multiple federal rules, regulat ions, and technology guidelines as well as evaluating District rules against comparable rule s from California’s most technologically progressive air districts.

The process began by comparing District rules to EPA’s CTGs. There are a total of 42 CTGs, twelve of which were promulgated by EPA after the original August 17, 2006 RACT SIP analysis was adopted. Chapter 2 of this report links the EPA-promulgated
CTGs with the District rules that cover t he same source category,and discusses two CTGs that have no applicable facilities in the SJVAB.

6 United States Environmental Protection Agency – letter from Andrew Stec kel, EPA Region IX to Kurt Karperos, ARB dated March 9, 2006 – RACT SIPSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 1: Overview

RACT Demonstration for Ozone SIP 1-9 The next part of the process was to identify the major sources of NOx and VOCs in the

SJVAB. For this demonstr ation, District staff began wit h the federal Clean Air Act definition of major source. In the Clean Air Act, what constitutes a major source depends on the nonattainment classification of the area where the sour ce is located. With its 2007 Ozone Plan, the District has reques ted that its nonattainm ent classification be changed to extreme nonattainment, meaning t hat the definition of major source for
NOx or VOC is one that has t he potential to emit of at l east 10 tons per year. The connection between the SJVAB’s major sources and applicable District rules is outlined in Chapter 3 of this report The District’ s database of current Permits-to-Operate was queried to find those sources that have the potentia l to emit at least ten tons per year of
either NOx or VOC. Chapter 3 contains a list of all of the facilities that have the potential to emit of at least ten tons per year of either NOx or VOCand the NOx and

VOC rules to which the fac ility’s equipment is subject.

Finally, in Chapter 4 are RACT evaluations of current District rules. All of the District’s NOx and VOC prohibitory rules are addressed in this RACT demonstration. The rules were rigorously compared to federal and state regulations and guidance on emission controls. As agreed to by EPA staff, t he rules were also compared to analogous regulations adopted by California’s most technolog ically progressive air districts: South Coast Air Quality Management District, Ba y Area Air Quality Management District, Sacramento Metropolitan Air Quality Manage ment District, and Ventura County Air

Pollution Control District.

1.4.3 Public Process

In keeping with the District’s philosophy of public accountability, the results of the comprehensive analysis became available for public review on March 16, 2009. Public comments will be accepted and in corporated into the analysi s as appropriate. The District’s Governing Board will consider this report at the April 16, 2009 meeting. The report will subsequently be transmitted to ARB who will then submit the report to EPA by May 15, 2009. EPA staff will then evaluat e the submission. The demonstration

would:

• Fulfill a District obligation under the one- hour ozone planning requirements to show that District rules implement RACT;

• Fulfill a District obligation under the eight -hour ozone planning r equirements to show that District rules implement RACT;

• Demonstrate the eight District rules cu rrently in limbo at EPA implement RACT; and

• Stop the two sanction clocks started by t he EPA’s finding of “failure to submit”.

1.5 GLOSSARY

The following terms are used in discussion of the control measure and technology requirements in this report:San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 1: Overview

RACT Demonstration for Ozone SIP 1-10 3⁄4 Best Available Control Technology (BACT): The mo st up-to-date methods, systems, techniques, and production processe s available to achieve the greatest feasible emission reductions for given regulated air pollutants and processes. Federal BACT is a requirement of New Source Review (NSR) and Prevention of Significant Deteri oration (PSD).

3⁄4 Best Available Retrofit Control Tec hnology (BARCT): A California emission standard that applies to existing sources and is based on the maximum degree of reduction achievable, taking into a ccount environmental, energy, and economic impacts by each class or category of s ource (California Health and Safety Code (CH&SC) Section 40406).

3⁄4 Reasonably Available Control Technolog y (RACT): Devices, systems, process modifications, or other apparatus or tec hniques that are r easonably available, taking into account the necessity of imposi ng such controls in order to attain and maintain a national ambient air quality standard; the social, environmental, and economic impact of such controls; and alternative means of providing for

attainment and maintenance of such a standard. These control techniques, which are defined in EPA guidelines for lim iting emissions from existing sources in nonattainment areas, are adopted and im plemented for nonattainment areas by state analysis.RACT Demonstration for Ozone SIP 

## Chapter 2

CONTROL TECHNIQUES GUIDANCE (CTG) SOURCE CATEGORIES AND APPLICABLE

DISTRICT RULESRACT Demonstration for Ozone SIP This page intentionally blank.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 2: CTG Source Categories and Applicable District Rules

RACT Demonstration for Ozone SIP 2-1 

## Chapter 2: CTG Source Categories and Applicable District Rules

2.1 DISTRICT IMPLEMEN TATION OF EPA CTGS

As a part of its RACT SIP analysis, the Distr ict is required to assure that EPA’s CTGs are being appropriately implemen ted though District regulations, . For this part of the analysis, staff matched the list of CTGs to District rules that apply to CTG source categories.

2.1.1 CTG Sources

There are a total of 42 CTGs, twelve of which have been promulgated by EPA after the original August 17, 2006 RACT SIP analysis was adopted. For this demonstration,

District staff reviewed District rules for matching CTG source categories, and then compared the rule requirements to the CT G recommendations. The demonstration that District rules implement CTGs is part of Chapter 4.

Table 2-1 shows the CTGs promulgated by the EPA to-date, and the corresponding

District rules.San Joaquin Valley Unified Air Pollution Control District April 16, 2009Chapter 2: CTG Source Categories and Applicable District RulesRACT Demonstration for Ozone SIP2-2Table 2-1: Control Techniques GuidelinesDescription Pollutant EPA Report Date District RulesDesign Criteria for Stage I Vapor Control Systems – Gasoline Service Stations VOC EPA-450/R-75-1021975/114622Control of Volatile Organic Emissionsfrom Existing Stationary Sources –Volume I: Control Methods for Surface Coating OperationsVOC EPA-450/2-76-0281976/11Note – Although often listedwith the CTGs for historicalreasons, this document doesnot define RACT for anysource. It is a compilation ofcontrol techniques.Control of Volatile Organic Emissionsfrom Existing Stationary Sources –Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, andLight-Duty TrucksVOC EPA-450/2-77-0081977/054602, 4604, 4607, 4612Control of Volatile Organic Emissions from Solvent Metal Cleaning VOC EPA-450/2-77-0221977/114662Control of Refinery Vacuum ProducingSystems, Wastewater Separators, andProcess Unit TurnaroundsVOC EPA-450/2-77-0251977/104453, 4454, 4455, 4625Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals VOC EPA-450/2-77-0261977/104621, 4624Control of Volatile Organic Emissionsfrom Existing Stationary Sources –Volume III: Surface Coating of Metal FurnitureVOC EPA-450/2-77-0321977/124603Control of Volatile Organic Emissionsfrom Existing Stationary Sources –Volume IV: Surface Coating of Insulation of Magnet WireVOC EPA-450/2-77-0331977/124605Control of Volatile Organic Emissionsfrom Existing Stationary Sources –Volume V: Surface Coating of Large AppliancesVOC EPA-450/2-77-0341977/124603Control of Volatile Organic Emissionsfrom Bulk Gasoline Plants VOC EPA-450/2-77-0351977/124621Control of Volatile Organic Emissionsfrom Storage of Petroleum Liquids inFixed-Roof TanksVOC EPA-450/2-77-0361977/124623Control of Volatile Organic Emissions from Use of Cutback Asphalt VOC EPA-450/2-77-0371977/124641Control Techniques for Volatile Organic Emissions from Stationary Sources VOC EPA-450/2-78-0221978/05Note – This document is oftenlisted with CTGs, but it doesnot define RACT for anyparticular sourceControl of Volatile Organic Emissionsfrom Existing Stationary Sources –Volume VI: Surface Coating of Miscellaneous Metal Parts and ProductsVOC EPA-450/2-78-0151978/064603Control of Volatile Organic Emissionsfrom Existing Stationary Sources –Volume VII: Factory Surface Coating of FlatWood PanelingVOC EPA-450/2-78-0321978/064606Control of Volatile Organic Compound Leaks from Petroleum RefineryEquipmentVOC EPA-450/2-78-0361978/064453, 4454, 4455, 4625San Joaquin Valley Unified Air Pollution Control District April 16, 2009Chapter 2: CTG Source Categories and Applicable District RulesRACT Demonstration for Ozone SIP2-3Table 2-1: Control Techniques GuidelinesDescription Pollutant EPA Report Date District RulesControl of Volatile Organic Emissionsfrom Manufacture of SynthesizedPharmaceutical ProductsVOC EPA-450/2-78-0291978/12Negative DeclarationControl of Volatile Organic Emissionsfrom Manufacture of Pneumatic RubberTiresVOC EPA-450/2-78-0301978/124681Control of Volatile Organic Emissionsfrom Existing Stationary Sources –Volume VIII: Graphic Arts-Rotogravure and FlexographyVOC EPA-450/2-78-0331978/124607Control of Volatile Organic Emissions from Petroleum Liquid Storage in ExternalFloating Roof TanksVOC EPA-450/2-78-0471978/124623Control of Volatile Organic Compound Leaks fromGasoline Tank Trucks andVapor Collection SystemsVOC EPA-450/2-78-0511978/124621Control of Volatile Organic CompoundEmissions from Large Petroleum DryCleanersVOC EPA-450/3-82-0091982/094672Control of Volatile Organic CompoundEmissions from Manufacture of HighDensity Polyethylene, Polypropylene, and Polystyrene ResinsVOC EPA-450/3-83-0081983/114682, 4684Control of Volatile Organic Compound Equipment Leaks from NaturalGas/Gasoline Processing PlantsVOC EPA-450/3-83-0071983/124409, 4455Control of Volatile Organic CompoundLeaks from Synthetic Organic ChemicalPolymer and Resin Manufacturing EquipmentVOC EPA-450/3-83-0061984/034682, 4684Control of Volatile Organic Compound Emissions from Air Oxidation Processesin Synthetic Organic Chemical Manufacturing IndustryVOC EPA-450/3-84-0151984/124455Control of Volatile Organic CompoundEmissions from Reactor Processes andDistillation Operations in Synthetic Organic Chemical Manufacturing IndustryVOC EPA-450/4-91-0311993/084455Control of Volatile Organic Compound Emissions from Wood FurnitureManufacturing OperationsVOC EPA-453/R-96-0071996/044606Control Techniques Guidelines for Shipbuilding and Ship Repair Operations(Surface Coating)VOC 61 FR-440501996/08Negative DeclarationAerospace (CTG & MACT) VOC EPA-453/R-97-0041997/124605Control Techniques Guidelines for Industrial Cleaning Solvents VOC EPA-453/R-06-0012006/094601, 4607 (screen print, flexo),4663, 4684 (not fiberglass boatmfg)Control Techniques Guidelines for Offset Lithographic Printing and LetterpressPrintingVOC EPA-453/R-06-0022006/094607Control Techniques Guidelines for Flexible Package Printing VOC EPA-453/R-06-0032006/094607Control Techniques Guidelines for FlatWood Paneling Coatings VOC EPA-453/R-06-0042006/094606Control Techniques Guidelines for Paper,Film, and Foil Coatings VOC EPA 453/R-07-0032007/094607San Joaquin Valley Unified Air Pollution Control District April 16, 2009Chapter 2: CTG Source Categories and Applicable District RulesRACT Demonstration for Ozone SIP2-4Table 2-1: Control Techniques GuidelinesDescription Pollutant EPA Report Date District RulesControl Techniques Guidelines for LargeAppliance Coatings VOC EPA 453/R-07-0042007/094603Control Techniques Guidelines for Metal Furniture Coatings VOC EPA 453/R-07-0052007/094603Control Techniques Guidelines for Miscellaneous Metal and Plastic PartsCoatingsVOC EPA 453/R-08-0032008/094603Control Techniques Guidelines for FiberglassBoat Manufacturing Materials VOC EPA 453/R-08-0042008/094684Control Techniques Guidelines for Miscellaneous Industrial Adhesives VOC EPA 453/R-08-0052008/094653Control Techniques Guidelines for Automobile and Light-Duty Truck AssemblyCoatingsVOC EPA 453/R-08-0062008/094612Protocol for Determining the Daily Volatile Organic Compound Emission Rate ofAutomobile and Light-Duty Truck Primer-Surfacer and Topcoat OperationsVOC EPA 453/R-08-0022008/09Not applicable - does notrecommend emission limits or workpracticesSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 2: CTG Source Categories and Applicable District Rules

RACT Demonstration for Ozone SIP 2-5 2.1.2 CTGs Without Subject Facilities

If there are no facilities within the District’s boundaries that ar e subject to a particular CTG, the District Governing Board has two opt ions. The first option is to create and implement a RACT rule for the CTG sour ce category, even t hough there would be no source subject to the rule. The second opti on requires the District’s Governing Board to approve a negative declaration as a signed, Go verning Board resolution, stating that there are no major sources and no minor source s that would be subject to a given CTG. As required by the implementation rule for t he eight-hour NAAQS, Di strict staff reviewed
all of the CTGs and found two CTGs without applicable facilities in the SJVAB:

• Surface coating at shipbuilding and ship repair facilities

• Pharmaceutical manufacturing

In its August 2006 RACT SIP analysis, District staff investigated whet her major or minor sources that could be subject to these CTGs existed within the District’s boundaries. If District staff had found sources, the Distr ict would have had to adopt and implement prohibitory rules for these sources. At t hat time, District staff found no sources that could be subject to the CTGs listed above and prepared a negative declaration in the form of a Governing Board resolution. With this submission, District staff has reevaluated whether there are ma jor or minor sources subjec t to these CTGs within the District’s boundaries, and found t hat there are none. Theref ore, District staff is recommending that the Governing Board re-a ffirm the August 2006 negative declaration for these source categories with another signed resolution.

2.1.2.1 Surface Coating Operations at Sh ip-Building and Ship Repair Facilities (61 FR-44050)

The only port in the SJVAB large enough to suppor t a shipbuilding or ship repair facility for vessels 20 meters or more in length is t he Port of Stockton. Located on the Stockton Deepwater Ship Channel, 75 nautical miles due east of the Golden Gate Bridge, the Port of Stockton, California, owns and oper ates a diversified and major transportation center that encompasses a 2, 000-acre operating area. The Port is one mile from Interstate 5, and all interconnecting major highway systems. Rail service is provided by two transcontinental railroads, Union Pacific and the Burlington Northern Santa Fe.

The Port has berthing space for 17 vessels. There is no width restriction of vessels, and ships up to 900 feet (275 meters) in length can navigate the Stockton Ship Channel. Vessels in the 45,000 to 55,000- ton class, and maximum 60,000-ton class (for certain wide-beam vessels) can use t he channel fully loaded. Up to 80,000-ton class vessels can transit the channel parti ally loaded. The Port has first class warehouse storage and handling facilit ies for both dry and liquid bulk materials, facilities and equipment to handle break-bulk and contai nerized cargoes by land or by sea.

Immediate access to two transcontinental railroads is complemented by two loop railroads, one on-dock, for accommodating unit tr ains for export of co al, petroleum coke, and ores, plus consolidation of rail sh ipments of inbound and outbound steel coils.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 2: CTG Source Categories and Applicable District Rules

RACT Demonstration for Ozone SIP 2-6 All of the Port's services are directed thr ough one administrative complex. The Port of Stockton publishes tariffs, stevedores car goes, assigns berths, supervises cargo activity, provides shipping documentation, a ccounting and rate quotations. It is a broad hands-on effort that includes marketing, traffic, property management, warehousing, distribution, data processing and police protecti on services to its cu stomers. (Reference 1)

Although the Port of Stockton that can handle large marine vessels, the Port has no surface coating operations associated with shipbu ilding or ship repair. A survey of the District’s emissions inventory found minor amounts of marine coatings. However, further analysis determined that these emi ssions were associated with the surface coating of pleasure craft, a different source category than shipbuilding or ship repair. District staff assigned to inspect various operati ons at the Port of Stockton reported that there were no coatings operations related to shipbuilding or ship repair within the port. The management at the Port of Stockton has verbally re-confirmed this fact. On this basis, District staff recommends that the Distr ict Governing Board declare that there are no major or minor sources for surface coatin g operations at shipbuilding and ship repair

facilities.

2.1.2.2. Pharmaceutical Manufacturing Operations (EPA-450/2-78-029)

The pharmaceutical industry includes the manufacture, extrac tion, processing, purification, and packaging of chemical materials to be used as medication for humans or animals. Pharmaceutical manufacturing is divided into two ma jor processing stages, primary and secondary. Primar y processing or manufacture is the production of the active ingredient or drug. Secondary proce ssing is the conversion of the active drugs into products suitable for administration. Major pharmaceutical groups manufactured

include:

• prescription-only medicines (POM), which usually are patented products;

• standard prescription-only medicines m ade to a recognized formula, which may be specified in standard i ndustry reference books; and

• over-the-counter (OTC) or non-prescription products.

The principal manufacturing steps are: (a) preparation of process intermediates; (b) introduction of functional groups; (c) c oupling and esterification; (d) separation processes (such as washing and stripping); and (e) purification of the final product. In addition, other product preparation steps incl ude granulation; drying; tablet pressing, printing, and coating; filling; and packaging . Each of these steps may generate air emissions, liquid effluents, and solid wastes. (Reference 2)San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 2: CTG Source Categories and Applicable District Rules

RACT Demonstration for Ozone SIP 2-7 District staff searched for pharmaceutical manuf acturing within the District by looking for VOC emissions in emission inventory c ode (EIC) 410-995-5520-000 in the District’s emission inventory. This EI C is used specifically for emissions from pharmaceutical

manufacturers. There were no emissions in this EIC. A search of the Districts permits

database found that there are no facilities for any of the standard industrial codes (SICs) associated with pharmaceutical manufacturi ng, namely SICs in the range of 2830 through 2839. An Internet sear ch for pharmaceutical manufac turers in the San Joaquin Valley yielded no results. Therefore, District staff concludes that there are no pharmaceutical manufacturers in the Distr ict and recommends that District Governing Board declare that there are no major or minor sources for pharmaceutical manufacturing within the SJVAB.

2.1.2.3 References

1. Port of Stockton website - http://www.portofstockton.com

2. “Environmental Guidelines for Pha rmaceutical Manufacturing” Multilateral Investment Guarantee Agency; Fruit and Vegetable Processing. January 31, 1996. http://www.miga.org/miga_documents/ PharmaceuticalManufacturing.pdfSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 2: CTG Source Categories and Applicable District Rules

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## Chapter 3

MAJOR SOURCES AND APPLICABLE RACT RULESRACT Demonstration for Ozone SIP This page intentionally blank.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 3: Major Sources and Applicable RACT Rules

RACT Demonstration for Ozone SIP 3-1 

## Chapter 3: Major Sources and Applicable RACT Rules

3.1 MAJOR SOURCE LISTING

As discussed in Chapter 2, the District is r equired to evaluate the rules that apply to major sources. Staff began by querying the District’s database of current Permits to Operate to identify the facilities that have the potential to emit at least ten tons per year
of either NOx or VOC. The individual facili ties are listed in Tabl e 3-1, along with the NOx and VOC rules that apply to the facility’s equipment.

Two clarifications should be noted in Table 3-1.

• First, several facilities shown in Table 3- 1 will become subject to VOC rules that the District is currently developing. Thes e facilities are identified with a mark in

the column titled “New.” For example, the District is currently developing Rule 4566 (Organic Waste Operations) and Rule 4694 (Brandy and Wine Aging Operations). These are the first rules of their kind anywhere (no other agency has an existing rule), and EPA has not promulgated a CTG for the category. When the District rule is adopted, it will in essence, establish RACT nationwide for those source categories.

• Second, in Table 3-1, ther e are several facilities where the units or processes are so small (or have such low throughputs), that the units are exempt from the District’s prohibitory rule. These faciliti es are marked with an “o” instead of an “x” for a specific rule. It should be emphasized that a facility’s exem ption from a rule does not signify that the rule does not meet RACT. The District goes through a methodical and reasoned process as it develops the emission limits and applicability thresholds for its prohib itory rules, with input from EPA and

stakeholders from numerous and divers e groups. Chapter 4 demonstrates how

District rules meet or exceed RACT requirements, including exemption

thresholds.San Joaquin Valley Unified Air Pollution Control DistrictApril 16, 2009

Region ID #Facility Name Facility Description 4103 4104 4106 4301 4306 4307 4308 4309 4311 4313 4352 4354 4401 4402 4404 4407 4408 4409 4453 4454 4455 4565 4570 4601 4602 4603 4604 4605 4606 4607 4610 4612 4621 4622 4623 4624 4625 4641 4642 4651 4652 4653 4661 4662 4663 4672 4681 4682 4684 4691 4692 4693 4694 4702 4703 4902 4905 New RuleC 14 FRESNO COGENERATION PARTNERS COGENERATION x xx xC 17 ALBRECHT FARMS AGRICULTURAL PRODUCTS PROCESSING oC 26 ALTA OIL COMPANY BULK PLANTxC 36 PACTIV CORPORATION PLASTIC FOAM PRODUCTSx x xxC 72 BAKER COMMODITIES, INC. RENDERING x x x x xC 73 BALTIMORE AIRCOIL OF CAL AIR CONDITIONING AND HEATING EQUIPMENT MFRxC 120 THE WINE GROUP, INC. WINERYxC 149 BROADVIEW COOP GIN COTTON GINNINGoC 150 NEWBY ISLAND LANDFILL MUNICIPAL WASTE LANDFILLxC 194 WOOLF ENTERPRISES AGRICULTURAL CROP PRODUCTIONxx xC 195 CALIF STATE PRISON - AVENAL CORRECTIONAL INSTITUTION x x x x x x x xxC 214 CALIF STATE PRISON - CORCORAN CORRECTIONAL INSTITUTION xx x xx xC 218 CALIFORNIA ARMY NATIONAL GUARD MILITARY INSTALLATIONxC 246 HUBBELL LENOIR CITY INC POLYMER CONCRETE/FIBERGLASS MANUFACTURINGxx xC 261 CERTAINTEED CORPORATION FIBERGLASS MANUFACTURING OPERATION x xxC 264 EXOPACK LLC COMMERCIAL PRINTINGx xC 282 GUTHRIE PETROLEUM INC BULK PLANTx xC 283 CHEMICAL WASTE MANAGEMENT, INC WASTE DISPOSALx xx x xC 306 CHEVRON PIPELINE CO -TANK FARM CRUDE PETROLEUM PIPELINESx xC 311 CHEVRON USA INC OIL PRODUCTION x x x x x x x x xC 336 GENERAL PETROLEUM DBA BRYANT PETROLEUM BULK PLANTx xC 343 CLOVIS UNIFIED SCHOOL DISTRICT ELEMENTARY AND SECONDARY SCHOOLSxx x xx xC 354 COALINGA COGENERATION CO ELECTRIC AND OTHER SERVICES COMBINEDxxC 366 DEL MONTE CORPORATION AGRICULTURAL PRODUCTS PROCESSING x xxC 393 SILVAS OIL COMPANY, INC. BULK PLANTx xC 402 CALIFORNIA DAIRIES, INC. MILK PROCESSING PLANT xxC 406 DARLING INTERNATIONAL INC. RENDERING PLANT xC 443 DUREY LIBBY EDIBLE NUTS INC AGRICULTURAL PRODUCTS PROCESSING DEHYDRATING xC 447 E & J GALLO WINERY WINERY x x x x x x x xC 495 FLORESTONE PRODUCTS CO, INC PLASTICS PLUMBING FIXTURE MANUFACTURINGxx xC 497 JOHN BEAN TECHNOLOGIES CORPORATION FOOD PROCESSING EQUIPMENT MANUFACTURING xxxC 528 FRESNO AREA EXPRESS BUS LINE OPERATIONxxC 535 FRESNO/CLOVIS REGIONAL WWTP WASTEWATER RECLAMATION FACILITY x x x xx xC 540 FRESNO COMMUNITY HOSPITAL HOSPITAL xxC 568 GEORGIA-PACIFIC CORRUGATED LLC C0RRUGATED AND SOLID FIBER BOXES xxx x xC 581 GOLDEN STATE VINTNERS WINERYxx xC 591 GRAYLIFT, INC. EQUIPMENT RENTALxC 597 GRUNDFOS PUMPS CORPORATION PUMP MANUFACTURINGx xC 598 GUARDIAN INDUSTRIES CORP GLASS MANUFACTURINGx xxC 603 HANFORD L P ELECTRICAL GENERATION x x xC 628 C W US INC DBA MISSION BELL WINERY WINERY x x xxC 629 O'NEILL BEVERAGES CO LLC WINERYxx xC 646 CON AGRA FOODS AGRICULTURAL PRODUCTS PROCESSING xC 650 CALMAT CO. ASPHALT PAVING MIXTURES xC 651 CALMAT CO. ASPHALT PAVING MIXTURES xC 652 CALMAT CO. ASPHALT PAVING MIXTURES xC 705 J R SIMPLOT COMPANY FERTILIZER PRODUCTION x x x x xC 713 KEENAN FARMS INC AGRICULTURAL PRODUCTS PROCESSING, PISTACHIOS xC 722 KINGSBURG COGEN FACILITY COGENERATION x x x x xC 724 KINGS COUNTY PUBLIC WORKS DEPT GOVERNMENTAL AGENCYxx xC 741 LAMANUZZI & PANTALEO AGRICULTURAL PRODUCTS PROCESSING xC 782 LIFTCO CAPS SANDBLASTING METAL PARTS AND PRODUCTS COATINGxC 790 CAVALLETTO RANCHES AGRICULTURAL PRODUCTS PROCESSING - ALMONDS xC 799 MADERA POWER, LLC POWER GENERATION x x xC 801 SAINT-GOBAIN CONTAINERS, INC GLASS MANUFACTURING x x xxC 825 COVANTA MENDOTA LP POWER GENERATION x x x x x xC 847 MODERN WELDING STEEL STORAGE TANK FABRICATIONx xxC 898 PACIFIC BELL TELEPHONE CO (DBA AT&T CA) TELECOMMUNICATIONSx xC 904 PACIFIC GAS & ELECTRIC CO PUBLIC UTILITYxxC 948 PPG INDUSTRIES GLASS MANUFACTURINGx xC 954 PRISON INDUSTRY AUTHORITY-AVENAL CORRECTIONAL INSTITUTIONxx xxC 986 QUINN COMPANY INDUSTRIAL EQUIPMENT SALESx xx xC 996 EARTHGRAINS BAKING COMPANIES INC BAKERYxxC 999 VAN DE POL ENT INC DBA RATHAMANN OIL CO BULK PLANTx xC 1027 R L VERNON BULK PLANTx xC 1037 ROE OIL COMPANY BULK PLANTx xC 1042 BATTH DEHYDRATOR LLC AGRICULTURAL PRODUCTS PROCESSING - DEHYDRATING oC 1046 GUTHRIE PETROLEUM INC BULK PLANTxC 1059 SAINT AGNES MEDICAL CENTER HOSPITAL xx xC 1066 J G BOSWELL COMPANY COTTON GINNINGoC 1069 RAGHBIR S BATTH DBA SANGER DEHYDRATOR AGRICULTURAL PRODUCTS PROCESSING xC 1074 SANGER BOATS, INC. BOAT MANUFACTURINGx xxC 1077 SFPP, L.P. PETROLEUM TRANSPORTATIONx x xx xC 1089 SEALED AIR CORPORATION PLASTIC FOAM PRODUCTS MANUFACTURINGx xC 1121 AERA ENERGY LLC PETROLEUM PRODUCTION x x x x x x xC 1163 SK FOODS INC AG PRODUCTS PROCESSING - FRUITS/VEGETABLES x xxC 1179 SPRECKELS SUGAR COMPANY BEET SUGAR MANUFACTURING x x x x x x x xC 1203 SURABIAN PACKING COMPANY, INC. AGRICULTURAL PRODUCTS PREPARATIONC 1234 SHELL PIPELINE COMPANY LP PETROLEUM TRANSPORTATION x x x x x xC 1243 TOMA-TEK INC TOMATO PROCESSING xC 1244 GENERAL PETROLEUM BULK PLANTx xC 1259 MODERN CUSTOM FABRICATION, INC METAL FABRICATIONx xx xC 1301 CONOCOPHILLIPS PIPE LINE COMPANY PETROLEUM PIPELINESx xTable 3-1: Major Sources and Applicable RACT Rules3-2Chapter 3: Major Sources and Applicable RACT RulesRACT Demonstration for Ozone SIPSan Joaquin Valley Unified Air Pollution Control DistrictApril 16, 2009

Region ID #Facility Name Facility Description 4103 4104 4106 4301 4306 4307 4308 4309 4311 4313 4352 4354 4401 4402 4404 4407 4408 4409 4453 4454 4455 4565 4570 4601 4602 4603 4604 4605 4606 4607 4610 4612 4621 4622 4623 4624 4625 4641 4642 4651 4652 4653 4661 4662 4663 4672 4681 4682 4684 4691 4692 4693 4694 4702 4703 4902 4905 New RuleTable 3-1: Major Sources and Applicable RACT RulesC 1306 US ARMY CORPS/PINE FLAT HDQTR RECREATIONAL PROGRAM ADMINISTRATION - GOVxx xC 1326 VALLEY FIG GROWERS AGRICULTURAL PRODUCTS PROCESSING - DEHYDRATING xC 1336 VA MEDICAL CENTER HOSPITALS xxC 1344 VIE-DEL WINERY #1 AGRICULTURAL PRODUCTS PROCESSING, WINERY xxC 1353 THE WINE GROUP LLC DBA ALMADEN-MADERA WINERY x x xxC 1355 V/M CUSTOM BOAT TRAILERS TRANSPORTATION EQUIPMENT MANUFACTURINGxC 1356 VOGEL FRAME CO INC WOOD PRODUCTSxC 1361 WASCO HARDFACING METALS PARTS & PRODUCTS COATINGxC 1371 WESTERN STAR SANDBLASTING CO. NONCLASSIFIABLE ESTABLISHMENTSxC 1383 WESTSIDE FARMERS COOP #2 & #3 COTTON GINNINGoC 1385 ANDERSON CLAYTON CORP/SILVER C COTTON GINNINGoC 1387 WEST HILLS OIL, INC. BULK PLANT WITH GASOLINE DISPENSINGx xC 1396 INTERNATIONAL PAPER COMPANY CORRUGATED CARDBOARD BOX MANUFACTURER xxxxC 1555 J G BOSWELL COMPANY AGRICULTURAL PRODUCTS PROCESSING x x x x xC 1562 WESTERN WASTE INDUSTRIES REFUSE TRANSPORTINGxC 1594 DEL MONTE CORPORATION AG PRODUCTS PROCESSING - FRUITS/VEGETABLES xxC 1658 EXARO ENERGY LLC OIL AND GAS PRODUCTIONxC 1683 HOLMES WESTERN OIL CORPORATION PETROLEUM PRODUCTIONx xC 1694 SUNSWEET DRYERS AGRICULTURAL PRODUCTS PROCESSING - DEHYDRATING oC 1713 J W MYERS, INCORPORATED BULK PLANT WITH GASOLINE DISPENSINGxC 1820 RIO BRAVO FRESNO ELECTRICAL SERVICES COGENERATION x x x xC 1854 C CASE COMPANY OIL AND GAS PRODUCTIONx xC 2012 STEEL STRUCTURES INC METAL FABRICATIONx xxC 2041 VALLEY GRAIN/AZTECA MILLING AGRICULTURAL PRODUCTS PROCESSING xC 2106 NAS LEMOORE/ PUBLIC WORKS MILITARY BASExxx xx x xC 2249 SAMSON RESOURCES COMPANY OIL AND GAS PRODUCTIONxC 2253 SILGAN CONTAINERS MANUFAC CORP CAN COATINGxC 2265 GARY V. BURROWS INC. BULK PLANTx xC 2272 OLSON & COMPANY STEEL METAL FABRICATIONx xxC 2283 CALIF STATE PRISON- CHOWCHILLA CORRECTIONAL INSTITUTIONx xx xC 2341 NAS LEMOORE MILITARY INSTALLATION xx xx xx xC 2349 CLOVIS-SANGER CABINET MFG WOOD PRODUCTSxC 2444 ITO PACKING COMPANY INC AG PRODUCTS PROCESSING - FRUITS/VEGETABLESxC 2471 STURDY SAFE METAL PARTS & PRODUCTS COATINGxC 2646 PB LOADER CORPORATION FARM MACHINERY AND EQUIPMENTxC 2675 WHOLESALE EQUIPMENT OF FRESNO MOBILE EQUIPMENT COATINGxC 2696 CALAVERAS MATERIALS INC ASPHALT PAVING MIXTURES xC 2709 PACIFIC PRINTING COMMERCIAL PRINTING, LITHOGRAPHIC xxC 2852 TRI BORO FRUIT CO INC CROP PREPARATION SERVICE oC 2872 CHEVRON USA, INC. OIL AND GAS PRODUCTIONxC 2883 COUNTY OF KINGS GOVERNMENT SERVICESxC 2885 CHEVRON USA, INC. NATURAL GAS PRODUCTIONx xxC 2902 CHILDRENS HOSPITAL OF CENTRAL CALIFORNIA HOSPITAL xxC 2908 SALWASSER INC AGRICULTURAL PRODUCTS PROCESSINGC 2913 MADERA COUNTY RESOURCE MGMT AGENCY WASTE DISPOSALx xC 3062 ANDERSON PUMP CO, INC INDUSTRIAL EQUIPMENT SALES - PUMPSxC 3071 WARMERDAM PACKING AGRICULTURAL PRODUCTS PROCESSING - FRUITSxC 3115 COUNTY OF FRESNO PUBLIC WORKS LANDFILL (EG SOURCE) x xC 3375 TRI-COUNTIES WALNUT CO AGRICULTURAL PRODUCTS PROCESSING xC 3402 JCW CO. WOOD KITCHEN CABINETSx xC 3549 INTERIOR SERVICES AND DESIGN METAL PARTS AND PRODUCTS COATINGxC 3591 WESTERN MANUFACTURING CORP. METAL PARTS AND PRODUCTS COATINGxC 3649 CHIN-CHING HSU DBA POLYCELL PACKAGING PLASTICS, FOAM PRODUCTS MANUFACTURINGxC 3775 CALIFORNIA POWER HOLDINGS LLC POWER GENERATIONxC 3811 CAL PEAK POWER, LLC POWER GENERATIONxxC 3839 AVENAL REGIONAL LANDFILL LANDFILL (EG SOURCE)xC 3843 WELLHEAD POWER LLC POWER GENERATIONxx xC 3844 WELLHEAD POWER PANOCHE, LLC. POWER GENERATIONx xC 3929 GWF ENERGY LLC - HENRIETTA ELECTRICAL GENERATIONxxC 3955 LEPRINO FOODS COMPANY CHEESE PRODUCTION x xxC 4051 COALINGA STATE HOSPITAL HOSPITAL xxx xC 4140 GWF ENERGY LLC POWER GENERATIONxxC 4261 PACIFIC ETHANOL MADERA LLC INDUSTRIAL ORGANIC CHEMICALS x x x xC 4305 KINGS RIVER CONSERVATION DISTRICT POWER GENERATIONxC 4352 CSATF/CA SUBSTANCE ABUSE TREATMENT FACIL CALIFORNIA SUBSTANCE ABUSE TREATMENT FACILITY xxx xx xx xC 4998 TERRANOVA RANCH INC AGRICULTURAL CROP PRODUCTIONx xC 5097 MANZANILLO RANCH AGRICULTURAL CROP PRODUCTIONxC 5163 DLM PARTNERS AGRICULTURAL CROP PRODUCTIONx xC 5166 HARRIS FARMS INC AGRICULTURAL CROP PRODUCTIONxC 5169 MOUREN FAMILY FARMS, INC AGRICULTURAL CROP PRODUCTIONxC 5191 CENTRAL GREEN COMPANY AGRICULTURAL CROP PRODUCTIONx xC 5202 LOUIS D CAVALLETTO DBA CAVALLETTO RANCH AGRICULTURAL CROP PRODUCTIONxx xC 5218 ZONNEVELD FARMS #1 AGRICULTURAL CROP PRODUCTIONxx xC 5225 CMA GENERAL PARTNERSHIP AGRICULTURAL CROP PRODUCTIONxC 5226 SHEIN RANCH AGRICULTURAL CROP PRODUCTION, DAIRYxxC 5289 DIAMOND H DAIRY DAIRY FARMx xx xC 5318 DON HEADRICK AGRICULTURAL CROP PRODUCTIONx xC 5326 KANWARJIT & GAGANDIP BATTH FARMS AGRICULTURAL CROP PRODUCTIONxx xC 5356 JOHN VISSER DAIRY AGRICULTURAL CROP PRODUCTION, DAIRYx xxC 5370 LOVELACE & SONS FARMING AGRICULTURAL CROP PRODUCTIONxx xC 5417 VLOT BROTHERS DAIRY & HEIFER RANCH AGRICULTURAL CROP PRODUCTION, DAIRY,FEEDLOTx xC 5427 DAVID TEVELDE DAIRY AGRICULTURAL CROP PRODUCTION, DAIRYx xxC 5469 JOHANN DAIRY DAIRY FARMxx x3-3Chapter 3: Major Sources and Applicable RACT RulesRACT Demonstration for Ozone SIPSan Joaquin Valley Unified Air Pollution Control DistrictApril 16, 2009

Region ID #Facility Name Facility Description 4103 4104 4106 4301 4306 4307 4308 4309 4311 4313 4352 4354 4401 4402 4404 4407 4408 4409 4453 4454 4455 4565 4570 4601 4602 4603 4604 4605 4606 4607 4610 4612 4621 4622 4623 4624 4625 4641 4642 4651 4652 4653 4661 4662 4663 4672 4681 4682 4684 4691 4692 4693 4694 4702 4703 4902 4905 New RuleTable 3-1: Major Sources and Applicable RACT RulesC 5472 JESSE SILVA DAIRY AGRICULTURAL CROP PRODUCTION, DAIRYxC 5513 FRED RAU DAIRY INC AGRICULTURAL CROP PRODUCTIONxC 5524 RIVER RANCH DAIRY AGRICULTURAL CROP PRODUCTION, DAIRYx xx xC 5613 CHARANJIT S BATTH AGRICULTURAL CROP PRODUCTIONxx xC 5658 OPC EQUIPMENT COMPANY, INC AGRICULTURAL CROP PRODUCTIONxC 5715 VINTAGE DAIRY AGRICULTURAL CROP PRODUCTION, DAIRYxxC 5749 J G BOSWELL (HOMELAND RANCH SOURCE) AGRICULTURAL CROP PRODUCTIONxC 5858 AVILA FAMILY DAIRY LLC DAIRY FARMSxC 6029 FERNANDES DAIRY DAIRY FARMxx xC 6046 MARTIN RANCH DAIRY LLC DAIRY FARMxC 6047 TURNER RANCH FAMILY DAIRY DAIRY FARMxC 6426 F & B RANCHES AG OPERATIONxC 6529 HIGARD FARMS LLC VEGETABLES AND MELONSxC 6537 BORBA BROTHERS FARMS AG OPERATIONxC 6894 LEMSTRA CATTLE COMPANY, LLC DAIRYxC 6927 MADDOX FARMS AGRICULTURAL CROP PRODUCTIONxC 7020 HOLLANDIA FARMS DAIRY FARMxxC 7021 CLOVERDALE DAIRY, LLC DAIRY FARMxxC 7057 VALLEY VIEW FARMS DAIRY FARMSxx xC 7066 WREDEN RANCH DAIRY DAIRY FARMxC 7075 PINE FLAT LAKE MARINA INC MARINAx xC 7253 HERITAGE ORCHARDS LLC FRUITS AND TREE NUTSxC 7307 WHITNEY OAKS AGRICULTURAL CROP PRODUCTION, DAIRYx xx xC 7310 RIVER RANCH FARMS AGRICULTURAL CROP PRODUCTIONxC 7656 DE GROOT DAIRY FARM (SOUTH) DAIRY FARMxC 7679 JERSEYLAND FARMS AGRICULTURAL CROP PRODUCTION, DAIRYxN 33 ANGKOR AUTO BODY & PAINT METAL PARTS AND PRODUCT COATINGx xN 164 CALIFORNIA SPRAY DRY CO RENDERING PLANT x x xN 180 CARPENTER CO. FOAM MANUFACTURING x x x xN 188 ROBERTSON CECO II CORP/STAR BLDG SYSTEMS METAL BUILDING MANUFACTURING FACILITYx xN 199 CHEVRON USA GASOLINE DISTRIBUTIONx x xx xN 222 COMMERCIAL BLDG COMPONENTS, INC METAL FABRICATIONxN 238 CORN PRODUCTS GRAIN MILLING AND PROCESSING - WET CORN MILLING x xxN 257 DART CONTAINER CORPORATION STYROFOAM CONTAINERS MANUFACTURING x x xxN 266 DELICATO VINEYARDS WINERYxxx xN 285 DIAMOND FOODS INCORPORATED AGRICULTURAL PRODUCTS PROCESSING - WALNUTS x xxN 298 EARTHGRAINS BAKING COMPANIES INC BAKERYxxN 314 H. J. HEINZ COMPANY, L.P. AG PRODUCTS PROCESSING - FRUITS/VEGETABLES x xN 339 FORWARD INC LANDFILLx xxx xN 355 GENERAL MILLS INC CEREAL MANUFACTURER x x xx xN 366 GRANITE CONSTRUCTION ASPHALTIC CONCRETE PRODUCTIONx xN 367 GRANITE CONSTRUCTION CO AGGREGATE AND ASPHALTIC CONCRETE PRODUCTIONxN 408 HOLZ RUBBER COMPANY, INC SYNTHETIC RUBBER xx xN 421 TIN INC DBA TEMPLE-INLAND CORRUGATED PAPERBOARD CONTAINER MANUFACTURER xxxN 474 LEPRINO FOODS FOOD PROCESSOR xxN 477 PILKINGTON NORTH AMERICA INC FLAT GLASS MANUFACTURER x x xxN 479 MONIERLIFETILE LLC CONCRETE PRODUCTS - ROOFING TILE MANUFACTURINGxN 493 LODI IRON WORKS, INC IRON FOUNDRYx xN 524 N.J. MCCUTCHEN, INC. METAL PARTS AND PRODUCT COATINGxN 556 MONIERLIFETILE L.L.C. CONCRETE PRODUCTS - ROOFING TILE MANUFACTURINGx xN 566 MUNN AND PERKINS, INC ASPHALT PAVING MIXTURES AND BLOCKS xN 583 NORTHERN CALIFORNIA POWER AGENCY POWER GENERATIONxN 593 OWENS-BROCKWAY GLASS CONTAINER GLASS CONTAINER MANUFACTURER x xxN 594 PACIFIC COAST PRODUCERS AGRICULTURAL PRODUCTS PROCESSING x xN 608 PG&E - CGO/ ENVRN CORD NATURAL GAS DISTRIBUTIONx x xxx xN 645 POSDEF POWER COMPANY, L.P. POWER GENERATION FACILITY x x x xxN 672 UNILEVER SUPPLY CHAIN INC AGRICULTURAL PRODUCTS PROCESSING x xxN 717 A. SAMBADO & SON, INC. AGRICULTURAL PRODUCTS PROCESSINGN 758 EQUILON ENTERPRISES LLC BULK TERMINALx xN 767 J R SIMPLOT COMPANY FERTILIZER MANUFACTURING x x x x x x x x xN 770 RIPON COGENERATION LLC COGENERATION FACILITY x x xxN 802 STOCKTON COGEN COMPANY ELECTRICAL POWER PLANT x x x xN 811 STOCKTON MUNICIPAL UTIL DEPT WASTEWATER TREATMENT FACILITY x x x x xN 812 THE HERRICK CORPORATION METAL FABRICATIONxN 823 STOCKTON EAST WATER DISTRICT WATER TREATMENT FACILITYx xx xN 829 ST SERVICES, LLC BULK FUEL STORAGE TERMINALx xx xN 846 SHELL PIPELINE COMPANY LP PETROLEUM PIPELINES x x x xN 886 TUFF BOY, INC. TRUCK TRAILER MANUFACTURINGx xN 956 THE WINE GROUP INC WINERY x xx xN 964 GEORGE REED INC. ASPHALTIC CONCRETE MANUFACTURING xN 994 8309 TUJUNGA AVENUE CORPORATION POWER GENERATIONxN 1002 LODI METAL TECH INC METAL PARTS AND PRODUCT COATING OPERATIONx xN 1026 THERMAL ENERGY DEV PARTNERSHIP LP ELECTRICAL GENERATION FACILITY x x xxN 1027 COLORADO ENERGY MGMT/ENVIRO COGENERATION FACILITYxx xN 1044 GB INDUSTRIAL SPRAY METAL PARTS AND PRODUCTS COATINGx xN 1045 HUBBARD FEEDS, INC. ANIMAL FEED PROCESSINGxN 1075 B&C PAINTING SOLUTIONS INC METAL PARTS AND PRODUCTS COATING OPERATIONx xN 1100 U S INTEC, INC. ASPHALT ROOFING PRODUCTS MANUFACTURING FACILITYx xN 1119 NORTH COUNTY SANITARY LANDFILL LANDFILLx xN 1174 SUN GARDEN-GANGI CANNING CO AGRICULTURAL PRODUCTS PROCESSING xN 1237 E & J GALLO WINERY WINERY x x x x x x xN 1246 FINELINE INDUSTRIES INC MANUFACTURER OF FIBERGLASS BOATSxxN 1248 FOSTER POULTRY FARMS-KOPRO MANURE COMPOSTING STORAGE FACILTIY x3-4Chapter 3: Major Sources and Applicable RACT RulesRACT Demonstration for Ozone SIPSan Joaquin Valley Unified Air Pollution Control DistrictApril 16, 2009

Region ID #Facility Name Facility Description 4103 4104 4106 4301 4306 4307 4308 4309 4311 4313 4352 4354 4401 4402 4404 4407 4408 4409 4453 4454 4455 4565 4570 4601 4602 4603 4604 4605 4606 4607 4610 4612 4621 4622 4623 4624 4625 4641 4642 4651 4652 4653 4661 4662 4663 4672 4681 4682 4684 4691 4692 4693 4694 4702 4703 4902 4905 New RuleTable 3-1: Major Sources and Applicable RACT RulesN 1252 FOSTER FOOD PRODUCTS MEAT PROCESSING AND RENDERING FACILITY x x xxN 1276 INGOMAR PACKING COMPANY PRODUCE PROCESSING PLANT x x xN 1302 MCCONNELL RECREATION AREA PARKS AND RECREATIONx xN 1326 MORNING STAR PACKING COMPANY AGRICULTURAL PRODUCTS PROCESSING xxN 1351 MORNING STAR MERCED LLC AGRICULTURAL PRODUCTS PROCESSING xxN 1399 LIBERTY PACKING CO - THE MORNING STAR CO AGRICULTURAL PRODUCTS PROCESSING xxN 1646 QUEBECOR WORLD COMMERCIAL PRINTINGx xxN 1647 CALAVERAS MATERIALS INC. ASPHALT PAVING MIXTURESx xN 1657 SENSIENT DEHYDRATED FLAVORS COMPANY DEHYDRATED VEGETABLE PROCESSING x x x x xxN 1662 GALLO GLASS COMPANY GLASS MANUFACTURING PLANT x xxN 1665 BRONCO WINE COMPANY WINERYx x xx xxN 1679 SANTA FE AGGREGATES, INC. AGGREGATE AND ASPHALTIC CONCRETE PRODUCTION xN 1680 STANISLAUS FOOD PRODUCTS TOMATO PROCESSING FACILITY x xxN 1719 SILGAN CONTAINERS MFR. CORP. METAL CANSxN 1787 GILROY FOODS VEGETABLE PROCESSING AND DEHYDRATING x x xN 1919 FRITO-LAY NORTH AMERICA INC FOOD PROCESSING FACILITY x xN 1931 GAYLORD MANUFACTURING CO METAL PARTS & PRODUCTS MANUFACTURINGxN 1976 CONAGRA FOODS FOOD PRODUCTS PROCESSING xxN 1980 EVERGREEN BEVERAGE PACKAGING CONVERTED PAPER PRODUCTS MANUFACTURERx xN 1982 INTERNATIONAL PAPER COMPANY CORRUGATED AND SOLID FIBER BOXES xxN 2010 GEORGE W. LOWRY, INC. GASOLINE DISTRIBUTIONx xN 2022 MEMORIAL HOSPITAL NORTH HOSPITAL AND MEDICAL CENTER x xxN 2052 MID - ATTN: GENERAL MANAGER ELECTRIC POWER GENERATIONxxN 2073 COVANTA STANISLAUS, INC MUNICIPAL SOLID WASTE COMBUSTORxN 2107 DARLING INTERNATIONAL, INC. RENDERING x x xN 2149 CALIFORNIA DAIRIES, INC. MILK PROCESSING x xxN 2174 SILGAN CONTAINERS MFR. CORP. CAN AND CONTAINER MANUFACTURINGxx x xN 2224 SHELL PIPELINE COMPANY LP CRUDE PETROLEUM PIPELINES x xxN 2232 SENECA FOODS LLC FRUIT CANNING FACILITY x xxN 2246 TURLOCK IRRIGATION DISTRICT POWER GENERATION FACILITYxx xN 2253 BALL METAL FOOD CONTAINER CORP. CAN & COIL MANUFACTURINGxx xN 2274 VARCO PRUDEN BUILDINGS, INC. PREFABRICATED METAL BUILDINGS AND COMPONENTSx xN 2279 GEORGE W. LOWRY, INC. GASOLINE DISTRIBUTIONx xN 2303 CALAVERAS MATERIALS INC. ASPHALT PAVING MIXTURESx xN 2305 INTERNATIONAL PAPER COMPANY PAPERBOARD CONTAINER MANUFACTURER xxN 2321 RME INC - WOODBRIDGE WINERY WINERYxx xx xN 2355 RECYCLE TO CONSERVE ANIMAL FEED PROCESSING xN 2360 GALLO GLASS COMPANY NONCLASSIFIABLE ESTABLISHMENTS xN 2369 BP WEST COAST PRODUCTS, LLC CLASS 1 ORGANIC LIQUID LOADING FACILITYx xx xN 2697 NORTHERN CALIFORNIA POWER COGENERATION FACILITYxxN 2835 TEICHERT AGGREGATES SAND AND GRAVEL xN 3006 R & B PAINTING & SANDBLASTING METAL PARTS AND PRODUCTS COATINGxN 3038 MONSCHEIN INDUSTRIES INC CABINET MANUFACTURING FACILITYxN 3075 JRW & ASSOCIATES COGENERATION ELECTRICAL SERVICESxN 3095 SAN JOAQUIN DELTA COLLEGE COLLEGES AND UNIVERSITIES x xxN 3104 GEER RD LANDFILL C/O FINK ROAD LANDFILL LANDFILLxx xN 3202 BIRCHWOOD CABINETS, MODESTO WOOD PRODUCTSxN 3233 MID - GENERATION MANAGER POWER GENERATION FACILITYxxN 3243 SILGAN CONTAINERS MFR. CORP. CAN AND CONTAINER MANUFACTURERx xN 3299 TURLOCK IRRIGATION DISTRICT POWER GENERATION FACILITYxx xN 3309 G-3 ENTERPRISES, LABEL DIVISION GRAPHIC ARTS FACILITYxxN 3386 E & J GALLO WINERY/LINK PLANT MAINT WINERY x x x x x xN 3433 AMERICAN MODULAR SYSTEMS, INC. MODULAR BUILDING MANUFACTURINGx xN 3500 MATTHEWS REDWOOD, INC. WOOD CONTAINERSxN 3585 VALLEY PRINTING GRAPHIC ARTS PRINTING OPERATIONxN 3606 PACIFIC SOUTHWEST CONTAINER PRINTING OF CONTAINERS & PACKAGING MATERIALSx xN 3696 MERCED CO DEPT OF PUBLIC WORKS LANDFILLx xx xN 3715 CUSTOM MARBLE & ONYX POLYESTER RESIN CASTING OPERATIONxN 3780 ENVIROPLEX INC MODULAR BUILDING MANUFACTURINGx xN 3791 MARBLE PALACE INC SYNTHETIC MARBLE MANUFACTURINGxN 3852 LABEL TECHNOLOGY, INC. COMMERCIAL PRINTINGxN 3941 MALIBU BOATS LLC FIBERGLASS BOAT MANUFACTURINGx xxN 3969 GEER RD LANDFILL C/O FINK RD LANDFILL LANDFILLxx x xxxN 4013 JAXON ENTERPRISES SAND, GRAVEL, AND ASPHALT PROCESSING xN 4065 BARBOSA CABINETS, INC. MANUFACTURER OF WOODEN CABINETSxxN 4070 SAN JOAQUIN COUNTY LANDFILLx xN 4080 OAKDALE COMMERCIAL FEED YARD ANIMAL FEED MANUFACTURINGxN 4148 WELDWAY INC. STEEL FABRICATORxN 4238 LODI GAS STORAGE LLC NATURAL GAS TRANSMISSION x xxN 4247 TEICHERT AGGREGATES ASPHALT PAVING MIXTURES xN 4316 AMERICAN HIGHWAY TECHNOLOGY METAL FABRICATIONxN 4338 PREMIER COATINGS DBA PREMIER FINISHING METAL PARTS AND PRODUCT COATINGxx x xN 4390 WASTEQUIP MFG CO/MCLAUGHLIN REFUSE EQUIP METAL PARTS AND PRODUCTS COATINGxN 4422 DESIGNED MOBILE SYSTEMS IND GENERAL BUILDING CONTRACTORS-NONRESIDENTIALx xN 4473 DSS COMPANY ASPHALT BATCH PLANT xN 4592 SPORT BOAT TRAILERS TRANSPORTATION EQUIPMENT, NECx xN 4597 GWF ENERGY LLC-TRACY PEAKER POWER PLANT ELECTRIC POWER GENERATIONxxN 4680 DOPACO, INC BEVERAGE CONTAINER MANUFACTURINGxN 4939 C W US INC DBA TURNER ROAD VINTNERS WINERYxxN 4940 MODESTO IRRIGATION DISTRICT POWER GENERATION FACILITYxN 4968 CITY OF CERES WATER SUPPLYxN 5177 FRAZIER NUT FARMS INC AGRICULTURAL CROP PRODUCTIONxN 5526 RAINBOW FARMS CHICKEN EGGSxx x3-5Chapter 3: Major Sources and Applicable RACT RulesRACT Demonstration for Ozone SIPSan Joaquin Valley Unified Air Pollution Control DistrictApril 16, 2009

Region ID #Facility Name Facility Description 4103 4104 4106 4301 4306 4307 4308 4309 4311 4313 4352 4354 4401 4402 4404 4407 4408 4409 4453 4454 4455 4565 4570 4601 4602 4603 4604 4605 4606 4607 4610 4612 4621 4622 4623 4624 4625 4641 4642 4651 4652 4653 4661 4662 4663 4672 4681 4682 4684 4691 4692 4693 4694 4702 4703 4902 4905 New RuleTable 3-1: Major Sources and Applicable RACT RulesN 5635 WILLOW DAIRY DAIRY FARMxN 5636 COTTONWOOD DAIRY DAIRY FARMxxN 5638 BEAR CREEK DAIRY DAIRY FARMxN 5639 BAMBOO DAIRY DAIRY FARMxN 5695 CASTELANELLI BROS AGRICULTURAL CROP PRODUCTION x x x x xN 7105 AUGUST RANCH POULTRY RANCHxxN 7172 WALNUT ENERGY CENTER AUTHORITY POWER GENERATION FACILITYx xN 7478 E & J GALLO WINERY - BRANDY DISTILLED SPIRITS oxN 7737 ROY JOHNSON FARMS, INC. ALMOND FARMINGxN 7827 CITY OF MODESTO COMPOSTING FACILITY COMPOSTING FACILITYxN 7899 SCONZA CANDY COMPANY CANDY AND CONFECTIONARY MANUFACTURING xx xS 4 TEHACHAPI-CUMMINGS WATER DIST WATER SUPPLYxxS 33 BIG WEST PETROLEUM REFINERY x x x x x x x x x x x xS 34 BIG WEST OF CA, LLC PETROLEUM REFINERY x x x x x x x x x xS 35 L P O D, INC PETROLEUM OILS DEHYDRATION OPERATION x x x x x x xS 36 SAN JOAQUIN REFINING COMPANY PETROLEUM REFINING x x x x x x x x xS 37 KERN OIL & REFINING COMPANY PETROLEUM REFINING x x x x x x xxxxxx xxS 39 INERGY PROPANE LLC MIXED, MANUFACTURED OR LPG PRODUCTION x x x x x x x xS 40 CENTRAL RESOURCES INC NATURAL GAS PRODUCTION x x x x x xS 44 TRICOR REFINING, LLC PETROLEUM REFINERY x x x x xxxxxxx xS 46 TRICOR REFINING, LLC PETROLEUM REFININGx xS 48 CRIMSON RESOURCE MANAGEMENT GAS PLANTx xx xS 55 CHEVRON USA INC NATURAL GAS PRODUCTION x x xxS 71 PLAINS LPG SERVICES, L.P. NATURAL GAS LIQUIDS x x x x x xS 73 OILDALE ENERGY LLC ELECTRIC POWER GENERATION x x xxS 75 COVANTA DELANO INC ELECTRIC SERVICES - POWER GENERATION x x xS 77 SHELL PIPELINE COMPANY LP CRUDE PETROLEUM PIPELINE xx xS 83 SHELL PIPELINE COMPANY LP CRUDE PETROLEUM PIPELINE x x x x xS 88 KERN RIVER COGENERATION CO COGENERATIONxxS 91 MT POSO COGENERATION COMPANY COGENERATIONxx x xS 132 PROVISIONS FOOD COMPANY INC MILK PROCESSING/DAIRY PRODUCTS MANUFACTURER xS 146 KAWNEER COMPANY INC METAL PARTS AND PRODUCTS COATINGxS 169 GLEN WELLS CONSTRUCTION CO ASPHALT PAVING MIXTURES AND BLOCKSxS 172 LIVE OAK LIMITED OIL & GAS PRODUCTIONxx xS 205 CONSOLIDATED FIBERGLASS ASPHALT FELTS AND COATINGS x xS 254 PLAINS PIPELINE LP CRUDE PETROLEUM PIPELINES x x x xS 285 CRES INC DBA DINUBA ENERGY ELECTRIC SERVICES - POWER GENERATION x xS 287 PETROLEUM PRODUCTION TESTING TRANSPORTABLE WELL TEST FLARE xS 334 PREGIS INNOVATIVE PACKAGING INC PLASTIC FOAM PRODUCTS MANUFACTURINGxx xS 348 WEST KERN WATER DISTRICT WATER DISTRICTxxS 349 WEST KERN WATER DISTRICT WATER DISTRICTxxS 350 WEST KERN WATER DISTRICT WATER DISTRICTxxS 353 WEST KERN WATER DISTRICT WATER DISTRICTxxS 360 LIBERTY COMPOSTING INC CO-COMPOSTINGxS 364 CALMAT CO., DBA VULCAN MATERIALS CO. ASPHALT PAVING MIXTURES xS 377 PARAMOUNT FARMS TREE NUT PROCESSING FACILITY x x x x xxS 381 HECK CELLARS WINERYxx xS 382 OCCIDENTAL OF ELK HILLS, INC (OEHI) OIL AND NATURAL GAS PRODUCTION x x x x x xxxxx xS 498 AMERICAN YEAST CORPORATION YEAST PRODUCTION x x x xS 511 SYCAMORE COGENERATION CO COGENERATIONxxS 512 SETTON PISTACHIO OF TERRA BELLA AGRICULTURAL PRODUCTS PROCESSING xxS 525 LAND O' LAKES, INC. MILK PROCESSING/DAIRY PRODUCTS MANUFACTURER x x x x xS 548 TULARE CITY WASTEWATER PLANT WASTEWATER TREATMENT x xxS 623 CAL MAT DBA VULCAN MATERIALS COMPANY ASPHALTIC PAVING MIXTURES xS 637 JOSTENS INC GRAPHICS ARTS PRINTING OPERATIONx xxS 713 PARAMOUNT KING LLC AGRICULTURAL PRODUCTS PROCESSING, PISTACHIOS xS 723 CHALK CLIFF LIMITED COGENERATIONxxS 724 DAI OILDALE INC OIL & GAS PRODUCTIONx x x x xxS 834 SIERRA POWER CORPORATION ELECTRICAL SERVICES x x xS 848 AGRI-CEL INC PLASTIC FOAM PRODUCTS xx xS 883 RIO BRAVO POSO ELECTRIC SERVICESx x x xx xS 892 PACTIV CORPORATION PLASTICS FOAM PRODUCTSx x xxS 984 VISALIA WASTEWATER TREATMENT WASTEWATER TREATMENT xxx xS 1075 STYROTEK INC PLASTICS FOAM PRODUCTS x x xx xS 1114 SENECA RESOURCES CORPORATION OIL AND NATURAL GAS PRODUCTION x x x x x x xS 1115 VICTORY OIL CO OIL & GAS PRODUCTION x x xxS 1118 HIGH SIERRA LIMITED OIL AND NATURAL GAS PRODUCTIONxx xS 1119 DOUBLE C LIMITED OIL AND NATURAL GAS PRODUCTIONxx xS 1120 KERN FRONT LIMITED OIL AND NATURAL GAS PRODUCTIONxx xxS 1121 NAFTEX OPERATING COMPANY OIL AND GAS PRODCTION x x xxS 1126 UPF CORPORATION FIBERGLASS INSULATION MANUFACTURINGxS 1127 CHEVRON USA INC OIL AND NATURAL GAS PRODUCTION x x x x x x xS 1128 CHEVRON USA INC OIL AND NATURAL GAS PRODUCTION x x x x x x x x xS 1129 CHEVRON U S A INC OIL AND NATURAL GAS PRODUCTION x x x x x x x x xS 1130 CHEVRON U S A INC OIL AND NATURAL GAS PRODUCTIONx xS 1131 CHEVRON USA INC OIL AND NATURAL GAS PRODUCTION x x x x x x x x x xS 1135 AERA ENERGY LLC CRUDE PETROLEUM AND NATURAL GAS PRODUCTION x x x x x x x x xS 1141 CHEVRON USA INC OIL AND NATURAL GAS PRODUCTION x x x x x x x xS 1188 NESTLE PURINA PETCARE COMPANY AGGREGATE/MINERAL PROCESSING xS 1199 PLAINS MARKETING LP CRUDE PETROLEUM PIPELINE x x x x xS 1203 SAPUTO CHEESE USA INC DRY, CONDENSED, EVAPORATED DAIRY PRODUCTS x xxS 1216 OCCIDENTAL OF ELK HILLS, INC. OIL AND GAS PRODCTION x x x x x xS 1234 TAFT PRODUCTION COMPANY AGGREGATE/MINERAL PROCESSING x x3-6Chapter 3: Major Sources and Applicable RACT RulesRACT Demonstration for Ozone SIPSan Joaquin Valley Unified Air Pollution Control DistrictApril 16, 2009

Region ID #Facility Name Facility Description 4103 4104 4106 4301 4306 4307 4308 4309 4311 4313 4352 4354 4401 4402 4404 4407 4408 4409 4453 4454 4455 4565 4570 4601 4602 4603 4604 4605 4606 4607 4610 4612 4621 4622 4623 4624 4625 4641 4642 4651 4652 4653 4661 4662 4663 4672 4681 4682 4684 4691 4692 4693 4694 4702 4703 4902 4905 New RuleTable 3-1: Major Sources and Applicable RACT RulesS 1242 SENECA RESOURCES OIL AND GAS PRODUCTION xx xS 1246 BERRY PETROLEUM COMPANY OIL AND NATURAL GAS PRODUCTION x x x x x x x x x x xS 1247 EMJAYCO OIL & NATURAL GAS PRODUCTION xxS 1250 BADGER CREEK LIMITED GAS TURBINE ENGINE COGENERATION SYSTEMxx xS 1251 MCKITTRICK LIMITED COGENERATIONxxS 1259 CLEAN HARBORS BUTTONWILLOW, LLC HAZARDOUS & NONHAZARDOUS WASTE DISPOSAL FACILITYxxx x xS 1326 VINTAGE PRODUCTION CALIFORNIA LLC OIL AND NATURAL GAS PRODUCTION x x x x x x x xS 1327 VINTAGE PRODUCTION CALIFORNIA LLC OIL AND NATURAL GAS PRODUCTION x x xxS 1328 EXXONMOBIL CORPORATION PETROLEUM AND NATURAL GAS PRODUCTION x x x x x x xS 1329 HUNTER EDISON OIL DEVELOPMENT OIL & GAS PRODUCTION x x x x xS 1346 CALIFORNIA DAIRIES, INC. DRY, CONDENSED, EVAPORATED DAIRY PRODUCTS x x x xx xS 1372 PLAINS EXPLORATION & PRODUCTION COMPANY OIL AND NATURAL GAS PRODUCTION x x x x x x x x x x xS 1379 PACIFIC FIBERGLASS INC PLASTICS PRODUCTSxS 1385 DELTA TRADING ICO CRIMSON RESOURCE MGMT PETROLEUM BLENDING FACILITY xxx xS 1388 DELTA TRADING ICO CRIMSON RESOURCE MGMT PETROLEUM REFININGxS 1399 CHEVRON USA INC PIPELINE PUMP STATIONxS 1405 EXXONMOBIL PIPELINE COMPANY PIPELINE PUMP STATIONxS 1406 EXXONMOBIL OIL CORPORATION PIPELINE PUMP STATIONxS 1413 SHELL PIPELINE COMPANY LP PIPELINE PUMP STATION x x x xS 1415 SHELL CALIFORNIA PIPELINE COMPANY LLC PIPELINE PUMP STATION xx xS 1416 SHELL CALIFORNIA PIPELINE COMPANY LLC PIPELINE PUMP STATION xx xS 1509 VAQUERO ENERGY, INC. OIL & GAS PRODUCTION x xxS 1510 VAQUERO ENERGY INC OIL & GAS PRODUCTIONx xS 1518 CONOCOPHILLIPS PIPE LINE COMPANY PETROLEUM PIPELINESxx xS 1520 CONOCOPHILLIPS PIPE LINE COMPANY PIPELINE FACILITY xx xS 1521 CONOCOPHILLIPS PIPE LINE COMPANY PETROLEUM PIPELINES xx xS 1525 CONOCOPHILLIPS PIPE LINE COMPANY PIPELINE FACILITYx xS 1543 AERA ENERGY LLC GAS PLANTx x x x xxS 1547 AERA ENERGY LLC CRUDE PETROLEUM AND NATURAL GAS x x x x x x x x x x x xS 1548 AERA ENERGY LLC LIGHT OIL PRODUCTION x x x x x xS 1550 MCFARLAND ENERGY INC OIL AND NATURAL GAS PRODUCTIONx xS 1610 GRANITE CONSTRUCTION COMPANY ASPHALT PAVING MIXTURES xx xS 1612 GRANITE CONSTRUCTION COMPANY ASPHALT PAVING MIXTURES xS 1624 E&B NATURAL RESOURCES MGMT CRUDE PETROLEUM AND NATURAL GAS x x x x x x x xS 1630 SENECA RESOURCES OIL & GAS PRODUCTIONx xS 1678 KERN MEDICAL CENTER HOSPITALS xxS 1703 MACPHERSON OIL COMPANY OIL AND NATURAL GAS PRODUCTION x x x x x x x xS 1737 VINTAGE PRODUCTION CALIFORNIA LLC CRUDE OIL AND NATURAL GAS PRODUCTION x x xS 1738 VINTAGE PRODUCTION CALIFORNIA LLC CRUDE OIL AND NATURAL GAS PRODUCTION x xxxxx xS 1751 RIO BRAVO JASMIN ELECTRIC SERVICESx xxS 1807 E&B NATURAL RESOURCES MGMT CORP CRUDE PETROLEUM AND NATURAL GAS x xxS 1810 CONTAINMENT SOLUTIONS INC. TANK MANUFACTURINGx xxS 1876 BLUESCOPE BUILDINGS NORTH AMERICA INC METAL FABRICATIONxS 2010 CHEVRON USA INC OIL AND NATURAL GAS PRODUCTION x x x x xS 2033 ELK CORPORATION OF TEXAS ASPHALT FELTS AND COATINGS xxS 2049 BEAR MOUNTAIN LIMITED OIL AND NATURAL GAS PRODUCTIONxx xxS 2076 FRITO-LAY NORTH AMERICA INC SNACK FOODS MANUFACTURING x x xx xS 2197 MAGEE INVESTMENT COMPANY OIL AND GAS FIELD SERVICExS 2199 CHEVRON USA PRODUCTION INC NATURAL GAS PRODUCTIONxxS 2234 OCCIDENTAL OF ELK HILLS, INC. (OEHI) NATURAL GAS PROCESSING x x x x x x x x x xS 2246 SAN JOAQUIN FACILITIES MGMT OIL & GAS PRODUCTIONx xS 2265 BERRY PETROLEUM COMPANY OIL & NATURAL GAS PRODUCTIONxxS 2273 BAKERSFIELD CITY WASTEWATER #2 SEWERAGE SYSTEMS xxS 2286 US OIL & GAS CRUDE OIL AND NATURAL GAS PRODUCTIONxS 2329 VINTAGE PRODUCTION CALIFORNIA, LLC OIL AND GAS PRODUCTION x x x x x xS 2392 JACO HILL GASOLINE DISPENSINGx xS 2584 SEQUOIA EXPLORATION OIL AND GAS PRODUCTIONxS 2585 SEQUOIA EXPLORATION OIL AND NATURAL GAS PRODUCTIONxS 2592 MID-SET COGEN C/O G.M.THOMSON OIL AND NATURAL GAS PRODUCTIONxxS 2622 TRC OPERATING COMPANY INC CRUDE OIL AND NATURAL GAS PRODUCTION x x x xS 2645 A & P GROWERS NUT HULLING, SHELLING, SORTING, AND GRADING xS 2717 CAPCO RESOURCE CORPORATION OIL AND GAS PRODUCTIONxS 2742 SUN MOUNTAIN OIL & GAS OIL AND GAS PRODUCTIONxS 2814 SUN-GRO COMMODITIES INC AGRICULTURAL IMPLEMENTS & MACHINERYxS 2865 J P OIL COMPANY INC OIL & GAS PRODUCTIONx xS 2890 MM TULARE ENERGY, LLC ELECTRIC POWER GENERATIONx xS 2896 PACIFIC PROCESS SYSTEMS OIL WELL TESTING xS 2918 CRIMSON RESOURCE MANAGEMENT OIL AND NATURAL GAS PRODUCTIONx xx xS 2980 SAN JOAQUIN FACILITIES MGMT LIGHT OIL PRODUCTION x x x xS 2996 NEO TULARE LLC/TULARE COUNTY LANDFILLxS 3012 APTCO LLC PLASTICS FOAM PRODUCTS xxS 3027 EAGLE SANDBLASTING & PAINTING ABRASIVE BLASTING OPERATIONxxx xS 3036 SUN MOUNTAIN OIL & GAS OIL AND GAS PRODUCTIONxS 3079 CRIMSON RESOURCE MANAGEMENT OIL AND NATURAL GAS PRODUCTIONx xS 3088 TRC CYPRESS GROUP LLC CRUDE OIL AND NATURAL GAS PRODUCTION x x xxS 3103 BAKERSFIELD CITY WASTEWATER #3 SEWERAGE SYSTEMSxS 3232 KERN COUNTY WASTE MANAGEMENT SANITARY LANDFILLx xS 3303 BIG WEST OF CA, LLC GASOLINE TERMINAL WITHOUT BULK STORAGE FACILITIESx x xxS 3317 CHEVRON U S A INC NATURAL GAS TRANSMISSION & DISTRIBUTIONxxS 3322 N. W. LOST HILLS PETROLEUM HOLDINGS, LLC OIL AND GAS PRODUCTIONx xS 3342 CAMBRIAN ENERGY WOODVILLE LLC SANITARY LANDFILLx xS 3412 LA PALOMA GENERATING CO LLC POWER PLANT x x xx xS 3431 KERN COUNTY WASTE MANAGEMENT SANITARY LANDFILLxx x3-7Chapter 3: Major Sources and Applicable RACT RulesRACT Demonstration for Ozone SIPSan Joaquin Valley Unified Air Pollution Control DistrictApril 16, 2009

Region ID #Facility Name Facility Description 4103 4104 4106 4301 4306 4307 4308 4309 4311 4313 4352 4354 4401 4402 4404 4407 4408 4409 4453 4454 4455 4565 4570 4601 4602 4603 4604 4605 4606 4607 4610 4612 4621 4622 4623 4624 4625 4641 4642 4651 4652 4653 4661 4662 4663 4672 4681 4682 4684 4691 4692 4693 4694 4702 4703 4902 4905 New RuleTable 3-1: Major Sources and Applicable RACT RulesS 3432 KERN COUNTY WASTE MANAGEMENT SANITARY LANDFILLxx xS 3433 KERN COUNTY WASTE MANAGEMENT SANITARY LANDFILLxx xS 3461 BUILDING MATERIALS MANUF. CORP FIBERGLASS MAT MANUFACTURING OPERATIONxS 3523 ELK HILLS POWER LLC ELECTRIC POWER GENERATIONxx xS 3553 SALT CREEK OIL LLC OIL PRODUCTION x xxS 3570 DUNKIN & BUSH INC METAL PARTS AND PRODUCTS COATINGxS 3577 JIM'S FORMAL WEAR INDUSTRIAL LAUNDERERSxS 3585 BERRY PETROLEUM COMPANY OIL AND GAS PRODCTION x x xxS 3611 TULARE COUNTY RMA SANITARY LANDFILLxx x xS 3636 PASTORIA ENERGY FACILITY, LLC POWER GENERATIONx xS 3663 CITY OF DELANO GOVERNMENT SERVICESxS 3694 TRI VALLEY OIL & GAS OIL AND GAS FIELD SERVICES xS 3720 KERN COUNTY WASTE MANAGEMENT DEPT SANITARY LANDFILLxx xS 3724 HEALTHSOUTH PHYSICIANS PLAZA SURGERY CTR HOSPITALSxS 3728 TULARE COUNTY RESOURCE MGMT AGENCY SANITARY LANDFILLxx xS 3729 TULARE COUNTY RESOURCE MGMT AGENCY SANITARY LANDFILLxx xS 3746 SUNRISE POWER COMPANY POWER PLANTxxS 3878 BIG WEST OF CALIFORNIA LLC OIL AND GAS PRODUCTIONxS 3914 TS LEASING OPERATIONS INC OIL & GAS PRODUCTIONxS 3995 PATRICK HOLMES INDUSTRIAL PAINTINGxS 4001 PRIMEX FARMS LLC AGRICULTURAL PRODUCTS PROCESSINGxS 4026 ELCO INC FABRICATED METAL PRODUCTSxS 4034 E&B NATURAL RESOURCES OIL & GAS PRODUCTIONxx xS 4073 NATIONS PETROLEUM USA LTD OIL & NATURAL GAS PRODUCTION x x x xS 4080 LONGBOW, LLC. OIL PRODUCTIONxS 4126 SUNRAY PETROLEUM INC CRUDE OIL PRODUCTIONxS 4212 SOUTH KERN INDUSTRIAL CENTER LLC CO-COMPOSTINGxS 4214 PIXLEY ETHANOL LLC ETHANOL PRODUCTION FACILITYxx xS 4294 WORLD OIL CORP. SOIL AND GROUNDWATER REMEDIATION xxS 4434 FERNANDES BROTHERS DBA LEGACY RANCH AGRICULTURAL CROP PRODUCTIONx xx xS 4548 FARMLAND MANAGEMENT SERVICES AGRICULTURAL CROP PRODUCTIONxx xS 4554 WESTERN SKY DAIRY AGRICULTURAL CROP PRODUCTIONxS 4670 EJ DE GROOT FARMS AGRICULTURAL CROP PRODUCTIONx xS 4692 BELLANAVE CORPORATION DAIRY FARMxx xS 4693 WEST KERN DAIRY DAIRY FARMxS 4702 VANDER EYK & SONS DAIRY AGRICULTURAL CROP PRODUCTION, DAIRYxS 4719 GRACELAND DAIRY INC AGRICULTURAL CROP PRODUCTIONxxS 4737 VINCENT B. ZANINOVICH & SONS, INC. AGRICULTURAL FIELD CROPSxS 4749 MILKY WAY DAIRY DAIRY FARMSx xx xS 4751 BIDART DAIRY LLC AGRICULTURAL CROP PRODUCTION, DAIRYxS 4751 BIDART DAIRY, LLC AGRICULTURAL CROP PRODUCTION, DAIRYxS 4800 MARTIN HEIN RANCH COMPANY AGRICULTURAL CROP PRODUCTIONxS 4802 AGTOPROF INC FOR PA 4,8,9 AGRICULTURAL CROP PRODUCTIONxS 4853 WEST COAST GRAPE FARMING INC-TEHACHAPI AGRICULTURAL CROP PRODUCTIONxS 4877 KOETSIER DAIRY DAIRY FARMxS 5058 HILARIDES DAIRY AGRICULTURAL CROP PRODUCTION, DAIRY xxx xS 5060 TJAARDA DAIRY DAIRY FARMx xx xS 5064 KOOTSTRA DAIRY AGRICULTURAL CROP PRODUCTIONxS 5068 POSO CREEK DAIRY DAIRY FARMxx xS 5069 CARLOS ECHEVERRIA & SONS DAIRY DAIRY FARMx xxS 5134 COUNTRY SIDE DAIRY DAIRYxS 5209 MELVIN SIMOES DAIRY DAIRY FARMSxx xS 5213 COSTA DAIRY FARMS DAIRYxxS 5252 PAUL FARMS AGRICULTURAL CROP PRODUCTIONxS 5265 MAPLE DAIRY DAIRY OPERATIONxx xS 5294 WEST KERN WATER DISTRICT WATER DISTRICTxS 5324 ANGIOLA DAIRY DAIRY FARMxx xS 5325 ATSMA DAIRIES DAIRY FARMxx xS 5346 WESTHILL DAIRY DAIRY FARMxS 5348 RICHARD D WESTRA DAIRY FARMSxx xS 5439 GREEN ACRES FARM AGRICULTURAL CROP PRODUCTIONxx xS 5446 PAUL FARMS AGRICULTURAL CROP PRODUCTIONxS 5688 MONROVIA GROWERS, VISALIA AGRICULTURAL CROP PRODUCTION xxS 5712 D & J FARM MGMT / FABBRI FARMING CO AGRICULTURAL CROP PRODUCTIONxS 6331 WM. BOLTHOUSE FARMS INC AGRICULTURAL CROP PRODUCTIONxxS 6375 BOSMAN-PIXLEY DAIRY (FARMLAND) AGRICULTURAL CROP PRODUCTIONxS 6509 HATHAWAY LLC CRUDE OIL STORAGE OPERATIONxS 6592 BOSMAN DAIRY AGRICULTURAL CROP PRODUCTION, DAIRYx xS 6622 SOUTH LAKES DAIRY DAIRYxS 6644 ALVIN SOUZA DAIRY DAIRY FARMSx xS 6673 MEADOWLAKE EAST DAIRY DAIRY FARMSxS 6706 C & R VANDERHAM DAIRY DAIRY FARMxS 6718 ARTESIA DAIRY DAIRY FARMxx xS 6723 JOE MACEDO & SONS DAIRY DAIRY FARMx xx xS 6911 ALVIN SOUZA - DEER CREEK AGRICULTURAL CROP PRODUCTIONxS 6918 BROTHERS FARMS, LLC AGRICULTURAL CROP PRODUCTIONxS 6978 MEADOWLAKE WEST DAIRY DAIRY FARMxx xS 6983 CORE ENERGY, LLC OIL PRODUCTION x xxS 6991 G J TEVELDE RANCH AGRICULTURAL CROP PRODUCTIONxx xS 7045 ANATESCO WEST OIL WELL TESTINGxS 7063 CALIFORNIA DAIRIES, INC MILK PROCESSING/DAIRY PRODUCTS MANUFACTURER x xS 7112 WASCO REAL PROPERTIES I, LLC AGRICULTURAL CROP PRODUCTIONxS 7117 BORBA DAIRY DAIRY FARMxx x3-8Chapter 3: Major Sources and Applicable RACT RulesRACT Demonstration for Ozone SIPSan Joaquin Valley Unified Air Pollution Control DistrictApril 16, 2009

Region ID #Facility Name Facility Description 4103 4104 4106 4301 4306 4307 4308 4309 4311 4313 4352 4354 4401 4402 4404 4407 4408 4409 4453 4454 4455 4565 4570 4601 4602 4603 4604 4605 4606 4607 4610 4612 4621 4622 4623 4624 4625 4641 4642 4651 4652 4653 4661 4662 4663 4672 4681 4682 4684 4691 4692 4693 4694 4702 4703 4902 4905 New RuleTable 3-1: Major Sources and Applicable RACT RulesS 7164 FELICITA DAIRY DAIRY FARMxxS 7214 BONANZA CREEK ENERGY OPERATION COMPANY OIL & GAS PRODUCTIONxS 7241 K & M VISSER AGRICULTURAL CROP PRODUCTION, DAIRYxx xS 7469 ETCHEGARAY FARMS AGRICULTURAL CROP PRODUCTIONx3-9Chapter 3: Major Sources and Applicable RACT RulesRACT Demonstration for Ozone SIPSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 3: Major Sources and Applicable RACT Rules

RACT Demonstration for Ozone SIP 3-10 This page intentionally blank.RACT Demonstration for Ozone SIP 

## Chapter 4

Rule AnalysisRACT Demonstration for Ozone SIP This page intentionally blank.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-1 

## Chapter 4: Rule Analysis

4.1 RULES ANALYZED FOR RACT

The bulk of the District’s RACT Demonstrat ion effort was to review the District’s numerous NOx and VOC regulations for compli ance with federal RACT requirements. Except for the rules shown in Table 4-2, District staff reviewed the applicability, stringency, and enforceability of every District NOx or VOC prohibitory rule. Table 4-1 shows the rules that District staff analyzed for RACT.

As discussed in Chapter 1, criteria for deter mining that RACT is satisfied included the RACT guidance from EPA, r equirements per California law, and a comparison against multiple federal rules, regulations, and tec hnology guidelines as well as evaluating District rules against comparable rules from California’s most technologically progressive air districts. Dis trict staff, upon applicat ion of the criteria, was then able to

determine RACT status for each rule.

It should be noted that if a District rule had been recently SIP-approved, it was

understood that the rule had been evaluated by the EPA and found to fulfill RACT, and no detailed analysis was conducted. However, since RACT is a moving target, if there were no recent SIP-approvals for a rule, Distr ict staff performed a detailed analysis to evaluate rule requirements against current technology.San Joaquin Valley Unified Air Pollution Control District April 16, 2009Chapter 4: Rule AnalysisRACT Demonstration for Ozone SIP4-2Table 4-1 District Rules Analyzed and Rule HistoryRule # Rule TitlePollutantsControlledCTGSource?DateAdoptedDate LastAmendedFederalRegisterPublicationDateFederalRegisterCitationPageNumber4103 Open BurningminimizesmokeimpactN 6/18/1992 5/17/2007 4/11/2006 71 FR 18216 4-84104 Reduction of Animal MatteraircontaminantsN 5/21/1992 - 1/2/2008 73 FR 48 4-214106Prescribed Burning and HazardReduction BurningVOC, NOx,SOx, PMN 6/21/2001 - 2/27/2002 67 FR 8894 4-244301 Fuel Burning EquipmentNOx, SOx,combustioncontaminantN 5/21/1992 12/17/1992 5/18/1999 64 FR 26876 4-394306Boilers, Steam Generators, andProcess Heaters – Phase 3NOx, CO Y 9/18/2003 10/16/2008 5/18/2004 69 FR 28061 4-424307Boilers, Steam Generators, andProcess Heaters - 2.0 MMBtu/hr to5.0 MMBtu/hrNOx, CO Y 12/15/2005 10/16/2008 5/30/2007 72 FR 29887 4-454308Boilers, Steam Generators, andProcess Heaters - 0.075 MMBtu/hrto 2.0 MMBtu/hrNOx, CO Y 10/20/2005 - 5/30/2007 72 FR 29886 4-474309 Dryers, Dehydrators and Ovens NOx, CON 12/15/2005 - 5/30/2007 72 FR 29886 4-544311 Flares NOx, VOC N 6/20/2002 6/15/2006 2/26/2003 68 FR 8835 4-564313 Lime Kilns NOx N 3/27/2003 - 9/4/2003 68 FR 52510 4-594354 Glass Melting FurnacesNOx, CO,VOCN 9/14/1994 10/16/2006 8/1/2007 72 FR 41894 4-694401Steam-Enhanced Crude OilProduction Well VentsVOC N 4/11/1991 12/14/2006 6/22/1998 63 FR 33854 4-734402 Crude Oil Production Sumps VOC N 4/11/1991 12/17/1992 1/2/2008 73 FR 48 4-76San Joaquin Valley Unified Air Pollution Control District April 16, 2009Chapter 4: Rule AnalysisRACT Demonstration for Ozone SIP4-3Table 4-1 District Rules Analyzed and Rule HistoryRule # Rule TitlePollutantsControlledCTGSource?DateAdoptedDate LastAmendedFederalRegisterPublicationDateFederalRegisterCitationPageNumber4404Heavy Oil Test Station – KernCountyVOC N 5/21/1992 12/17/1992not in SIPSubmitted toEPA 5/20074-804407 In-situ Combustion Well Vents VOCN 5/19/1994 - 3/6/1995 60 FR 12121 4-824408 Glycol Dehydration Systems VOC N12/19/2002 - 8/26/2003 68 FR 51187 4-844409Components at Light Crude OilProduction Facilities, Natural GasProduction Facilities, and NaturalGas Processing FacilitiesVOC Y 4/20/2005 - 3/23/2006 71 FRv14653 4-864453Refinery Vacuum ProducingDevices or SystemsVOC Y 5/21/1992 12/17/1992 1/2/2008 73 FR 48 4-884454 Refinery Process Unit Turnaround VOC Y 5/21/1992 12/17/1992 1/2/2008 73 FR 48 4-914455Components at Refineries, GasProcessing Facilities, andChemical PlantsVOC Y 4/20/2005 - 3/23/2006 71 FR 14652 4-944565Biosolids, Animal Manure, andPoultry Litter OperationsVOC N 3/15/2007 -New Rule –submitted toEPA4-964570 Confined Animal Facilities VOC N 6/15/2006 - 4-994601 Architectural Coatings VOC N 4/11/1991 10/31/2001 1/2/2004 69 FR 34 4-1704603Surface Coating of Metal Partsand ProductsVOC Y 4/11/1991 10/16/2008 6/25/2002 67 FR 42726 4-1724604 Can and Coil Coating Operations VOC Y 4/11/1991 9/20/2007 5/19/2005 70 FR 28826 4-1894605Aerospace Assembly andComponent Coating OperationsVOC Y 12/19/1991 9/20/2007 11/14/2003 68 FR 64537 4-1964606Wood Products CoatingOperationsVOC Y 12/19/1991 10/16/2008 6/26/2002 67 FR 42999 4-2064607 Graphic Arts VOC Y 4/11/1991 12/18/2008 6/26/2002 67 FR 42999 4-215San Joaquin Valley Unified Air Pollution Control District April 16, 2009Chapter 4: Rule AnalysisRACT Demonstration for Ozone SIP4-4Table 4-1 District Rules Analyzed and Rule HistoryRule # Rule TitlePollutantsControlledCTGSource?DateAdoptedDate LastAmendedFederalRegisterPublicationDateFederalRegisterCitationPageNumber4610 Glass Coating Operations VOC N 5/16/2002 4/17/2003 10/14/2004 69 FR 60962 4-2344612Motor Vehicle and MobileEquipment Coating OperationsPhase IIVOC Y 9/21/2006 9/20/2007New Rule –submitted toEPA4-2384621Gasoline Transfer into StationaryStorage Containers, DeliveryVessels, and Bulk PlantsVOC Y 4/11/1991 12/20/2007 4/19/2000 65 FR 20912 4-2454622Gasoline Transfer into MotorVehicle Fuel TanksgasolinevaporsY 5/21/1992 12/20/2007 3/24/2003 68 FR 14156 4-2524623 Storage of Organic Liquids VOC Y 4/11/1991 5/19/2005 9/13/2005 70 FR 53937 4-2534624 Organic Liquid Loading VOC N 4/11/1991 12/20/2007 4-2554625 Wastewater Separators VOC Y 4/11/1991 12/17/1992 1/2/2008 73 FR 48 4-2704641Cutback, Slow Cure, andEmulsified Asphalt Paving andMaintenance OperationsVOC Y 4/11/1991 12/17/1992 1/2/2008 73 FR 48 4-2754642 Solid Waste Disposal Sites VOC N 7/20/1995 4/16/1998 7/26/2001 66 FR 38939 4-2814651 Soil Decontamination Operations VOC N 4/16/1992 9/20/2007 7/25/1996 61 FR 38571 4-2964652 Coatings and Ink Manufacturing VOC 5/21/1992 12/17/1992 4-3044653 Adhesives VOC N 3/17/1994 9/20/2007 5/7/2002 67 FR 30591 4-3084661 Organic Solvents VOC Y 5/21/1992 9/20/2007 9/16/2003 68 FR 54167 4-3144662Organic Solvent DegreasingOperationsVOC Y 4/11/1991 9/20/2007 7/22/2002 67 FR 47701 4-3174663Organic Solvent Cleaning,Storage, and DisposalVOC Y 12/20/2001 9/20/2007 7/22/2002 67 FR 47701 4-3204672Petroleum Solvent Dry CleaningOperationsVOC Y 4/11/1991 12/17/1992 1/2/2008 73 FR 48 4-3234681 Rubber Tire Manufacturing VOC Y 5/16/1991 12/16/1993 8/17/1998 63 FR 43881 4-330San Joaquin Valley Unified Air Pollution Control District April 16, 2009Chapter 4: Rule AnalysisRACT Demonstration for Ozone SIP4-5Table 4-1 District Rules Analyzed and Rule HistoryRule # Rule TitlePollutantsControlledCTGSource?DateAdoptedDate LastAmendedFederalRegisterPublicationDateFederalRegisterCitationPageNumber4682Polystyrene, Polyethylene, andPolypropylene ProductsManufacturingVOC, CFC11, CFC-12Y 5/21/1992 9/20/2007 6/13/1995 60 FR 31086 4-3384684 Polyester Resin Operations VOC Y 5/19/1994 9/20/2007 6/26/2002 67 FR 42999 4-3454691Vegetable Oil ProcessingOperationsVOC 4/11/1991 12/17/1992 4-3534692 Commercial Charbroiling VOC, PM3/21/2002 - 6/3/2003 68 FR 33005 4-3554693 Bakery Ovens VOC N 5/16/2002 - 4/26/2004 69 FR 22441 4-3584694Wine Fermentation and StorageTanksVOC N 12/15/2005 -New Rule –submitted toEPA4-3614702Internal Combustion Engines –Phase 2NOx, CO,VOCN 8/21/2003 1/18/2007 1/10/2008 73 FR 1819 4-3634703 Stationary Gas Turbines NOx N 8/18/1994 9/20/2007 5/18/2004 69 FR 28061 4-3664902 Residential Water Heaters NOx N 6/17/1993 - 2/17/2004 69 FR 7370 4-3724905Natural Gas Fired, Fan-type,Residential Central FurnacesNOx N 10/20/2005 - 5/30/2007 72 FR 29886 4-375San Joaquin Valley Unified Air Pollution Control District April 16, 2009Chapter 4: Rule AnalysisRACT Demonstration for Ozone SIP4-6Table 4-2 District NOx and VOC Rules Not AnalyzedRule # Rule TitlePollutantsControlledCTGSource?DateAdoptedDate LastAmendedNotes4304Equipment TuningProcedure for Boilers,Steam Generators, andProcess HeatersNOx, CO N 10/19/1995 -There are no NOx and VOC emission limitsassociated with this rule.4305Boilers, SteamGenerators, and ProcessHeaters – Phase 2NOx, CO Y 12/16/1993 8/21/2003This rule was superceded by Rules 4306, 4307, and43084351Boilers, SteamGenerators, and ProcessHeaters – ReasonablyAvailable ControlTechnologyNOx N 10/20/1994 8/21/2003This rule was superceded by Rules 4306, 4307, and43084403Components ServingLight Crude Oil or Gasesat Light Crude Oil andGas Production Facilitiesand Components atNatural Gas ProcessingFacilitiesVOC N 4/11/1991 4/20/2005 This rule was superceded by Rule 44094405Oxides of NitrogenEmissions from ExistingSteam Generators Usedin Thermally EnhancedOil Recovery – Centraland Western Kern CountyFieldsNOx N 5/21/1992 12/17/1992 This rule was superceded by Rule 43064451Valves, Pressure ReliefValves, Flanges,Threaded Connectionsand Process Drains atPetroleum Refineries andChemical PlantsVOC N 4/11/1991 4/20/2005 This rule was superceded by Rule 4455San Joaquin Valley Unified Air Pollution Control District April 16, 2009Chapter 4: Rule AnalysisRACT Demonstration for Ozone SIP4-7Table 4-2 District NOx and VOC Rules Not AnalyzedRule # Rule TitlePollutantsControlledCTGSource?DateAdoptedDate LastAmendedNotes4452Pump and CompressorSeals at PetroleumRefineries and ChemicalPlantsVOC N 4/11/1991 4/20/2005 This rule was superceded by Rule 44554602Motor Vehicle and MobileEquipment CoatingOperationsVOC Y 4/11/1991 7/21/2006 This rule was superceded by Rule 46124701Internal CombustionEngines – Phase 1NOx, CO,VOCN 5/21/1992 8/21/2003 This rule was superceded by Rule 47029310 School Bus Fleets NOx, PM N 9/21/2006 -This rule does not regulate any major stationarysourcesSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-8 

### Rule 4103 – Open Burning

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 4.8 4.8 4.7 4. 7 4.7 4.6 4.6 4.5

VOC 5.7 5.7 5.6 5. 6 5.6 5.5 5.5 5.4
(Source: District 2007 Ozone Plan)

District Rule 4103 Description

District Rule 4103 applies to open burning co nducted within the San Joaquin Valley Air Basin, with the exception of prescribed burning and hazard reduction burning which are subject to Rule 4106 (Prescribed Burning an d Hazard Reduction Burning). District Rule 4103 includes the following r equirements and prohibitions

General Requirements

• Prohibits open outdoor fire for disposal of or burning of petroleum wastes; demolition or construction debris; resi dential rubbish; gar bage or vegetation; tires; tar; trees; woodwaste; or other co mbustible or flammable solid, liquid or gaseous waste; or for metal salv age or burning of motor vehicles.

• The APCO will allocate burning based on t he predicted meteorolog ical conditions and whether it would cause nuisance, impac t smoke sensitive areas, or create or

contribute to an exceedance of the ambient air quality standard.

• The APCO will restrict the time of day when burns are ignited and conducted.

• No open burning will be permitted that will create nuisance as defined in the state Health and Safety Code.

Agricultural Burning

• Prohibits issuance of burn permits for spec ific field crops, specific prunings from certain crops, and certain types of w eed abatement, except for prunings from apple crops, pear crops, fig crops and quinc e crops as well as weed abatement activities affecting waterways (incl uding ponding and levee banks) whereby burn permits may be issued until June 1, 2010.

• Requires the use of at least one best m anagement practice specified in the rule (other practice approved by the APCO) for the control of certain type of weeds located along ditch banks or canal banks, and the disposal of pesticide sacks or

fertilizer sacks.

• Allows issuance of permits for burning of rice stubble until June 1, 2015, but the

amount of rice stubble that coul d be burned will be limited and will be incrementally reduced annually based on the percent of the total annual acreage of rice planted.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-9 • Agricultural burn permits may be iss ued until June 1, 2010 for orchard removals of citrus, apple, pear, quince, and fig cr ops; or orchard removals of up to 20 acres per location per calendar year from other crops.

• Prohibits burning of agricultural waste unl ess it is arranged or loosely stacked so as to promote drying and insure combustion with minimum smoke.

• Ignite agricultural waste with an approv ed ignition device, and not burned unless it is free of excessive dirt, so il, and visible surface moisture.

• Prohibits burning of agricultural waste unless it is free of certain materials (plastic, rubber, ornament or landscape ve getation, shop waste, construction and demolition, etc.)

• Prohibits burning of orchard or vineyar d removal waste, or other material, generated as a result of land use conversi on from agricultural to nonagricultural

purposes.

• Prohibits burning unless the material has been allowed to dry for a minimum specified time period.

• Monitor and attend burning to prevent smoldering; burn only during daylight hours; not add waste to existing fire a fter 5:00 PM; and ignite rapidly as practicable within applic able fire restrictions.

Field crop burning:

• Prohibits burning before 10:00 AM or a fter 2:00 PM of any day, unless local conditions indicate other hours are appropriate.

• Ignite only by strip burning into-the-wi nd or backfiring, except under a special permit and other special c onditions/requirements.

• Rice harvesting must employ mechanical straw spreader but certain exceptions are allowed, but rice straw must be dried and meet crackle test criteria detailed in

the rule.

Ditch Bank and Levee Maintenance

• Remove trash and debris prior to burning

• Prepare the material by stacking, dr ying, or other methods to promote

combustion.

Contraband Materials

• Prohibits transporting contraband confisca ted outside the District for disposal by burning within the District. Only contr aband confiscated within the San Joaquin Valley air basin may be disposed off by burning.

• Submit written notification to the Distr ict of the planned burn prior to burning.

• Fires should only be set or allowed by a peac e officer or public fire official in the performance of official duty.

• To the extent possible, materials must be burned in areas and in conditions limiting the possibility of smoke impacts on nearby neighbors or other sensitive

areas.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-10 Russian Thistle

• Maintain burn site in a fire safe condition accordi ng to local fire protection

agency.

• Smoke and air contaminants must not impact smoke sensitive areas or cause/contribute to a nuisance, or creat e/contribute to exce edance of air quality

standards.

Diseased Materials

• Requires a conditional burn permit for fi res set for the purpose diseased or pest prevention.

• Requires certain specific conditions/det erminations by the county agricultural commissioner confirming the presence of the disease and the effects of not allowing the burn in lieu of ot her disposal alternatives.

Administrative Requirements

• Specific procedures and conditions fo r burn permits, burn plans for fire suppression training, and contraband are detailed in the rule.

How does District Rule 4103 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

District staff’s review of the EPA CTG list i ndicates that there is no CTG for open burning.

B. EPA – Alternative Control Techniques (ACT) Document

District staff’s review of the EPA ACT lis t indicates that there is no ACT for open burning.

C. Standards of Performance fo r New Stationary Sources (NSPS)

District staff’s review of 40 CFR 60 (St andards of Performanc e for New Sources) indicates that there is no NSPS for open burning.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

District staff’s review of 40 CFR 61 (NESHAP) and 40 CFR (NESHAP for Source Categories) indicates that there is no NESHAP or MACT for open burning.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-11 How does District Rule 4103 compare to rules in other air districts?

District staff compared District Rule 4103 with the rules of ot her California ozone nonattainment air districts’ rules on open bur ning. The results of the analysis are

discussed below.

• South Coast Air Quality Management District, Rule 444 (Open Burning) amended December 21, 2001

• Bay Area Air Quality Management Distric t, Regulation 5 (Open Burning) amended November 2, 1994

• Sacramento Metropolitan Air Quality M anagement Air District, Rule 407 (Open Burning) amended June 4, 1998

• Ventura County Air Pollut ion Control District) Ru le 56 (Open Burning) amended November 11, 2003

A. South Coast AQMD Rule 444 (Open Burning)

SCAQMD Rule 444 applies to open burning of agr icultural waste, disposal of Russian thistle, prescribed burning, fire preventi on/suppression training, open detonation or use of pyrotechnics, fire hazard, disposal of in fectious wastes (other than hospital waste), research and testing materials equipment or techniques, disposal of contraband, and residential burning.

SCAQMD Rule 444 prohibi ts open burning unless:

• The executive officer has declared the day as a permissive burn day and such burning is not prohibited by a public fire protection agency.

• A written permit and an authorization are obtained from the executive for each day for each open burning.

SCAQMD Rule 444 allows open burning for:

• Agricultural burning;

• Prescribed burning;

• Disposal of Russian thistle;

• Fire hazard abatement that a fire protection agency dete rmines cannot be abated by any viable option;

• Disposal of waste infected with agricultu ral pest or disease and ordered by the county agricultural commissioner;

• Disposal of infectious waste (other than hos pital waste) ordered by the county health officer;

• Use of pyrotechnics for creation of s pecial effects in motion pictures, etc.;

• Disposal of contraband in the possession of law enforcement personnel provided burning is the only available reaso nable method for safe disposal; and

• Fire prevention training; and researching and testing fire reta rdant properties of materials, etc.

SCAQMD Rule 444 prohibits open burning for

• Residential burning;San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-12 • Disposal of waste except as mentioned above;

• Materials generated as a result of land us e conversion for non-agricultural purposes;

• Disposal of materials from the production or storage of militar y ordnance, etc.; and

• Wildland suppression fires except those se t by fire protection agencies to save life and property.

SCAQMD Rule 444 requires open burni ng to comply with the following:

• Agricultural field crop burning must comme nce before 10:00 AM or later than 5:00 PM;

• Open burning other than field crop burning must not commence earlier than one hour after sunrise with no new ignition, or fuels to be added to an existing fire, later than two hours before sunset except as authorized at a time consistent with an approved smoke management plan;

• Use only approved ignition device

• Prior to burning, agricultural waste must be allowed to dry for a specified time as detailed in the rule;

• Agricultural waste must be free of dirt, soil and visible moisture; and

• Ignite rice, barley, oat, and wheat straw only by strip-firing or backfiring into the wind unless fire protection agency declares such ac tions would constitute a fire hazard.

SCAQMD Rule 444 specifies that the execut ive officer may allow the certain specified maximum daily burn acreage for agricultural burning and prescribed burning as follows:

• Except for Coachella Valley, 150 acres for prescribed wildl and and range burning, and150 acres for agricultural burning.

• Fro Coachella Valley, 5 acres for pr escribed wildland and range burning and 35 acres for agricultural burning.

• The above restrictions do not apply to prescribed burning when a land manger demonstrates that it is requi red to reduce fire hazard t hat jeopardized public health and safety and a satisfactory smoke m anagement plan is submitted and approved by the air district.

SCAQMD Rule 444 ex empts the following;

• Wildfire suppression ignited to save lif e and valuable property conducted by fire protection agency.

• Fire prevention/suppression training, except for the bur ning of existing structure, conducted by fire protection agency fo r no more than 30 minutes. Training involving burning of existing structure is exempt provided each training is no

more than 30 minutes.

• Burning of Russian thistle is exempt from having to get authorization from the

district.

• Recreational fires or ceremonial fires.

• Open burning of natural gas, propane, unt reated wood, or charcoal for the purpose of preparation or warming of f ood for human consumption or generating warmth for social gathering.

• Open burning located on islands 15 mile s or more from the mainland coast.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-13 • Fireworks displays or pyrotechnics used for the creation of special effects at theme parks.

• Detonation of explosives during quarry mining operations, bomb disposal by law enforcement agency, or demolition of buildi ngs or structures.

• Pyrotechnics, detonation of explosives, or fire effects for creation of special effects during theatrical productions, film ing of motion pictures, videotaping of television programs or other commercial filming or video production activities

must not be more than 30 minutes in duration.

SCAQMD Rule 444 applies to a variety of open burning activities which includes prescribed burning and hazard reduction burning which are not regula ted by District Rule 4103, but are regulated by District 4106 (Prescribe Burning and Hazard Reduction Burning).

Overall, District Rule 4103 is more stringent than SCAQMD Rule 444 for the following major reasons:

• District Rule 4103 prohibits open burning of almost all agricultural wastes, except prunings from apples crops, pears crops, fi g crops, and quince crops, as well as weed abatement activities affecting wate rways for which open burning is allowed until June 1, 2010. District Rule 4103 allo ws open burning of orc hard removal from citrus, apple, pear, quince, fig crops and orchard removal of up to 20 acres per location per calendar year until June 1, 2010, the burning of rice straw until June 1, 2015. Rule amendment projec t for 2009 would implement Phase IV of the state Health and Safety Code will address prohibi tion of burning of surface harvested crops prunings (almond, walnut, pecan and gr ape vines), vineyard removal, vineyard materials (grape canes and raisin trays) , and other materials (brooder paper, diseased goats, and diseased beehives). SCAQMD Rule 444 allows open burning of agricultural waste.

• District Rule 4103 requires the use of at least one best management practice specified in the rule (other practice approv ed by the APCO) for th e control of certain type of weeds located along ditch banks or canal banks, and the disposal of pesticide sacks or fertilizer sacks. SCAQMD Rule 444 has no similar restrictions for burning weeds.

• Prohibits transporting contraband confisca ted outside the District for disposal by burning within the District. Only contr aband confiscated within the San Joaquin Valley air basin may be disposed off by bur ning. SCAQMD Rule 444 allows burning of contraband in the possession of law enf orcement personnel regardless of where the contraband originated.

• District Rule 4103 does not allow open burni ng that will create a nuisance as defined

in Section 41700 of the state Health and Sa fety Code, but SCAQMD Rule 444 does not specify such restriction.

Based on the above discussion, District staff deems that District Rule 4103 is more stringent than SCAQMD Rule 444.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-14 B. Bay Area AQMD Regulat ion 5 (Open Burning)

BAAQMD Regulation 5 applies to open burni ng of agricultural waste, range management, forest management, and wildland m anagement. The rule prohibits a person from igniting, causing to ignite, permit to be ignited, or suffer , allow, or maintain fires within the district. No burning should take place in the district on other than a permissive burn day.

BAAQMD Regulation 5 allows the follo wing fires on permissive burn days:

• Disease and pests prevention;

• Crop replacement;

• Orchard pruning and attrition;

• Double cropping stubble;

• Hazardous materials (prevention or reducti on of fire hazard, disposal of dangerous materials);

• Fire training;

• Flood debris;

• Control growth of vegetation fr om irrigation ditches and canals;

• Disposal of material which is lying or gr owing within natural channels or flood control channels;

• Fires set for the purpose of range management and grazing;

• Fires set for the purpose of removing forest debris and for forest management;

• Fires set for the purpose of improvement of lowland and marsh for wildlife and game habitat;

• Fires set for the purpose of disposing contraband;

• Prescribed burning by stat e or federal agency, or th rough cooperative agreement or contract involving st ate or federal agency.

• Fires set as part of commercial film or video production activities for motion picture

and television.

• Fires set as part of a planned civic event designed to educate or otherwise benefit the public.

BAAQMD Regulation 5 requires that any person conducting open burning that is allowed by the rules must also comply with the following:

• No burning should take place before sunrise.

• No additional materials or fuel should be ignited nor should any material or fuel be added to any fire after two hours before sunset.

• No material or fuel should be ignited nor should any material or fuel be added to any fire when the wind velocity is less than 5 m iles per hour except for certain conditions specified in the rule.

• The material should be dried for a mini mum of 60 days prior to ignition.

• All material to be burned should be reasonably free from dirt or soil.

• Piled material should be limited to 25 s quare yards base area and the height should

be at least 2/3 of the av erage width of the pile.

• Ignition material should be lim ited to those listed by the state director of forestry.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-15 • Ignition should be started at or ne ar the top of the piled material.

• Tonnage, volume or acreage of material bur ned on any given day at any given site is subject to limitations set by the APCO, but may not exceed any li mits set by ARB.

BAAQMD Regulation 5 requires the submissi on of burn plan and the APCO’s approval prior to burning. The rule specify the r equirements that must be met when burning of propellants, explosives, pyrotechnics, dise ase and pests, fire training, flood control, irrigation ditches, range management, hazar dous materials, and contraband as wells prescribed burning, filmmaking petition. The rule also includes recordkeeping and monitoring requirements.

BAAQMD Regulation 5 exempts fires set for cooking food for human consumption; fires set for recreational purposes using only clea n dried wood or charc oal, and small amount of fire starter; fires burning as safety flar es or for combustion of waste gases; use of flame cultivation using only LPG or natural gas fired burners designed and used to kill seedling grass and weeds in orchards, vineyar ds and field crops and the growth is such

that the combustion will conti nue without the burner; and fires set for training purposes using one gallon or less of fl ammable liquid per fire..

BAAQMD Regulation 5 applies to a variety of open burning activities which includes prescribed burning and hazard reduction burning which are not regula ted by District Rule 4103, but are regulated by District 4106 (Prescribe Burning and Hazard Reduction Burning).

Overall, District Rule 4103 is more stringent than BAAQMD Regulation 5 for the following major reasons:

• District Rule 4103 prohibits open burning of almost all agricultural wastes, except prunings from apples crops, pears crops, fi g crops, and quince crops, as well as weed abatement activities affecting wate rways for which open burning is allowed until June 1, 2010. District Rule 4103 allo ws open burning of orc hard removal from citrus, apple, pear, quince, fig crops and orchard removal of up to 20 acres per location per calendar year until June 1, 2010, the burning of rice straw until June 1, 2015. Rule amendment projec t for 2009 would implement Phase IV of the state Health and Safety Code will address prohibi tion of burning of surface harvested crops prunings (almond, walnut, pecan and gr ape vines), vineyard removal, vineyard materials (grape canes and raisin trays) , and other materials (brooder paper, diseased goats, and diseased beehives). BAAQMD Regulation 5 allows open burning of agricultural waste.

• BAAQMD Regulation 5 exempts use of flam e cultivation using only LPG or natural gas fired burners designed and used to kill s eedling grass and weeds in orchards, vineyards and field crops and the growth is such that the combustion will continue without the burner, but District Ru le has no similar exemption.

• District Rule 4103 requires the use of at least one best management practice specified in the rule (other practice approv ed by the APCO) for th e control of certain type of weeds located along ditch banks or canal banks, and the disposal ofSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-16 pesticide sacks or fertilizer sacks. BAAQMD Regulation 5 has no similar restrictions for burning weeds.

• District Rule 4103 prohibits transporting co ntraband confiscated outside the District for disposal by burning within the Distr ict. Only contraband confiscated within the San Joaquin Valley air basin may be dispos ed off by burning. BAAQMD Regulation 5 allows burning of cont raband in the possession of law enforcement personnel regardless of where the contraband originated.

• BAAQMD Regulation 5 regulates r ange management, forest management, and wildland management which ar e not regulated by District Rule 4103 but are regulated by District 4106 (Prescribe Burning and Ha zard Reduction Burning)

.

Based on the above discussion, District staff deems that District Rule 4103 is more stringent than BAAQMD Regulation 5.

C. Sac Metro AQMD Rule 407 (Open Burning)

SMAQMD) Rule 407 applies to non-agricultural open outdoor fires. Ag ricultural burning is regulated under SMAQMD Rule 501 (Agricultural Burning).

SMAQMD) Rule 407 prohi bits the following:

• Burning of petroleum waste, demolition waste, tires, trees, wood waste, or other combustible or flammable solid or liquid waste, motor vehicle bodies, materials for the purpose of metal salvage, putrescible materials, bedding, asphaltic products, or rubber products.

• Burning or allowing to be burned, or ma intaining any open outdoor fire for the purpose of burning refuse or organic waste on an agricultural no-burn day.

• Burning or allowing to be burned, or ma intaining any open outdoor fire for the purpose of burning refuse or organic waste at any time at certain locations specific in

the rule.

Overall, District Rule 4103 is more stri ngent than SMAQMD Rule 407 for the following major reasons:

• Unlike District Rule 4103, SMAQMD Rule 407 does not require submission of burn plans or obtaining burn permits prior to burning the materials.

• Unlike District Rule 4103, SMAQMD Rule 407 does not allocate burning based on the predicted meteorological conditions and whether it would cause nuisance, impact smoke sensitive areas, or create or contribute to an exceedance of the ambient air quality standard.

• Unlike District Rule 4103, SMAQMD Rule 4 07 does not restrict th e time of day when burns are ignited and conducted.

• Unlike District Rule 4103, SMAQMD Rule 407 does not require the use of at least one best management practice for the control of certain type of weeds located along

ditch banks or canal banks.

Based on the above discussion, District staff deems that District Rule 4103 is more stringent than SMAQMD Rule 407.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-17 D. Sac Metro AQMD Rule 501 (Agricultural Burning)

SMAQMD Rule 501 regulates ag ricultural burning. Agricult ural burning is defined in the rule as open outdoor fires to dispose agribus iness waste, agribusiness-related waste, forest management, range improvement, improv ement of land for wildlife and game habitat, prevention of disease or pests, irrigation system management, wild land vegetation management, or disposal of empty paper containers of agricultural

chemicals.

SMAQMD Rule 501 prohibits igniting, conduc ting, or allowing agricultural burning on a no-burn day, except as when the designate d agency determines that denial of burn permission would pose imminent and subst antial economic loss and the designated agency approves or conditionally approves a special permit authorizing such burning on a no-burn day. The authorization to burn dur ing no-burn day will lim it the amount of acreage that may be burned in any one day and when the downwind populated areas are forecast by the district or designated agent to achieve the state and federal ambient air quality standards.

SMAQMD Rule 501 requires obtaining a burning permit prior to igniti ng, conducting, or allowing agricultural burning. The rule prohibits the burning of material that is not clearly described in the authorized burn permit. An approved burn permit is not valid for any time when agricultural burning is prohibited by either the State B oard or the APCO or has been restricted by the APCO. A permit hol der or any other person is not exempt from any fire control or prev ention statute or regul ation, or if burning is prohibited by a public fire control agency.

SMAQMD Rule 501 specifies the followi ng standards for all agricultural burning:

• The acreage shall not exceed should not exceed the acreage allotment determined pursuant to the agricultural Burning Plan.

• The APCO may restrict agricultural burning to less than the State-allotted acreage or may declare a no-burn day in all or in part of the district depending on meteorological conditions that would cause undue emissions to be transported to a sensitive receptor or populat ed areas or cause a nuisance.

• No agricultural burning will be conducted wh en the wind direction is such that smoke

from the burn will cause or does cause a nuisance.

• Contact the designated agency or fire pr otection agency having jurisdiction over the burn location prior to the burn, on the same day as the burn.

• Ignite using an approved ignition device. Other ignition methods may be authorized by special permit when and where the fire protection agency has declared that an

extreme fire hazard exists or where the designated agency has determined that crops do not lend itself to strip-firing or backfiring

• For field crop stubble, ignite by stri p-firing into the wind or backfiring.

• Specifies the allowable ignition hours.

• Specifies materials that are prohibited to be burned as part of any type of agricultural burning.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-18 • Requires agricultural waste to be a rranged to burn with minimum of smoke.

• Requires a minimum drying time pr ior to burning agricultural waste.

• Requires a mechanical rice straw spreader to be used in rice harvesting to ensure even distribution of the straw, but rice straw may be left in rows provided it meets the specified drying time prior to being burned.

• Except for rice straw acreage that was harvested prior to September 10, prohibits burning of field crop acreage during October 1 through November 15 of each year, unless a special permit is approved.

• Prohibits agricultural burning in the ce rtain boundary in the northwest Sacramento area if the APCO or fire protection agen cy predicts that winds will be from the direction within 90 degrees of true north . The exception is if the burning is necessary to preclude hazards on public t horoughfares or at airports due to smoke or can be performed without causing a nuisance.

• Burn only agribusiness waste or agribusin ess-related waste that is reasonably free of excessive dirt, soil, and visible moisture.

• Agricultural burning must occur where the material being burned was grown or raised, or in the case of agr ibusiness-related waste, used.

• Specifies certain standards for forest management burning, range improvement burning, irrigation system management, wild land vegetation management burning, and burning of empty paper containers of agricultural chemicals.

• Specify administrative requirements for permit application information, approval of burning permits, permit statement, advanc e notice request, and suspension or revocation of approved permit.

Overall, District Rule 4103 is more stringent than SMAQMD Rule 501 for the following major reasons:

• District Rule 4103 prohibits open burning of almost all agricultural wastes, except prunings from apples crops, pears crops, fi g crops, and quince crops, as well as weed abatement activities affecting wate rways for which open burning is allowed until June 1, 2010. District Rule 4103 allo ws open burning of orc hard removal from citrus, apple, pear, quince, fig crops and orchard removal of up to 20 acres per location per calendar year until June 1, 2010, the burning of rice straw until June 1,
2015. SMAQMD Rule 501 allows open burning of agricultural waste.

• SMAQMD Rule 501 regulates forest management burning, range improvement burning, wildlife and game habitat which are not regulated by District Rule 4103 but are regulated by District 4106 (Prescribe Burning and Ha zard Reduction Burning)

.

• Unlike District Rule 4103, SMAQMD Rule 407 does not require the use of at least one best management practice for the control of certain type of weeds located along

ditch banks or canal banks.

Based on the above discussion, District staff deems that District Rule 4103 is more stringent than SMAQMD Rule 501.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-19 E. Ventura County APCD Rule 56 (Open Burning)

VCAPCD Rule 56 applies to the burning of com bustible materials in open outdoor fires. The rule allows open burning provided the following requirements are met:

• A valid burn permit must be obtained prior to burning.

• Open burning is allowed only on days dec lared to be Burn Days by the APCO.

• Open burning is allowed for disposal of agricultural waste in the pursuit of agricultural operations, range improvemen t, wildland vegetati on management, levee, reservoir or ditch maintenance, an d disposal of Russian thistle.

• Burn only plant material that grew on pr operty where the burn is conducted, or on another property of the same grower if approved by APCO.

• Material to be burned should be reasonably free from dirt, soil and visible moisture.

• Material to be burned should sufficiently dr y (except for prescribed burning) for the minimum time period specified in the rule.

• Material to be burned should be stack ed or arranged to allow maximum air circulation to minimize smoke during combustion.

• Use only ignition device approved by the APCO or the fire protection agency, and should be ignited as rapidly as practic able within fire control restrictions.

• Conduct open burning when wind speed and dire ction will not carry emissions into

smoke sensitive areas.

• Conduct burning during time per iods specified in the rule.

• The amount, timing, and location of all open bur ning will be restricted by the district to minimize smoke impacts on smoke sensitive areas.

VCAPCD Rule 56 includes specific require ments for prescri bed burning and range improvement burning. Among other things , range improvement burning requires a

statement from the De partment of Fish and Game certifying that burning is desirable and proper. For prescribed burning, the land manger should submit a smoke management plan that includes specific information detailed in the rule for review and approval by the district. A dditionally, for prescribed bur ning, the land manager should register all planned burn projects annually or seas onally to the district.

VCAPCD Rule 56 exempts outdoor fires for the following purposes:

• Heating or cooking food for human c onsumption or for recreational purposes.

• Burning of unserviceable American flag.

• Fires authorized public officer to prevent fire hazard, training in the methods of fighting fires, etc.

• Setting of backfires to save life or valuable property.

• Abatement of fire hazards.

• Disease or pest prevention.

• Remediation of oil spill.

Overall, District Rule 4103 is mo re stringent than VCAPCD Rule 56 for the following major reasons:San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-20 • District Rule 4103 prohibits open burning of almost all agricultural wastes, except prunings from apples crops, pears crops, fi g crops, and quince crops, as well as weed abatement activities affecting wate rways for which open burning is allowed until June 1, 2010. District Rule 4103 allo ws open burning of orc hard removal from citrus, apple, pear, quince, fig crops and orchard removal of up to 20 acres per location per calendar year until June 1, 2010, the burning of rice straw until June 1,

2015. VCAPCD Rule 56 allows open burning of any agricultural waste.

• VCAPCD Rule 56 regulates range improvement burning, wildlife and game habitat and prescribed burning which are not r egulated by District Rule 4103 but are regulated by District 4106 (Prescribe Burning and Hazard Reduction Burning).

• Unlike District Rule 4103, VCAPCD Rule 56 does not require the use of at least one best management practice for the control of certain type of weeds located along

ditch banks or canal banks.

Conclusion

There are no federal rules and regulations that apply to open burning. After careful evaluation the prohibitory rules in other California nonattainment areas, District staff

concludes that District Rule 41 03 satisfies RACT for open burning.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-21 

### Rule 4104 (Reduction of Animal Matter)

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023
NOx NQ NQ NQ NQ NQ NQ NQ NQ

VOC NQ NQ NQ NQ NQ NQ NQ NQ
(Source: District 2007 Ozone Plan)

District Rule 4104 Description

Rule 4104 applies to source operations used for the reduction of animal matter which involves any heated process, including rend ering, cooking, dr ying, dehydration, digesting, evaporating, and protein concentrati on. The rule prohibits operation of any machine/equipment used in r eduction of animal matter unle ss all gases, vapors, and gas-entrained effluent are incinerated at a temperature of at least 1200 o F for a period of not less than 0.3 seconds, or processed in a m anner that is equally or more effective as determined by the APCO.

How does District Rule 4407compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

District staff’s review of the EPA CTG list indi cates that there is no CTG for reduction of

animal matter.

B. EPA – Alternative Control Techniques (ACT) Document

District staff’s review of the EPA ACT list indi cates that there is no ACT for reduction of

animal matter.

C. Standards of Performance fo r New Stationary Sources (NSPS)

40 CFR 60 (Standards of Performance for Ne w Sources) does not specify any NSPS for

reduction of animal matter.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

40 CFR 61 (NESHAP) and 40 CFR (NESHAP for S ource Categories) do not specify any

NSPS for reduction of animal matter.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-22 How does District Rule 4104 compare to rules in other air districts?

District staff compared District Rule 4104 with the rules of ot her California ozone

nonattainment air districts’ rules. The results of the analysi s are discussed below.

• South Coast Air Quality Management Distr ict (SCAQMD) Rule 472 (Reduction of Animal Matter) adopted May 7, 1976

• Bay Area Air Quality Management District (BAAQMD) Regulation 12 Rule 2 (Rendering Plants) adoption date not available

• Sacramento Metropolitan Air Quality Manage ment Air District, Rule 410 (Reduction of Animal Matter) amended August 3, 1977

• Ventura County Air Polluti on Control District Rule 58 ((Reduction of Animal Matter) amended May 23, 1972

A. South Coast Air Quality Manage ment District (SCAQMD) Rule 472 (Reduction of Animal Matter)

SCAQMD Rule 472 prohibits the operation or use of any equipment for the reduction of animal matter unless all gases, vapors, and gas entrained effluents from such equipment are incinerated at tem peratures of not less than 650 o C (1202 o F for a period of not less than 0.3 second, or processed in such a manner that is determined by the APCO to be equally or more effectiv e than the conditions stated above.

District Rule 4104 requires an in cineration tem perature of 1200 o F compared to
SCAQMD Rule 472 temperature of 1202 o F. However, District staff’s review of the District Permit database indicates that permitt ed incineration equipment such as thermal oxidizer requires a temperature of 1400 o F for a period of no less than one second. Based on the above discussion, District staf f deems that District Rule 4401 is as stringent as SCAQMD Rule 1108.

B. Bay Area Air Quality Management Di strict (BAAQMD) Regulation 12 Rule 2 (Rendering Plants)

BAAQMD Regulation 12 Rule 2 requires the an incineration temperature 1202 o F and for a period of not less than 0.3 second, or processed in a manner which is equally or more effective for the purpose of air polluti on odor control as determined by the APCO.

District Rule 4104 requires an in cineration tem perature of 1200 o F compared to BAAQMD Rule 472 temperature of 1202 o F. However, District staff’s review of the District Permit database indicates that permitt ed incineration equipment such as thermal oxidizer requires a temperature of 1400 o F for a period of no less than one second. Based on the above discussion, District staf f deems that District Rule 4104 is as stringent as BAAQMD Regulation 12 Rule 2.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-23 C. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 410 (Reduction of Animal Matter)

SMAQMD Rule 410 requires the an incineration temperature 1202 o F and for a period of not less than 0.3 second, or process ed in a manner which is equally or more effective for the purpose of air pollution control as determined by the APCO.

District Rule 4104 requires an in cineration tem perature of 1200 o F compared to
SMAQMD Rule 410 temperature of 1202 o F. However, District staff’s review of the District Permit database indicates that permitt ed incineration equipment such as thermal oxidizer requires a temperature of 1400 o F for a period of no less than one second. Based on the above discussion, District staf f deems that District Rule 4104 is as stringent as SMAQMD Rule 410.

D. Ventura County Air Pollution Control District (VCAPCD) Rule 58 (Reduction of Animal Matter)

VCAPCD Rule 58 requires the an incineration temperature 1300 o F for a period of not less than 0.4 second, or processed in a m anner which is equally or more effective for the purpose of air pollution contro l as determined by the APCO.

District Rule 4104 requires an in cineration tem perature of 1200 o F for a period of 0.3 second compared to VCAPCD Ru le 58 temperature of 1300 o F for a period of not less than 0.4 second. However, District staff’ s review of the District Permit database indicates that permitted incineration equipment such as thermal oxidizer requires a temperature of 1400 o F for a period of no less than one second. Based on the above discussion, District staff deems that District Rule 4104 as stringent as stringent as

VCAPCD Rule 58.

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, Distric t staff concludes that District Rule 4104

satisfies RACT for reduc tion of animal matter.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-24 

### Rule 4106 – Prescribed Burning and Hazard Reduction Burning

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 3.41 3.40 3.39 3. 38 3.38 3.36 3.34 3.32

VOC 7.85 7.82 7.79 7. 78 7.76 7.72 7.68 7.63
(Source: District 2007 Ozone Plan)

District Rule 4106 Description

District Rule 4106 applies to prescribed burning and hazard reduction burning conducted within the San Joaquin Valley Air Ba sin. The purpose of this rule is to permit, regulate, and coordinat e the use of prescribed burning and hazard reduction burning while minimizing smok e impacts to the public.

District Rule 4106 includes the follo wing requirements and prohibitions

General Requirements

• Rule 4106 provides that r egardless of the status of bur n permits or burn plans, no prescribed or hazard reduction burning may occur at any location in the District unless it is within the allocation for the day for the region in which it is located and the burning has been author ized by the District.

• The APCO will allocate burning based on t he predicted meteorolog ical conditions and whether it would cause nuisance, impac t smoke sensitive areas, or create or

contribute to an exceedance of the ambient air quality standard.

• The APCO will restrict the time of day when burns are ignited and conducted.

• No prescribed burning or hazard reduc tion burning will be permitted that will create nuisance as defined in the state Health and Safety Code.

• All burning authorized pursuant to the rule shall be subj ect to any requirements, restrictions or prohibitions of the fire protection agency having jurisdiction over

the burn site.

Prescribed Burning

• Ignition of a prescribed burn shall not occur on a no-burn day.

• Rule 4106 provides that planned bur n projects be submitted annually or seasonally for registration. The annual registration would have to include areas being considered for potential natura lly ignited wildland fires managed for

resource benefits. Rule 4106 also descr ibes the information that must be included in the annual regist ration of prescribed burning projects and includes provisions related to plan review and approval. The District must approve or disapprove the plan and/or provide co mments on the element s of the smoke management section within 30 days or it will be deemed adequate and approved

as submitted.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-25 • Requires that any person responsible for conducting a prescribed burn greater than ten acres in size or projected to em it more than one ton of particulate matter take a smoke management class approved by the APCO.

• For a multi-day burn which may impact smoke sensitive areas, a land manager or his or her designee shall coordinate daily with the Dist rict or the ARB to affirm that the burn project rema ins within the conditions specified in the smoke management plan, or whether conti ngency plans must be implemented.

Smoke Management Plans

• Smoke Management Plans (SMPs) woul d be required for all prescribed burn projects.

• SMPs require progressively more detail as the acreage and/or projected emissions get larger.

• For projects less than 10 acres in size or projected to produce less than 1 ton of particulate matter a SMP must be submitted that includes:

o A legal description of the burn, including maps,

o A description of the type of fuels and the amount of fuels in tons or acres

o The identity and mailing address of t he responsible personnel, including telephone numbers for 24-hour contact.

• For projects larger than 10 acres but less than 100 acres in size a SMP must

also includes:

o The distance and compass headings of sm oke sensitive areas within five (5) miles including but not limit ed to schools, day care cent ers, hospitals, medical clinics, populated areas, highways.

o A description of the wind speed and direction necessary for burning.

o A description of the anticipated durati on of project’s smoke production from ignition to burn down.

• For projects larger than 100 acres but less than 250 acres in size a SMP must

also include

o A description of the meteorological c onditions the land manager or his/her designee will use for making burn ignition decisions to limit smoke impacts to

smoke sensitive areas.

o A description of the sm oke management criteria t he land manager or his/her designee will use for making burn ignition decisions.

o A description of the per acre fuel loadi ng, including the fuel type, existing fuel loading in tons per acre, and anticipated fuel consumption. Describe the fuel expected to be consumed such as duff, fines, 1-, 10-, 100- , and/or 1000-hour fuels, live fuels, etc.

o Identification of potential impacts to smoke sens itive areas as determined by mapping the daytime and nighttime sm oke paths, including upslope and downslope and/or diurnal drainage flow, for a distance of twenty-five miles

from the burn site.

o Identification of the population located in the potential smoke sensitive areas.

o A description of how the public will be informed of the possible effects of

smoke and the duration of t he effects. Include copies of public information planned for release.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-26 o A description of the type and frequency of the surveillance and/or monitoring that will be conducted to determine any smoke impacts to smoke sensitive

areas.

o a description of the specific smoke contingency actions that will be taken in the event smoke impacts occur in smok e sensitive areas or meteorological conditions deviate from those spec ified in the smoke management plan.

o a description of what post-burn Be st Available Control Measures will be implemented to limit the duration of smok e impacts to smoke sensitive areas.

• For projects larger than 250 acres in size a SMP must also include

o A description of the surv eillance and air monitoring me thods. Monitoring may be visual monitoring, ambient particula te monitoring or other monitoring approved by the District. The type of m onitoring required for a specific burn project shall be determined in consulta tion with the District and a description of the monitoring shall be included in the smoke management plan for that project.

o A description of the surveill ance and air monitoring methods.

o A description of the smoke complaint handling procedures.

o A description of the decision making process that will be used in implementing smoke mitigations procedures.

o A description of the responsive impact mitigations up to and including a declaration of a wildfire and aggressive fire suppression.

o A post-burn smoke management evaluation.

Naturally Ignited Fires

• Naturally ignited wildland fires occurri ng on a “no-burn” day shall not be allowed to continue as a prescribed burn unless, after consultation, the District decides, for smoke management purposes, that t he burn can be managed for resource

benefits.

• If a naturally ignited wildland fire is allowed to continue for resource benefits, smoke management plans are required within 72 hours of the start of the fire.

Hazard Reduction Burning

• No person shall knowingly set or pe rmit hazard reduction burning unless they have a valid Permit by t he APCO or his designee.

• No vegetation shall be burned unless it is described on a valid Permit.

• The vegetation shall be in a condition that will facilitate combustion and minimize

the amount of smoke emi tted during combustion.

• Vegetation to be burned shall be igni ted only with an APCO approved ignition

device.

• Vegetation shall not be burned unless it is free of excessive dirt, soil, and

moisture.

• Vegetation shall not be bur ned unless it is arranged or loosely stacked in such a manner as to promote dr ying and insure combustion with a minimum of smoke production.

• A Permit shall be valid only on those da ys during which burning is not prohibited by the ARB, by the District or by t he designated agency having jurisdiction overSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-27 the site of the proposed burning pursuant to section 41855 of the California Health and Safety Code and the District has authorized the burning as being within the day’s burn system allocation for the region in which the burn site is

located.

How does District Rule 4106 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

District staff’s review of the EPA CTG list indi cates that there is no CTG for prescribed burning or hazard reduction burning.

B. EPA – Alternative Control Techniques (ACT) Document

District staff’s review of the EPA ACT list in dicates that there is no ACT for prescribed burning or hazard reduction burning.

C. Standards of Performance fo r New Stationary Sources (NSPS)

District staff’s review of 40 CFR 60 (St andards of Performanc e for New Sources) indicates that there is no NSPS for prescr ibed burning or hazard reduction burning.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

District staff’s review of 40 CFR 61 (NESHAP) and 40 CFR (NESHAP for Source Categories) indicates that there is no N ESHAP or MACT for prescribed burning or hazard reduction burning.

How does District Rule 4106 compare to rules in other air districts?

District staff compared District Rule 4106 with the rules of ot her California ozone nonattainment air districts’ rules on pre scribed burning or hazard reduction burning.

The results of the anal ysis are discussed below.

• South Coast Air Quality Management Distr ict Rule 444 (Open Burning) amended December 21, 2001

• Bay Area Air Quality Management Distric t Regulation 5 (Open Burning) amended November 2, 1994

• Sacramento Metropolitan Air Quality Management Air District Rule 501 (Agricultural Burning) amended April 3, 1997

• Ventura County Air Pollut ion Control District) Ru le 56 (Open Burning) amended November 11, 2003San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-28 A. South Coast AQMD Rule 444 (Open Burning)

SCAQMD Rule 444 applies to open burning, burni ng of agricultural waste, disposal of Russian thistle, prescribed burning, fire prevention/suppression training, open detonation or use of pyrotechnics, fire hazard, disposal of infectious wastes (other than hospital waste), research and testing materi als equipment or techniques, disposal of contraband, and residential burning.

SCAQMD Rule 444 prohibi ts open burning unless:

• The executive officer has declared the day as a permissive burn day and such burning is not prohibited by a public fire protection agency.

• A written permit and an authorization are obt ained from the execut ive for each day of prescribed burning or haz ard reduction burning.

SCAQMD Rule 444 allows open burning for:

• Agricultural burning;

• Prescribed burning;

• Disposal of Russian thistle;

• Fire hazard abatement that a fire protection agency dete rmines cannot be abated by any viable option;

• Disposal of waste infected with agricultu ral pest or disease and ordered by the county agricultural commissioner;

• Disposal of infectious waste (other than hos pital waste) ordered by the county health officer;

• Use of pyrotechnics for creation of s pecial effects in motion pictures, etc.;

• Disposal of contraband in the possession of law enforcement personnel provided burning is the only available reaso nable method for safe disposal; and

• Fire prevention training; and researching and testing fire reta rdant properties of materials, etc.

SCAQMD Rule 444 prohibits open burning for

• Residential burning;

• Disposal of waste except as mentioned above;

• Materials generated as a result of land us e conversion for non-agricultural purposes;

• Disposal of materials from the production or storage of militar y ordnance, etc.; and

• Wildland suppression fires except those se t by fire protection agencies to save life and property.

SCAQMD Rule 444 requires prescribed burni ng or hazard reduction burning to comply with the following:

• Prescribed burning shall not be conduct ed until a burn implementation plan is approved in writing by the Executive Officer.

• A person shall conduct or allow prescr ibed burning only when the fires are set by, under the jurisdiction of, or pursuant to the orders or requirements of a fire protection

agency.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-29 • Prior to conducting or allowing prescribed burning for any project greater than 10 acres or that produces more than one t on of particulate matter emissions, as determined using EPA AP-42 or equivalent emissions factors approved by the Executive Officer, CARB, and EPA, a pers on shall have a Smoke Management Plan approved in writing by the Executive Office r. At a minimum, the Smoke Management

Plan shall contain the following information:

o location, types, and amounts of material to be burned;

o expected duration of the fire from ignition to extinction;

o identification of responsible perso nnel, including telephone contacts;

o identification and location of all smoke sensitive areas; and

o where the particulate emissions t onnage is selected as the criteria for determining the project size, calculation of the particulate emissions tonnage.

• Prior to conducting or allowing prescribed burning for any project greater than 100 acres or that produces more than 10 tons of particulate matter emissions, as determined using EPA AP-42 or equivalent emissions factors approved by the Executive Officer, CARB, and EPA, a pers on shall have a Smoke Management Plan approved in writing by the Executive Office r. At a minimum, the Smoke Management Plan shall contain the information requir ed for 10-100 acre burns and the following

information:

o Identification of me teorological conditions necessary for burning

o The smoke management cr iteria the land manager will use for making burn ignition decisions

o Projections, including a map, of where the smoke from burns are expected to travel both day and night

o Specific contingency actions (such as fire suppression or containment) that will be taken if smoke impacts occur or meteorological conditi ons deviate from those specified in t he smoke management plan

o An evaluation of and consideration of economically, and logistically viable alternatives to burning

o Discussion of public notification procedures.

• The Executive Officer shall prioriti ze burn authorization requests based upon:

o the burner’s demonstrated level of training identified in the burn implementation and smok e management plans

o the measures identified in the sm oke management plan proposed to reduce

emissions.

• The Executive Officer may allow prescri bed burning on marginal burn days provided a smoke management plan has been approved and the predicted daily maximum hourly average ozone concentration in the s ource receptor area of the prescribed

burn meets the Californi a 1-hour ozone standard.

SCAQMD Rule 444 specifies that the execut ive officer may allow the certain specified maximum daily burn acreage for agricultural burning and prescribed burning as follows:

• Except for Coachella Valley, 150 acre s for prescribed wildland and range burning, and 150 acres for agricultural burning.

• For Coachella Valley, 5 acres for pr escribed wildland and range burning and 35 acres for agricultural burning.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-30 • The above restrictions do not apply to prescribed burning when a land manger demonstrates that it is requi red to reduce fire hazard t hat jeopardized public health and safety and a satisfactory smoke m anagement plan is submitted and approved by the air district.

SCAQMD Rule 444 ex empts the following;

• Wildfire suppression ignited to save lif e and valuable property conducted by fire protection agency.

• Fire prevention/suppression training, except for the bur ning of existing structure, conducted by fire protection agency fo r no more than 30 minutes. Training involving burning of existing structure is exempt provided each training is no

more than 30 minutes.

• Burning of Russian thistle is exempt from having to get authorization from the

district.

• Recreational fires or ceremonial fires.

• Open burning of natural gas, propane, unt reated wood, or charcoal for the purpose of preparation or warming of f ood for human consumption or generating warmth for social gathering.

• Open burning located on islands 15 mile s or more from the mainland coast.

• Fireworks displays or pyrotechnics used for the creation of special effects at theme parks.

• Detonation of explosives during quarry mining operations, bomb disposal by law enforcement agency, or demolition of buildi ngs or structures.

• Pyrotechnics, detonation of explosives, or fire effects for creation of special effects during theatrical productions, film ing of motion pictures, videotaping of television programs or other commercial filming or video production activities

must not be more than 30 minutes in duration.

SCAQMD Rule 444 applies to a variety of open burning activities which includes prescribed burning and hazard reduction burning which are not regula ted by District Rule 4106, but are regulated by District 4103 (Open Burning).

Overall, District Rule 4106 is more stringent than SCAQMD Rule 444 for the following major reasons:

• District Rule 4106 requires SMPs for pre scribed fires less than 10 acres. SCAQMD

Rule 444 has no similar restrictions.

• District Rule 4106 has SMP requirements fo r prescribed fires larger than 100 acres that SCAQMD Rule 444 does not, including:

o A description of the per acre fuel loading

o Identification of pot ential impacts to smoke sensit ive areas for a distance of twenty-five miles fr om the burn site.

o Identification of the population located in the potential smoke sensitive areas.

o A description of how the public will be in formed of the possible effects of smoke

and the duration of the effe cts. Include copies of public information planned for

release.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-31 o A description of the type and frequency of the surveillance and/or monitoring that will be conducted to determine any smoke impacts to smoke sensitive areas.

o a description of the specific smoke c ontingency actions that will be taken in the event smoke impacts occur in smoke sensitive areas or meteorological conditions deviate from those spec ified in the smoke management plan.

o a description of what post-burn Be st Available Control Measures will be implemented to limit the duration of sm oke impacts to smoke sensitive areas

• Rule 4106 provides that planned burn projects be submi tted annually or seasonally for registration. The annual registra tion would have to include areas being considered for potential nat urally ignited wildland fires managed for resource

benefits. Rule 4106 also describes the in formation that must be included in the annual registration of pr escribed burning projects and includes provisions related to plan review and approval. The District must approve or disapprove the plan and/or provide comments on the elements of the smoke m anagement section within 30 days or it will be deemed adequate and approved as submitted. SCAQMD Rule 444

has no similar restrictions.

• District Rule 4106 requires that any pers on responsible for conducting a prescribed burn greater than ten acres in size or projected to emit more than one ton of particulate matter take a smoke m anagement class approved by the APCO.
SCAQMD Rule 444 has no similar restrictions.

• SCAQMD is more stringent than District Rule 4106 because it establishes maximum daily burn acreage for agricultural burning a nd prescribed burning. However, these limits can be if a land manger demonstrates t hat it is required to reduce fire hazard that jeopardized public health and safety and a satisfactory smoke management plan is submitted and approved by the air district.

Based on the above discussion, District staff deems that additional SMP, planning, and training requirements in District Rule 4106 ma ke it more stringent than SCAQMD Rule

444.

B. Bay Area AQMD Regulat ion 5 (Open Burning)

BAAQMD Regulation 5 applies to open burni ng of agricultural waste, range management, forest management, and wildland m anagement. The rule prohibits a person from igniting, causing to ignite, permit to be ignited, or suffer , allow, or maintain fires within the district. No burning should take place in the district on other than a permissive burn day.

BAAQMD Regulation 5 allows the follo wing fires on permissive burn days:

• Disease and pests prevention;

• Crop replacement;

• Orchard pruning and attrition;

• Double cropping stubble;

• Hazardous materials (prevention or reducti on of fire hazard, disposal of dangerous materials);

• Fire training;San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-32 • Flood debris;

• Control growth of vegetation fr om irrigation ditches and canals;

• Disposal of material which is lying or gr owing within natural channels or flood control channels;

• Fires set for the purpose of range management and grazing;

• Fires set for the purpose of removing forest debris and for forest management;

• Fires set for the purpose of improvement of lowland and marsh for wildlife and game habitat;

• Fires set for the purpose of disposing contraband;

• Prescribed burning by state or federal agency, or thr ough cooperative agreement or contract involving st ate or federal agency.

• Fires set as part of commercial film or video production activities for motion picture

and television.

• Fires set as part of a planned civic event designed to educate or otherwise benefit the public.

BAAQMD Regulation 5 requires that any pers on conducting prescribed burning that is allowed by the rules must also comply with the following:

o Effective June 1, 2002, fires may not be conducted on other t han a permissive burn day.

o A smoke management plan must be submitted to the APCO for review at least 30 calendar days prior to the proposed burning that is consis tent with the most current USEPA guidance on wildland and prescribed fires (Interim Air Quality Policy on

Wildland and Prescribed Fire s, USEPA 1998, or any subsequent document that supersedes this document), and prov ides the following information:

o Location and specific objectives of each proposed burn

o Acreage, tonnage, type, and arrangem ent of vegetation to be burned

o Directions and distances to near by sensitive receptor areas

o Fuel condition, combustion and meteorol ogical prescription elements for the project

o projected burn schedule and expected durat ion of project ignition, combustion, and burn down (hours or days)

o specifications for monitoring and of verifying critical parameters

o including meteorological condition s and smoke behavior before and during the

burn

o specifications for disseminating project information to public

o contingency actions that will be taken dur ing the burn to reduce exposure if smoke intrusions impact any sensitive receptor area

o certification by a qualified professional re source ecologist, biologist, or forester that the proposed burning is necessary to achieve the specific management objective(s) of the plan

o a copy of the environmental impact analysis prepared for the plan that includes an evaluation of alternatives to burning, if such an analysis was required by state

or federal law or statute

o project fuel loading estimate (t ons vegetation/acre) by vegetation

o type(s) and a description of the calculation methodSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-33 o particulate matter emissions estimate in cluding referenced emission factor(s) and a description of the calculation method used

o Permission to burn shall be governed by the acreage burning allocation issued by

the APCO.

o For each day on which burning occurs, r eport the total ac reage and tonnage of vegetation actually burned to the APCO by telephone no later than 12:00 p.m. local time the following day.

o Within 30 calendar days following completi on of the burn project, provide a written post-burn evaluation to the APCO that addresses whethe r the project objectives

were met and describes actual smoke behavior.

o Any fire official seeking to conduc t prescribed burning in a geographical area considered for a potential naturally-igni ted wildland fire managed for resource benefits that is expected to exceed 10 acres in size shall annually register each burn project in writing with the APCO by Dece mber 31 each year, with updates as they occur. Once a decision is made to manage t he fire for resource benefits, the fire official shall provide a smoke management plan for the burn project to the APCO, upon request.

BAAQMD Regulation 5 requires that any per son conducting hazard reduction burning that is allowed by the rules must also comply with the following:

• The person setting the fire shall provide el ectronic, typewritten, legibly handwritten, or computer printed notificat ion to the District prior to the burn on a District-approved

form or facsimile thereof.

• The fire must be set or allowed by any public fire official having jurisdiction, in the performance of official duty.

• The fire must, in the opinion of such o fficer, be necessary, and the fire hazard not able to be abated by any other means.

• No fires involving piled material shall be i gnited or take place before 9:30 a.m. local time on any day.

BAAQMD Regulation 5 applies to a variety of open burning activities which includes activities which are not regulated by District Rule 4106, but are regulated by District Rule 4103 (Open Burning).

Overall, District Rule 4106 is more stringent than BAAQMD Regulation 5 for the following major reasons:

• District Rule 4106 requires that no pers on shall knowingly set or permit hazard reduction burning unless they have a valid Permit by the APCO or his designee. BAAQMD Regulation 5 requires that the person setting the fire notify the District of a pending burn and keep a personal record of burning activities.

• Ignition of a prescribed burn shall not occur on a no-burn day under District Rule 4106. BAAQMD Regulation 5 contains no such restrictions.

• District Rule 4106 requires that any pers on responsible for conducting a prescribed burn greater than ten acres in size or projected to emit more than one ton of particulate matter take a smoke m anagement class approved by the APCO. BAAQMD Regulation 5 has no similar requirement.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-34 • BAAQMD Regulation 5 has the same requirements for all Smoke Management Plans, regardless of fire size. For smalle r fires (less than 100 acres) Regulation 5’s SMP requirements are stricter than District Rule 4106. However, for larger fires (over 100 acres) District Rule 4106 has mo re stringent requireme nts for SMPs.

Based on the above discussion, District staff deem s that District Rule 4106 is overall more stringent than BAAQMD Regulation 5.

C. Sac Metro AQMD Rule 501 (Agricultural Burning)

SMAQMD Rule 501 applies agricultural open outdoor fires. Non-agricultural burning is regulated under SMAQMD Rule 407 (Open Burning).

SMAQMD Rule 501 prohibits the following:

• Burning of petroleum waste, demolition waste, tires, trees, wood waste, or other combustible or flammable solid or liquid waste, motor vehicle bodies, materials for the purpose of metal salvage, putrescible materials, bedding, asphaltic products, or rubber products.

• Burning or allowing to be burned, or ma intaining any open outdoor fire for the purpose of burning refuse or organic waste on an agricultural no-burn day.

• Burning or allowing to be burned, or ma intaining any open outdoor fire for the purpose of burning refuse or organic waste at any time at certain locations specific in

the rule.

SMAQMD Rule 501 contains the following s pecific standards for prescribed burning:

o Vegetation to be burned shall be in a condi tion that will facilitate combustion and

minimize the amount of smok e emitted during combustion.

o For wild land vegetation management burni ng projects exceeding 10 acres in size, the following information—in addition to the information set fo rth in the burning permit application —shall be provided to the designated agency for review and approval 30 days in advance of the proposed burning:

o The location and specific objectives of the burn project

o The acreage or tonnage, type and arrangem ent of wild land vegetation to be

burned

o The directions and distances to nearby sensitive receptor areas

o The fuel condition, combustion, and me teorological pre scription elements developed for the burn

o The projected schedule and duration of project ignition, combustion, and burn

down

o The specifications for monitoring and verifying critical project parameters

o The specifications for disseminating proj ect information—i.e., notification of the public, the designated agency, the fire pr otection agency having jurisdiction, and other affected agencies of the time, date, location, and acreage of the proposed

burn.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-35 Overall, District Rule 4106 is more stri ngent than SMAQMD Rule 501 for the following major reasons:

• District Rule 4106 prohibits prescribed burni ng or hazard reduction burning of almost all agricultural wastes, exce pt prunings from apples cr ops, pears crops, fig crops, and quince crops, as well as weed abatement activities affect ing waterways for which prescribed burning or hazard reduction burning is allowed until June 1, 2010. District Rule 4106 allows prescribed burning or hazard reduction burning of orchard removal from citrus, apple, pear, quince, fig crops and orchard removal of up to 20 acres per location per calendar year until J une 1, 2010, the burning of rice straw until June 1, 2015. SMAQMD Rule 501 allows prescribed burning or hazard reduction burning of agricultural waste.

• Unlike District Rule 4106, SMAQMD Rule 501 does not require submission of burn plans or obtaining burn permits prior to igniting a hazard reduction burn.

• Unlike District Rule 4106, SMAQMD Ru le 501 does not allocate burning based on the predicted meteorological conditions and whether it would cause nuisance, impact smoke sensitive areas, or create or contribute to an exceedance of the ambient air quality standard.

• Unlike District Rule 4106, SMAQMD Rule 501 does not restrict the time of day when burns are ignited and conducted.

• Unlike District Rule 4106, SMAQMD Ru le 501 does not require Smoke Management

Plans for burns less than 10 acres.

• Unlike District Rule 4106, SMAQMD Rule 501 does not have more stringent Smoke Management Plan requirements for burns over 100 acres.

Based on the above discussion, District staff deems that District Rule 4106 is more stringent than SMAQMD Rule 501.

D. Ventura County APCD Rule 56 (Open Burning)

VCAPCD Rule 56 applies to the burning of com bustible materials in open outdoor fires. The rule allows open burning provided the following requirements are met:

• A valid burn permit must be obtained prior to burning.

• Open burning is allowed only on days dec lared to be Burn Days by the APCO.

• Open burning is allowed for disposal of agricultural waste in the pursuit of agricultural operations, range improvemen t, wildland vegetati on management, levee, reservoir or ditch maintenance, an d disposal of Russian thistle.

• Burn only plant material that grew on pr operty where the burn is conducted, or on another property of the same grower if approved by APCO.

• Material to be burned should be reasonably free from dirt, soil and visible moisture.

• Material to be burned should sufficiently dr y (except for prescribed burning) for the minimum time period specified in the rule.

• Material to be burned should be stack ed or arranged to allow maximum air circulation to minimize smoke during combustion.

• Use only ignition device approved by the APCO or the fire protection agency, and should be ignited as rapidly as practic able within fire control restrictions.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-36 • Conduct open burning when wind speed and dire ction will not carry emissions into

smoke sensitive areas.

• Conduct burning during time per iods specified in the rule.

• The amount, timing, and location of all open bur ning will be restricted by the district to minimize smoke impacts on smoke sensitive areas.

VCAPCD Rule 56 includes specific requi rements for prescr ibed burning and range improvement burning, including:

• The vegetation to be burned shall be in a condition that will facilitate combustion and

minimize the amount of smok e emitted during combustion.

• Burning at night and multi-day burns s hall be minimized whenever practicable.

• For range improvement burning conducted pr imarily for improvement of land for wildlife and game habitat, the applicant shall file with the APCD a statement from the Department of Fish and Game certifying t hat burning is desirable and proper. The Department of Fish and Game may specify the amount of brush treatment required, along with any other conditions it deems appropriate.

• The land manager or his/her designee shal l register all planned burn projects annually or seasonally with the APCD, incl uding areas considered for potential naturally-ignited wildland fires managed for re source benefits, wit h updates as they

occur.

• The land manager or his/her designee must receive authorization to burn from the APCD the business day prior to burning.

• Prior to ignition on the day of the burn, the land manager or hi s/her designee shall

confirm with the APCD that all conditions and all requirements stated in the smoke management plan are met.

• When a natural ignition occurs on a No Bu rn Day, the initial "go/no-go" decision by the land manager to manage the fire for res ource benefit will be "no-go" unless, after consultation with the APCD or ARB, the APCD or ARB concurs, for smoke management purposes, that the burn can be managed for resource benefit. A "nogo" decision does not necessarily mean that the fire must be extinguished, but that

the fire cannot be cons idered prescribed burning.

• For naturally-ignited wildland fires managed for resource benefits that are expected to exceed 10 acres in size, the land manage r or his/her design ee shall submit a smoke management plan no later than 72 hour s after the start of the fire.

• For fires greater than 250 ac res, the land manager or his/ her designee, shall submit a post-burn smoke management evaluation to the APCD no later than 30 days after completion of the burn.

• Smoke Management Plans are required for bur ns over 10 acres and must include:

o The location and the specific objectives of the burn.

o The acreage or tonnage, type and arr angement of the vegetation to be

burned.

o The distances and directions to all pot entially affected smoke sensitive areas.

o The fuel condition, combustion and meteorological prescription elements developed for the project.

o The project schedule and duration of project ignition, combustion and

burndown.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-37 o Specifications for monitoring and verify ing critical parameters such as air quality or weather.

o A discussion of how the requirements of Section B of this Rule that apply to prescribed burning will be satisfied.

o A discussion of what specific contingen cy actions (such as fire suppression or containment) will be taken if unanticipat ed conditions cause smoke to create

or contribute to an exceedance of a st ate or federal am bient air quality standard or cause a public nuisance.

o A discussion of the procedure that t he land manager or his/her designee will use to coordinate daily with the APCD on multi-day burns, which may impact smoke sensitive areas, to affirm that the burn project remains within the conditions specified in the Plan, or whether contingency actions are

necessary.

o Specifications and procedures for di sseminating project information to the public.

o Procedures for public notification and education, including appropriate signage at burn sites, and fo r reporting any public smoke complaints to the

APCD.

o Identification of respons ible personnel, including 24- hour telephone contacts for on-site personnel responsible for the burn.

o The smoke management crit eria the land manager or his/her designee will use for making burn ignition decisions.

o Projections, including a map, of where the smoke is expected to travel, both day and night.

o An evaluation of alternatives to burning considered. If an analysis of alternatives has been prepared as part of the environmental documentation required for the burn project pursuant to the National Environmental Policy

Act or the California Environmental Quality Act, as applicable, the analysis shall be attached to the smoke management plan to satisfy this requirement.

Overall, District Rule 4106 is mo re stringent than VCAPCD Rule 56 because District Rule 4106 prohibits open burning of almost a ll agricultural wastes, except prunings from apples crops, pears crops, fig crops, and qui nce crops, as well as weed abatement activities affecting waterways for which op en burning is allowed until June 1, 2010. District Rule 4106 allows open burning of or chard removal from citrus, apple, pear, quince, fig crops and orchard removal of up to 20 acres per location per calendar year until June 1, 2010, the burning of rice st raw until June 1, 2015. VCAPCD Rule 56 allows open burning of any agricultural waste.

VCAPCD Rule 56 and District Rule 4106 have compar able requirements for naturally ignited fires and prescribed fires.

Based on the above discussion, District staff deems that District Rule 4106 is more stringent than VCAPCD Rule 56.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-38 Conclusion

There are no federal rules and regulations that apply to prescribed burning or hazard reduction burning. After careful evaluation the prohibitory rules in other California nonattainment areas, District staff concludes t hat District Rule 4106 satisfies RACT for prescribed or hazard reduction burning.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-39 

### Rule 4301 – Fuel Burning Equipment

Emissions Inventory: Tons per day – summer season

Pollutant 2002 2004 2006 2008 2012 2016 2020 2024

NOx 89.157 90.311 83.046 79.302 79.944 80.452 80.574 79.188
(Source: District 2007 Ozone Plan)

District Rule 4301 Description

This rule was originally enacted by Californi a Air Resources Board (CARB) in the early 1970s. The rule was delegated to all air di stricts in California soon thereafter.

This rule limits the concentration of com bustion contaminants to 0.1 grain per standard cubic feet of gas and limits maximum emissi ons rates of sulfur dioxide to 200 pounds per hour, nitrogen oxide to 140 pounds per hour, and combustion contaminants to 10 pounds per hour from fuel burning equipment.

How does District Rule 4301 compare wi th federal rules and regulations?

A. EPA - Control Techniques Guidelines

There is no CTG for this source category.

B. EPA - Alternative Control Techniques Guidelines

NOx Emissions from Process Heaters - EPA-453/R-93-034

NO
x Emissions from Utilit y Boilers - EPA-453/R-94-023

NOx Emissions from Industrial/Commercial/ Institutional Boilers - EPA-453/R-94-022

These documents outline the NOx control techni ques used in controlling emissions from boilers and process heaters; such as low-NO x burners (LNB's), ul tra-low NOx burners (ULNBs), selective non-catalytic reduction (SNCR), selective catalytic reduction (SCR) and flue gas recirculation (FGR).

The reduction efficiency of each control technique varies depending on the application and design. The control efficiencies for LN B, ULNB, and SCR are considered to be representative averages based on operating experience, range from 27% for LNB to 92% for LNB plus SCR.

This rule was the very first rule to limit NO x from process heaters and boilers or similar equipment used in process of burning fuel fo r primary purpose of producing heat or power by indirect heat transfe r before many of the above technologies were developed.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-40 Rule limits NOx emissions to 140 lb/hr regar dless of control technique or technology, equipment design, applicat ion, size or rating. Much lo wer emissions can reasonably be achieved using control techniques described above.

However, District’s permits database search determined that all permit units to which NOx requirements of rule 4301 apply, have been subject to the following SIP approved rules that supersede the NOx re quirements of this rule.

The following District rules have been determined by EPA to fulfill Best Available Control Measures (BACM) required for seri ous nonattainment areas per Section 189(b) of Clean Air Act as well RACT required fo r moderate nonattainment areas per Section 189(a) of Clean Air Act.

Rule 4306 - BOILERS, STEAM GENERATORS AND PROCESS HEATERS

Rule 4307 - BOILERS, STEAM GENERATORS, AND PROCESS HEATERS - 2.0

MMBTU/HR TO 5.0 MMBTU/HR

Rule 4308 - BOILERS, STEAM GENERATORS, AND PROCESS HEATERS (0.075 MMBTU/HR TO 2.0 MMBTU/HR)

Rule 4309 - DRYERS, DEHYDRATORS AND OVENS

Rule 4352 - SOLID FUEL FIRED BOILERS, STEAM GENERATORS, AND PROCESS

HEATERS

How does Rule 4301 compare to ru les in other air districts

District staff compared NOx lim its, optional control require ments, and work practice standards in District Rule 4301 to comparable requirements in rules from the following

California nonattainment areas:

• .South Coast Air Quality Management Distric t Rule 474 (Fuel Burning Equipment - Oxides of Nitrogen)

• Bay Area Air Quality Management District Regulation 9 Rule 6 (Nitrogen Oxides

Emissions from Natural Gas-Fired Boilers and Water Heater) and Regulation 9 Rule 7 (Nitrogen Oxides and Carbon Monoxide from Industrial, Institutional, and Commercial Boilers, Steam Gener ators, and Process Heaters)

• Sacramento Metropolitan Air Poll ution Control District Rule 411

• Ventura County Air Polluti on Control District Rule 60

A. South Coast AQMD Rule 474

South Coast AQMD Rule 474 allows NOx em issions that range from 125 ppmv to 400 ppmv @ 3% O 2

.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-41 B. Bay Area AQMD

Bay Area Air Quality Management District does not have any rule that is similar to District Rule 4301. However it has following ru les that were determined by EPA to fulfill Best Available Control Measures (BACM) r equired for serious nonattainment areas per Section 189(b) of Clean Air Act as well RACT required for m oderate nonattainment areas per Section 189( a) of Clean Air Act.

Rule 9-6 Nitrogen Oxides Emissions from Natu ral Gas-Fired Boilers and Water Heaters

This rule applies to equipment with heat input rating between 0.75 MMBtu/hr and 2.0

MMBtu/hr. Allowable NOx emissions range from 20 ppmv to 55 ppmv @ 3% O 2

.

Rule 9-7 Nitrogen Oxides and Carbon Monoxide from Indus trial, Institutional, and Commercial Boilers, Steam Gener ators, and Process Heaters

This rule applies to equipment with heat input rating greater than 2.0 MMBtu/hr. Allowable NOx emissions range fr om 5 ppmv to 30 ppmv @ 3% O 2

.

C. Sac Metro AQMD Rule 411

Sacramento Metropolitan Air Qua lity Management District does not have any rule that is

similar to District Rule 4301. However it has following rule that was determined by EPA

to fulfill Best Available Control Measures (BACM) required for serious nonattainment areas per Section 189(b) of Clean Air Act as well RA CT required for moderate nonattainment areas per Section 189(a) of Clean Air Act.

Rule 411 NOx from Boilers, Proc ess Heaters and St eam Generators

This rule applies to equipment with heat input rating greater than 1.0 MMBtu/hr. Allowable NOx emissions range fr om 9 ppmv to 30 ppmv @ 3% O 2

.

D. Ventura County APCD Rule 60

Ventura County Air Pollution Control District Rule 60 (New Non-Mobile Equipment - Sulfur Dioxide, Nitrogen Oxi des, and Particulate Matter) limits maximum emissions rates of nitrogen oxide to 140 pounds per hour from fuel burning equipment.

Conclusion

District staff has determined that Rule 4301 itself can not be considered to fulfill the Reasonably Available Control Technology. However Distric t staff concludes that NOx requirements of District Rule 4301 have been superseded by requi rements of other District Rule that satisfy RACT for fuel bur ning equipment, since all units subject to Rule 4301 are subject to a more spec ific NOx rule, discussed elsewhere.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-42 

### Rule 4306 – Boilers, Steam Gener ators, and Process Heaters, >5
MMBtu/hr

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 7.5 4.7 4.6 4. 6 4.7 4.7 5.2 5.4

VOC 0.7 0.7 0.7 0. 71 0.71 0.73 0.75 0.77
(Source: District 2007 Ozone Plan)

The emissions inventory for large boilers (> 5.0 MMBtu/hr) is assumed to be included as part of the inventory for Distr ict Rule 4306 (large boilers - fr om units rated at 5 MMBtu/hr or less); above are the baseline emi ssions from boilers as a whole. (Note: All Rule 4306 units are also subject to Rule 4320, which is more stringent)

District Rule 4306 Description

District Rule 4306, was adopted September 18, 2003, and was most recently amended October 16, 2008. The purpose of Rule 4306 is to limit NOx and CO emissions from boilers, steam generators, and process heaters. The rule applies to any gaseous fuel or liquid fuel fired boiler, steam generator, and process heater with a rated heat input of

5.0 million Btu/hr or greater. This source category includes a wide range of industries including but not limited to medical facilities, educational institutions, office buildings, prisons, military facilities, hot els and industrial industries.

Units subject to Rule 4306 ar e to be certified that they comply with the following NOx

and CO emission limits:

Rule 4306 NOx and CO Limits

Operated on Gaseous Fuel Operated on Liquid Fuel

NOx Limit Category

Standard Option Enhanced Option CO

Limit (ppmv) NOx Limit CO Limit (ppmv)

A. Units with a rated heat input equal to or less than 20.0 MMBtu/hour, except for Categories C, D, E, F, G, H,

and I units 15 ppmv or

0.018 lb/MMBtu 9 ppmv or

0.011 lb/MMBtu 400 40 ppmv or

0.052

lb/MMBtu 400

B. Units with a rated heat input greater than 20.0 MMBtu/hour, except for Categories C, D, E, F, G, H,

and I units 9 ppmv or

0.011 lb/MMBtu 6 ppmv or

0.007 lb/MMBtu 400 40 ppmv or

0.052

lb/MMBtu 400San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-43 

### C. Oilfield Steam

Generators 15 ppmv or

0.018 lb/MMBtu No option 400 40 ppmv or

0.052

lb/MMBtu 400

D. Refinery units with a rated heat input greater than 5 MMBtu/hr up to 65

MMBtu/hr 30 ppmv or 0.036

lb/MMBtu No option 400 40 ppmv or

0.052

lb/MMBtu 400

E. Refinery units with a rated heat input greater than 65 MMBtu/hr up to 110

MMBtu/hr 25 ppmv or

0.031 lb/MMBtu No option 400 40 ppmv or

0.052

lb/MMBtu 400

F. Refinery units with a rated heat input greater than 110

MMBtu/hr 5 ppmv or

0.0062 lb/MMBtu No option 400 40 ppmv or

0.052

lb/MMBtu 400

G. Load-following units 15 ppmv or 0.018

lb/MMBtu 9 ppmv or

0.011 lb/MMBtu 400 40 ppmv or

0.052

lb/MMBtu 400

H. Units limited by a Permit to Operate to an annual heat input of 9 billion Btu/year to 30 billion Btu/year 30 ppmv or 0.036

lb/MMBtu No option 400 40 ppmv or

0.052

lb/MMBtu 400

How does District Rule 4306 compare wi th federal rules and regulations?

District staff conducted a rule consistency anal ysis as part of the recent amendments to Rule 4306. This analysis was included with t he SIP submittal as Appendix E of the staff report. The purpose of this document was to compare the amended rule to federal rules, regulations and policies.

This analysis determined that Rule 4306 met or exceeded the following federal requirements:

• 40 CFR 60 Subpart D (Standards of Pe rformance for Fossil-Fuel Fired

Steam Generators for Which Constr uction Commenced After August 17, 1971)

• 40 CFR 60 Subpart Db (Standards of Performance for IndustrialCommercial-Institutional Steam Generating Units)

• 40 CFR 60 Subpart Dc (Standards of Performance for Small IndustrialCommercial-Institutional Steam Generating Units)

• 40 CFR 63 Subpart DDDDD (NESHAP fo r Industrial, Commercial, and

Institutional Boilers and Process Heaters)

• EPA –453/R-94-022 “Alternative Contro l Techniques (ACT) Document –

NOx Emissions from Industrial/Commerc ial/Institutional Boilers”, dated

March 1994

• EPA “Control Techniques Gu ideline (CTG) Document

• EPA Policy on Start-up or ShutdownSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-44 • EPA Policy on Recordkeeping

• EPA Policy on Representative Unit Testing

• EPA Policy on Alternate Emission Control Plan (AECP)

How does District Rule 4306 compare to rules in other air districts?

The recent amendments to Rule 4306 st rengthened emission limits and removed any exemptions which may have prevented the ru le from satisfying RACT. Due to the overall stringency of recent ly amended Rule 4306, the Distric t did not conduct a detailed comparison to rules in other air districts.

Conclusion

District staff concludes that District Rule 4306 satisfies RACT for Boilers, Steam Generators, and Process Heaters – 5.0 MMBtu/hr or greater.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-45 

### Rule 4307 – Boilers, Steam Generators, and Process Heaters – 2.0

MMBtu/hr to 5.0 MMBtu/hr

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 7.5 4.7 4.6 4. 6 4.7 4.7 5.2 5.4

VOC 0.7 0.7 0.7 0.71 0.71 0.73 0.75 0.77
(Source: District 2007 Ozone Plan)

The emissions inventory for medium size boile rs (2.0 to 5.0 MMBtu/hr) is assumed to be included as part of the inventor y for District Rule 4306 (large bo ilers - from units rated at 5 MMBtu/hr or greater); above are the baseli ne emissions from boilers as a whole.

District Rule 4307 Description

Rule 4307 was adopted by the District’s Go verning Board on December 15, 2005, and was most recently amended October 16, 2008. The purpose of Rule 4307 is to limit NOx and CO emissions from boilers, steam generators, and process heaters. The rule applies to any gaseous fuel or liquid fuel fired boiler, steam generator, and process heater with a rated heat input of 2.0 million Btu/hr up to and in cluding 5.0 million Btu/hr. This source category includes a wide range of industries in cluding but not limited to medical facilities, educational institutions, o ffice buildings, prisons, military facilities,

hotels and industrial industries.

Units subject to Rule 4307 ar e to be certified that they comply with the NOx and CO emission limits specified in the rule. For gaseous fuel-fired units the NOx limit is 30 ppmv or 0.036 lb/MMBtu and 400 ppmv for CO. For liquid fuel-fired units the NOx limit is 40 ppmv or 0.052 lb/MMBtu and 400 ppmv for CO . The most recent amendments to

Rule 4307 removed established lower NOx limits for new and replacement units (12 ppmv or 0.014 lb/MMBtu) and eliminated the ex emption associated with units that are

used at schools. The rule also limits emissions SO 2 , and PM10 from boilers, steam generators, and process heaters.

How does District Rule 4307 compare wi th federal rules and regulations?

District staff conducted a rule consistency analysis as part of the recent amendments to Rule 4307. This analysis was included with t he SIP submittal as Appendix E of the staff report. The purpose of this document was to compare the amended rule to federal rules, regulations and policies.

This analysis determined that Rule 4307 met or exceeded the following federal requirements:San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-46 • 40 CFR 60 Subpart D (Standards of Pe rformance for Fossil-Fuel Fired

Steam Generators for Which Constr uction Commenced After August 17, 1971)

• 40 CFR 60 Subpart Db (Standards ofPerformance for IndustrialCommercial-Institutional Steam Generating Units)

• 40 CFR 60 Subpart Dc (Standards of Performance for Small IndustrialCommercial-Institutional Steam Generating Units)

• 40 CFR 63 Subpart DDDDD (NESHAP fo r Industrial, Commercial, and

Institutional Boilers and Process Heaters)

• EPA –453/R-94-022 “Alternative Contro l Techniques (ACT) Document –

NOx Emissions from Industrial/Comme rcial/Institutional Boilers”, dated

March 1994

• EPA “Control Techniques Gu ideline (CTG) Document

• EPA Policy on Start-up or Shutdown

• EPA Policy on Recordkeeping

• EPA Policy on Representative Unit Testing

• EPA Policy on Alternate Emission Control Plan (AECP)

How does District Rule 4307 compare to rules in other air districts?

The recent amendments to Rule 4307 strengthened emission lim its and removed any exemptions which may have prevented the ru le from satisfying RACT. Due to the overall stringency of recent ly amended Rule 4307, the District did not conduct a detailed comparison to rules in other air districts.

Conclusion

District staff concludes that District Rule 4307 satisfies RACT for Boilers, Steam Generators, and Process Heaters – 2.0 MMBtu/hr to 5.0 MMBtu/hr.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-47



### Rule 4308 – Boilers, Steam Generato rs, and Process Heaters – 0.075
MMBtu/hr to 2.0 MMBtu/hr

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 7.5 4.7 4.6 4. 6 4.7 4.7 5.2 5.4

VOC 0.7 0.7 0.7 0.71 0.71 0.73 0.75 0.77
(Source: District 2007 Ozone Plan)

The emissions inventory for small size boilers (0.75 to 2.0 MMBtu/hr) is assumed to be included as part of the inventor y for District Rule 4306 (large bo ilers - from units rated at 5 MMBtu/hr or greater); above are the baseli ne emissions from boilers as a whole.

District Rule 4308 Description

Rule 4308 was adopted by the District’s Governing Board on October 20, 2005, and

limits NOx and CO emissions fr om boilers, steam generators, and process heaters. This rule applies to any person who supplies, sells, offers for sale, installs, or solicits the installation of any new small boiler, steam generator, process heater or water heater with a rated heat input capacity greater than or equal to 0.075 Million Btu/hr and up to but not including 2.0 Million Btu/ hr. Facilities with boilers in this size range may include electrical utilities, crude oil production fa cilities, manufacturing facilities, and food processing facilities. Exemptions include units installed in manufactured homes and humidifiers, where the products of combustion come into dire ct contact with the material

to be heated.

District Rule 4308 limits NOx emissions at 3% O 2 to the following:

Between 0.075-0.4 MMBtu/hr 0.093 lb NOx/MMBtu

Between 0.4 and 2.0 MMBtu/hr 0.036 lb NOx/MMBtu

Rule 4308 also includes emissions certif ication protocol, establishes a District certification program, and outlines compliance r eports requirements.

On May 30, 2007 EPA took direct final acti on to approve revisions to the San Joaquin Valley Unified Air Pollution Control District portion of the California State Implementation Plan. These revisions included approval of District Rule 4307. EPA, in evaluating and approving Rule 4308 included the following:

“We believe these rules are consistent with the relevant policy and guidance regarding enforceability, RACT, BACM, and SIP relaxations.” ( CFR Volume 72,

Number 103 )San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-48 How does District Rule 4308 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

District staff’s review of the EPA CTG list i ndicates that there is no CTG for boilers, steam generators, and proc ess heaters – 0.075 MMBtu/hr to 2.0 MMBtu/hr.

B. EPA – Alternative Control Techniques (ACT) Document

NOx Emissions from Industrial/Commercial/ Institutional Boilers - EPA-453/R-94-022

The ACT discusses the different control tec hniques for controlling NOx emissions from boilers with heat input capacities from 0.4 to 1,500 MMBtu/hr. The ACT also presented

the achievable emission levels of severa l control techniques based on the type of boiler and the type of fuel used. The ACT contains cost effectiveness estimates for different control techniques. However, the ACT does not prescribe the spec ific emission limits that should be used in developing a regulatio n to control NOx emissions from boilers.

C. Standards of Performance fo r New Stationary Sources (NSPS)

District staff’s review of 40 CFR 60 (St andards of Performanc e for New Sources)

indicates that there is no NSPS for boile rs, steam generators, and process heaters –

0.075 MMBtu/hr to 2.0 MMBtu/hr.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

40 CFR 63 Subpart DDDDD (NESHAP for Industr ial, Commercial, and Institutional Boilers and Process Heaters)

40 CFR 63 Subpart DDDDD establishes emission limits and work practice standards for boilers and process heaters to regulate hazar dous air pollutants such as arsenic, cadmium, chromium, hydrogen chloride, hydr ogen fluoride, lead, manganese, mercury, and nickel. NESHAP applies to any boiler process or heaters lo cated at a major source. Existing units are units that commenced construction before January 13, 2003; new units are units built on or after January 13, 2003. Emissions from new units are limited to 0.03 lb/MMBtu for PM, and 400 ppm at 3%O2 for CO. In general, the applicability, emission limits, and monitoring requirement s of Rule 4308 are more stringent than those specified for units that are subject to 40 CFR 60 Subpart DDDDD.

How does District Rule 4308 compare to rules in other air districts?

District staff compared NOx lim its, optional control require ments, and work practice standards in District Rule 4308 to comparable requirements in rules from the following

California nonattainment areas:San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-49 • South Coast AQMD Rule 1146.2 (Emissions of Oxides of Nitrogen from Large Water

Heaters and Small Boilers and Proc ess Heaters) amended May 5, 2006

• Bay Area AQMD Regulation 9 Rule 7 (Nit rogen Oxides and Carbon Monoxide from Industrial, Institutional, and Commercial Boilers, Steam Generators, and Process Heaters) adopted November 7, 2007

• Bay Area AQMD Regulation 9 Rule 6 (Nit rogen Oxides Emissions from Natural Gas

Fired Boilers and Water Heat ers) amended July 20, 2008

• Sacramento Metropolitan AQMD Rule 411 (NOx from Boiler s, Process Heaters, and Steam Generators) amended August 23, 2007

• Ventura County APCD Rule 74.11.1 ( Large Water Heaters and Small Boilers) adopted September 14, 1999

A. South Coast AQMD Rule 1146.2 (Emi ssions of Oxides of Nitrogen from Large Water Heaters and Small Boilers and Process Heaters)

SCAQMD Rule 1146.2 applies to natural gas -fired water heaters, boilers, and process heaters. This rule applies to units that have a rated heat input capacity less than or equal to 2,000,000 Btu per hour. Type 1 units have a rated heat input capacity less than or equal to 400,000 Btu/hr . per hour excluding. Type 2 units have a rated heat input capacity greater t han 400,000 Btu/hr, but less than 2,000,000 Btu/hr.

Exemptions include:

• Units used in recreational vehicles.

• Any residential unit

• Units with a rated heat input capacity gr eater than 400,000 Btu per hour, but less than or equal to 2,000,000 Btu per hour t hat are demonstrated to use less than 9,000 therms during every calendar year.

Key requirements of th e Rule 1146.2 include:

• No person shall manufacture for use, or of fer for sale for use, in the District any new Type 2 Unit, unless the NOx emissions level is less than or equal to 30 ppm

of NOx emissions and no more than 400 ppm of carbon monoxide (at 3% O2, dry)

• No person shall manufacture for use, or of fer for sale for use, in the District any new Type 1 Unit, unless the NOx emissions level is less than or equal to 40 nanograms of NOx (calculated as NO2) per joule of heat output or 55 ppm NOx emissions (at 3% O2, dry)

• On or after January 1, 2006, no person shall operate in the District any unit more than 15 years old, based on the original date of manufacture with a rated heat input capacity greater t han 1,000,000 Btu per hour but less than or equal to 2,000,000 Btu per hour and manufactured on or after January 1, 1992, which

does not meet emission limits of 30 ppm NOx and 400 ppm of carbon monoxide (at 3% O2, dry)

• On or after January 1, 2006, no person shall operate in the District any unit more than 15 years old, based on the original date of manufacture as specified inSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-50 paragraph (c)(6), with a rat ed heat input capacity great er than 400,000 Btu per hour but less than or equal to 1,000,000 Btu per hour manufactured prior to January 1, 2000, which does not meet em ission limits of 30 ppm NOx and 400 ppm of carbon monoxide (at 3% O2, dry)

• On or after January 1, 2010, no person shall manufacture for use or offer for sale for use within the District any Type 2 unit unless the unit is certified pursuant to subdivision (d) to a NOx emission level of less than 14 nanograms of NOx (calculated as NO2) per j oule of heat output or less than or equal to 20 ppm of NOx emissions (at 3% O2, dry).

• On or after January 1, 2012, no person shall manufacture for use or offer for sale for use within the District any Type 1 uni t (excluding pool heater s), unless the unit

is certified to a NOx emission level of less than 14 nanograms of NOx (calculated as NO2) per joule of h eat output or less than or equal to 20 ppm of NOx emissions (at 3% O2, dry).

• On or after May 5, 2006, the owner or operator of any Type 2 unit shall perform

maintenance in accordance with the manufacturer's sch edule and specifications

as identified in a manual and other written materials supplied by the

manufacturer or distributor. The owner or operator shall maintain on site a copy

of the manufacturer’s and/or distributor's written instructions and retain a record of the maintenance activity for a per iod of not less than three years.

• The owner or operator shall maintain on site a copy of all documents identifying the unit’s rated heat input capacity. The rated heat input capacity shall be identified by a manufactu rer’s or distributor’s manual or invoice.

SCAQMD Rule 11.46.2 and District Rule 4308 apply to similar source categories, and

have identical emission limits

Differences between the rules include

• District Rule 4308 applies to all gaseous and liquid fuels while SCAQMD Rule 1146.2 applies only to units fueled by natural gas

• District Rule 4308 does not have exemptions for low-use units

• Rule 1146.2 has an emission limit for older in-use units, Rule 4308 does not

Based on the above discussion, District staff deem s that the rules are comparable. The

minor differences that the rules have do not ma ke either rule significantly more stringent

than the other.

B. Bay Area AAQMD Regul ation 9 Rule 7 (Nitrogen Oxides and Carbon Monoxide from Industrial, Instituti onal, and Commercial Boilers, Steam Generators, and Process Heaters)

BAAQMD Regulation 9 Rule 7 applies to indu strial, institutional, and commercial boilers, steam generators, and process heat ers. Exemptions include:

• Boilers, steam generators, and proce ss heaters with a rated heat input of 2 MMBtu/hour or less, if fired exclusively with natural gas , liquefied petroleum gas, or any combination thereofSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-51 • Boilers, steam generators and process heaters with a rated heat input less than 1

million Btu/hour fir ed with any fuel

• Boilers, steam generators, and process heaters that are used in petroleum refineries

• Boilers used by public electr ic utilities or qualifying sma ll power production facilities,

as defined in Section 228.5 of the Public Utilities C ode, to generate electricity;

Establishes emission limits of 40 ppm for NOx and 400 ppm for CO when boilers 1MMBtu/hour or greater are fired with non-gaseous fuel

BAAQMD Regulation 9 Rule 7 only applies to small boilers that are not fired by gaseous

fuels. For this subset of the overall source category, District Rule 4308 has more stringent NOx emission limits and is more stringent overall.

C. Bay Area AQMD Regulation 9 Rule 6 (Nitrogen Oxides Emissions from

Natural Gas Fired Boilers and Water Heaters)

BAAQMD Regulation 9 Rule 6 applies to natur al gas fired water heaters and boilers with a heat input capacity less than or equal to 2,000,000 Btu/hr. Exem ptions include:

• Units used in recreational vehicles

• Units using a fuel other than natural gas

• Pool/spa heaters with less than 400,000 Btu/hr rated heat input capacity

Emissions limits:

• No person shall sell, install, or offer fo r sale within the Distr ict any large natural gas-fired boiler, storage tank water heater , or instantaneous water heater with a rated heat input capacity from 400,001 to 2,000,000 Btu/Hour, inclusive, manufactured after January 1, 2008, that emits more than 20 nanograms of nitrogen oxides (calculated as NO2) per joule of heat output, or more than 30 ppm NOx at 3% O2, dry.

• No person shall sell, install, or offer fo r sale within the Distr ict any large natural gas-fired boiler, storage tank water heater , or instantaneous water heater with a rated heat input capacity from 400,001 to 2,000,000 Btu/Hour, inclusive, manufactured after January 1, 2013, that emits more than 14 nanograms of nitrogen oxides (calculated as NO2) per joule of heat output, or more than 20 ppm NOx at 3% O2, dry.

• Natural Gas-Fired Pool/Spa Heaters: No person shall sell, inst all, or offer for sale within the District any natural gas-f ired pool/spa heater with an input rating from 400,001 to 2,000,000 Btu/Hour, incl usive, manufactured after January 1, 2008, that emits more than 40 nanograms of nitrogen oxides (calculated as NO2) per joule of heat output, or more than 55 ppm NOx at 3% O2, dry.

• No person shall sell, install, or offer for sale within the District any natural gasfired pool/spa heater with an input rating from 400,001 to 2,000,000 Btu/Hour, inclusive, manufactured after Januar y 1, 2013, that emits more than 14 nanograms of nitrogen oxides (calculated as NO2) per joule of heat output, or more than 20 ppm NOx at 3% O2, dry.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-52 BAAQMD Regulation 9 Rule 6 also has com parable administrative requirements to

District Rule 4308.

District Rule 4308 is currently more stringent than BAAQMD Regulation 9 Rule 6. The District rule has comparable emission limits for water heaters and boilers, but has more stringent limits for pool/spa heaters. Howeve r, BAAQMD Regulation 9 Rule contains requirements that lower emission limits star ting in 2013. It should be noted that the District has a commitment to adopt an amended Rule 4308 in the 4 th Quarter 2009

which will have emission limits similar to or more stringent than BAAQMD Regulation 9

limits.

D. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 411 (NOx from Boilers, Process Heaters, and Steam Generators)

SMAQMD Rule 411 applies to units (i.e., boilers, steam generators and process heaters) fired on gaseous or nongaseous fuels wit h a rated heat input capacity equal to or greater than 1 MMBtu/hr.

Exemptions include:

• Any unit that is exclusively used by an electric utility to generate electricity

• Process heaters, kilns, and furnaces wher e the products of combustion come into

direct contact with the material to be heated

• Waste heat recovery boilers

Units 1.0-2.5 MMBtu/hr that use less than 40,000 therms per year are subject to a limited exemption from emission limits.

Applicable Emission Limits:
Boiler Type NOx limit CO limit
Gaseous Fuel Fired 1-5MMBtu/hr 30 ppm 400 ppm Non-Gaseous Fuel Fired 1-5MMBtu/hr 40 ppm 400 ppm Biomass Fuel Firing 70 ppm 400 ppm Emergency Standby Non-Gaseous Fuel Firing 150 ppm N/A

SMAQMD Rule 411 has additional monito ring and administrative requirements, although this are primarily direct ed at larger units that woul d not be subject to District

Rule 4308.

District Rule 4308 is has more stringent NOx emission limits for non-gaseous fired units and units fired by biomass. Rule 4308 also does not have allowances for emergency standby non-gaseous fuel firing. SMAQMD Rule 411 has CO emission limits that are

absent in Rule 4308.

Overall Rule 4308 is more stringent because it applies to a broader range of units. SMAQMD Rule 411 only applies to units with a rated heat input capacity equal to or greater than 1 MMBtu/hr. SMAQMD also has Rule 413 while applies to residentialSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-53 water heaters, but there is not a rule that establishes emission limits for boilers, steam generators and process heaters with a rated heat input c apacity greater than 75,000

btu/hr and less than 1,000,000 btu/hr.

E. Ventura County Air Pollution Control District (VCAPCD) Rule 74.11.1 (Large Water Heaters and Small Boilers)

VCAPCD Rule 74.11.1 applies to any person selli ng, offering for sale, or installing a new water heater, boiler, steam generator or process heater with a rated heat input capacity greater than 75,000 BT U/hr and less than or equal to 2,000,000 Btu/hr in Ventura County.

VCAPCD Rule 74.11.1 includes specific r equirements for small new water heaters, boilers, steam generators or process heaters, including:

o Beginning in 2001, NOx emissions from units with a rated heat input capacity of greater than 75,000 Btu/hr and less than 400,000 Btu/hr s hall not exceed 55 parts per million.

o Beginning in 2000, NOx emissions from units with a rated heat input capacity of greater than 400,000 Btu/hr and less t han 2,000,000 Btu/hr shall not exceed 30 parts per million. CO emissions shall not e xceed 400 parts per million.

o Every subject unit offered for sale in V entura County shall be certified by the Air

Pollution Control Officer.

o The manufacturer shall submit a comp liance report for each applicable new or modified unit by model, including a report on a unit source test.

District staff deems that the rules are comparabl e. They have identical emissions limits,

and similar certification and compliance requirements.

Conclusion

District Rule 4308 meets all federal requi rements and at least as stringent as comparable rules in California. Therefor e District Staff conclude that Rule 4308 satisfies RACT for Boilers, Steam Gener ators, and Process H eaters 0.75 to 2.0

MMBtu/hr.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-54 

### Rule 4309 – Dryers, Dehydrators, and Ovens

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 2.512 2.631 2.794 2.836 2.965 3.082 3.244 3.390 NOx adj 2.51 2.63 1.85 1.88 1.97 2.05 2.14 2.25

VOC 0.389 0.417 0.440 0.446 0.469 0.486 0.512 0.539
(Source: District 2007 Ozone Plan)

District Rule 4309 Description

Rule 4309, recently adopted on December 15, 2005, limits NO X and CO emissions from dryers, dehydrators and ovens . The main rule requirem ent is the lim itation of NO X and CO emissions from dryers, dehydrators, and ovens. These limitation and listed below.

Asphalt/Concrete Plant (ppm @ 19% O 2 ):

Gaseous fuel: NO X : 4.3 ppm; CO: 42 ppm Liquid fuel: NO X : 12.0 ppm; CO: 64 ppm

Milk, Cheese, and Dairy Processi ng < 20 MMBtu/hr (ppm @ 19% O 2 ):

Gaseous fuel: NO X : 3.5 ppm; CO: 42 ppm Liquid fuel: NO X : 3.5 ppm; CO: 42 ppm

Milk, Cheese, and Dairy Processing ≥ 20 MMBtu/hr (ppm @ 19% O 2 ):

Gaseous fuel: NO X : 5.3 ppm; CO: 42 ppm Liquid fuel: NO X : 5.3 ppm; CO: 42 ppm

Other Processes Not Described (ppm @ 19% O 2 ):

Gaseous fuel: NO X : 4.3 ppm; CO: 42 ppm Liquid fuel: NO X : 4.3 ppm; CO: 42 ppm

On May 30, 2007 EPA took direct final acti on to approve revisions to the San Joaquin Valley Unified Air Pollution Control District portion of the California State Implementation Plan. These revisions included approval of District Rule 4309. EPA, in evaluating and approving Rule 4309 included the following:

“We believe these rules are consistent with the relevant policy and guidance regarding enforceability, RACT, BACM, and SIP relaxations.” ( CFR Volume 72,

Number 103 )

Since Rule 4309 was recently approved by EPA as meeting RACT requirements, the District did not pursue a det ailed RACT analysis.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-55 How does District Rule 4309 compare wi th federal rules and regulations?

The District did not conduct a detailed analysis of federal rules and regulations for Rule

4309.

How does District Rule 4309 compare to rules in other air districts?

The District did not conduct a detailed comparison to rules in other air districts for Rule

4309.

Conclusion

District staff concludes that District Rule 4309 satisfies RACT for dryers, dehydrators,

and ovens.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-56 

### Rule 4311 – Flares

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 0.070 0.082 0.083 0.083 0.084 0.091 0.093 0.090

VOC 0.045 0.049 0.050 0.050 0.051 0.053 0.054 0.055
(Source: District 2007 Ozone Plan)

District Rule 4311 Description

District Rule 4311, recently amended on June 15, 2006, controls emissions from any operation involving the use of flares. This source category currently includes flares associated with oil and gas production, com bustion, sewage treatment, incinerators, petroleum refining, and VOC control. Flar ing is a high temperature oxidation process used to burn combustible components, most ly hydrocarbons, of waste gases from industrial operations. 95 per cent of the waste gases flared are natural gas, propane, ethylene, propylene, butadiene and butane.

Rule 4311 requires ground level enclosed flares to meet th e following emissions limits:

Type of Flare and Heat
Release Rate in MMBtu/hr VOC (lb/MMBtu) NOx (lb/MMBtu)

Without Steam-assist

<10 MMBtu 0.0051 0.0952

10-100 MMBtu 0.0027 0.1330

>100 MMBtu 0.0013 0.5240

With Steam-assist

All 0.14 as TOG 0.068

How does District Rule 4311 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

There is no EPA CTG for flares.

B. EPA - Alternative Control Technology (ACT)

There is no EPA ACT for flares.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-57 C. Standards of Performance fo r New Stationary Sources (NSPS)

40 CFR 60.18 (General Control Device Requi rements) and 40 CFR 65.147 (Flares)

40 CFR 60.18 specifies certain minimu m equipment performance standards for equipment used as control devices. In the case of flares, the CFR specifies no visible emission as well a certain equipment stand ards. Since NOx and VOC are invisible gasses, this portion of the CFR does not i dentify RACT for flares. 40 CFR 65.147 is part of the federal consolid ated air rule. It essentially echoes 40 CFR 60.18 and as such does not identify RACT for flares.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

There is no NESHAP or MACT for flares.

How does District Rule 4311 compare to rules in other air districts?

District staff compared emission limits, optional control requirements, and work practice standards in District Rule 4311 to comparabl e requirements in rules from the following

California nonattainment areas:

• South Coast AQMD Rule 1118 (Emissions from Refinery Flares) amended February

1998

• Bay Area AQMD Regulation 12 Rule 11(Flar e Monitoring at Petroleum Refineries) adopted June 4, 2003

• Bay Area AQMD Regulation 12 Rule 12 )F lares at Petroleum Refineries) adopted July 20, 2005

• Sacramento Metro AQMD has no specif ic prohibitory rule for flares

• Ventura County APCD has no specific prohibitory rule for flares.

A. SCAQMD Rule 1118 (Emissions from Refinery Flares)

The emissions data collected as a result of Rule 1118, between 1999 and 2003, was analyzed and resulted in recommendations being made for furt her strengthening emissions monitoring and reporti ng procedures, leading to the adoption of amendments on November 4, 2005. The 2005 amendments prohibit the flarin g of vent gases except in emergency situations, or during specific operational needs such as startups, shutdowns, and turnarounds. Operational require ments were established and practices to minimize flaring events, set specific annual SO 2 performance targets, require flares to operate in a smokeless manner , and require annual inspecti ons of pressure relief devices directly connected to flares. The rule also contains provisions for refineries to give 24-hour advance notice for each large plann ed flaring activity, as well as to notify SCAQMD within 1-hour of unexpe cted flaring events. Also r equired is the submittal of quarterly reports detailing flow, emissions, and cause of each fl aring event. SCAQMDSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-58 also requires refineries to set up a 24-hour public telephone number for inquiries on flaring events.

B. BAAQMD Regulation 12 Rule 11 and Regulation 12 Rule 12

BAAQMD Rule 12-11 requires that operators monitor and record emissions data for flares at petroleum refineries. This rule enabled BAAQMD to collect emissions data from
refineries. With emissions data BAAQMD wa s able to determine causes of specific flaring events, as well as estimate the quantity of emissions released during those events. As a result of findings obtained under Rule 12-11, Rule 12-12 was adopted.

Rule 12-12 reduces emissions from flares by minimizing the frequency and magnitude of flaring. Rule 12-12 also prohibits the us e of refinery flares wit hout the refinery first creating, following, and annually updating an FM P for each flare. Fa cilities are required to submit flaring reports when a flare, at that facility, rel eases more than 500,000 standard cubic feet of gas per calendar day ( scf/day). The flaring report must identify the cause and to avoid flaring from that cause in the future, if possible. The rule also requires continuous monitoring of the flare system’s knock-out drum water seal for leaks, and the submittal of annual reports to BAAQMD that evaluate flaring events that released less than 500,000 scf/day, but SO 2 emitted was more than 500 lbs.

Conclusion

District staff concludes that District Rule 4311 satisfies RACT for flaring operations in terms of emission limits and equipment st andards. However, EPA recommends the District reconsider the utility of incorporating provisions such as those in South Coast Air Quality Management District Rule 1118 and Bay Area Air Quality Management District

Rule 12-12 within Rule 4311 to air their enf orcing of the rule, developing an accurate emissions inventory for theses sources, and minimizing excess em issions from flare activity to the maximum ext ent practicable.” The experienc e of the Bay Area AQMD and South Coast AQMD in incorporating flare mi nimization plans (FMPs) have resulted in data being gathered, which can be used to evaluate the effectiveness of FMPs in reducing flaring events. To th is end, District staff is in t he process of amending this rule to incorporate the use of FMPs. As outlined Table 4-3, it is expected that the rule will go before the District’s Governing Board for ap proval during the second quarter of 2009.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-59 

### Rule 4313 – Lime Kiln

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NO X 0.00 0.00 0.00 0. 00 0.00 0.00 0.00 0.00

VOC 0.00 0.00 0.00 0. 00 0.00 0.00 0.00 0.00
(Source: District 2007 Ozone Plan)

District Rule 4313 Description

This rule applies to lime kilns. T he purpose of this rule is to limit NO X emissions from the operation of lime kilns.

How does District Rule 4313 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

There is no CTG for this source category.

B EPA – Alternative Control Technology (ACT)

There is no ACT for this source category.

C. Standards of Performance fo r New Stationary Sources (NSPS)

40 CFR Part 60 Subpart HH – Standards for Performance for Lime Manufacturing

Plants

The provisions of this subpart are applicab le to each rotary lime kiln used in the manufacturing of lime. However, this subpar t only has requirements for the particulate matter emissions from the rotary lime kiln s. District Rule 4313 only has requirements

for NO X and VOC emissions from lime kilns. Since 40 CFR Part 60 Subpart HH and District Rule 4313 do not have requirements fo r the same pollutant s, they cannot be compared to determine if Distr ict Rule 4313 satisfies RACT. In addition, the RACT analysis is only evaluating VOC and NOx em issions. Since this subpart only has provisions for PM emissions, it will not have any impact in the District’s RACT analysis

conclusion.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-60 D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

Subpart AAAAA—National Emission Standards fo r Hazardous Air Pollutants for Lime Manufacturing Plants

The provisions of this NESHAP are applicab le to each rotary lime kiln used in the manufacturing of lime. However, this NESH AP only has requirements for the particulate matter emissions from the rotary lime kiln s. District Rule 4313 only has requirements

for NO X and VOC emissions from lime kilns. Since 40 CFR Part 63 Subpart AAAAA and District Rule 4313 do not have requirements fo r the same pollutant s, they cannot be compared to determine if Distr ict Rule 4313 satisfies RACT. In addition, the RACT analysis is only evaluating VOC and NOx em issions. Since this subpart only has provisions for PM emissions, it will not hav e any impact in the Districts RACT analysis

conclusion.

How does District Rule 4313 compare to rules in other air districts?

District staff looked at the rule s and regulations for air district s located in other California nonattainment areas. None of the following air districts have a rule that is applicable to lime kilns: South Coast AQMD, Bay Ar ea AQMD, Sacramento Metro AQMD, Ventura County APCD

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, Distric t staff concludes that District Rule 4313

satisfies RACT for lime kilns.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-61 

### Rule 4352 – Solid Fuel Boilers, Steam Generators and Process

Heaters

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 4.0 4.0 4.1 4. 1 4.1 4.1 4.2 4.2

VOC 0.406 0.408 0.409 0. 409 0.409 0.411 0.413 0.413
(Source: District 2007 Ozone Plan)

District Rule 4352 Description

Rule 4352 applies to solid fuel fired boile rs, steam generators, and process heaters. Units subject to Rule 4352 are not s ubject to Rules 4351 , 4305, 4306, 4307, and 4308 because these rules apply to boilers, steam generators, and proce ss heaters fired on gaseous or liquid fuel.

District Rule 4352 requires municipal solid wa ste units to meet a NOx limit of 200 ppmv @ 12% CO2. For all other units the NOx limit is 115 ppmv @ 3% O2.

How does District Rule 4352 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

There is no EPA CTG for boilers, steam generators, and process heaters.

B EPA – Alternative Control Technology (ACT)

EPA –453/R-94-022 “Alternative C ontrol Techniques (ACT) Document – NOx Emissions

from Industrial/Commercial/Instit utional Boilers”, dated March 1994

The ACT discusses the different control tec hniques for controlling NOx emissions from boilers with heat input capacities from 0.4 to 1,500 MMBtu/hr. The ACT also presented

the achievable emission levels of severa l control techniques based on the type of boiler and the type of fuel used. The ACT contains cost effectiveness estimates for different control techniques. However, the ACT does not prescribe the spec ific emission limits that should be used in developing a regulatio n to control NOx emissions from boilers.

C. Standards of Performance fo r New Stationary Sources (NSPS)

1. 40 CFR 60 Subpart D (Standards of Perf ormance for Fossil-Fuel Fired Steam

Generators for Which Construction Commenced After August 17, 1971)

40 CFR 60 Subpart D applies to fossil fuel-fir ed, and fossil fuel and wood residue-fired steam generating units of more than 250 MMB tu/hr that commenced construction orSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-62 modification after August 17, 1971. Subpar t D establishes the emission standards for NOx, SOx, and PM. Since Rule 4352 applies to units that are fired on solid fuel, this analysis focuses only on the NOx standards established in 40 CFR 60 Subpart D for similar type of fuel.

NOx limits:

• Wood residue, or gaseous fossil f uel and wood residue – 0.30 lb/MMBtu

• Solid fossil fuel or solid fossil fuel and wood residue (except lignite or a solid fossil fuel containing 25 percent, by we ight, or more of coal refuse) – 0.70

lb/MMBtu

• Lignite or lignite and w ood residue – 0.60 lb/MMBtu

• Lignite which is mined in North Dakota , South Dakota, or Montana and which is burned in a cyclone-fired unit – 0.80 lb/MMBtu

In general, the applicability, emission limits, and monitoring requirements of Rule 4352 are more stringent than those specified for uni ts that are subject to 40 CFR 60 Subpart

D. The relevant standards used for com paring the draft rule with 40 CFR 60 Subpart D are shown in the Rule Consistency Table.

2. 40 CFR 60 Subpart Db (Standards of Performance for Industrial-CommercialInstitutional Steam Generating Units)

40 CFR 60 Subpart Db applies to steam generat ing units with a heat input capacity of greater than 100 MMBtu/hr that commence constr uction, modification, or reconstruction after June 19, 1984. Steam gener ating units, as defined in 40 CFR 60 Subpart Db, do not include process heaters. Ru le 4352 applies to solid fuel fi red units so this analysis focuses only on the NOx standards establis hed in 40 CFR 60 Subpart Db for similar type of fuel.

NOx limits:

• Mass-feed stoker – 0.50 lb/MMBtu.

• Spreader stoker and fluidized bed combustion – 0.60 lb/MMBtu.

• Pulverized coal – 0.70 lb/MMBtu

• Lignite – 0.60 lb/MMBtu

• Lignite mined in ND, SD, MT, and com busted in a slag tap furnace – 0.80

lb/MMBtu.

• Coal-derived synthetic fuels – 0.50 lb/MMBtu

In general, the applicability, emission limit s, and monitoring requirements of Rule 4352 are more stringent than those specified for uni ts that are subject to 40 CFR 60 Subpart

Db.

3. 40 CFR 60 Subpart Cb (Emissions Guide lines and Compliance Times for Large Municipal Waste Combustors That are C onstructed on or Before September 20, 1994)San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-63 40 CFR 60 Subpart Cb applies to each m unicipal waste combustor unit with a combustion capacity greater than 250 tons per day of muni cipal solid waste for which

construction was commenced on or before September 20, 1994. Rule 4352 applies to solid fuel fired units so this analysis focu ses only on the NOx standards established in 40 CFR 60 Subpart Cb for si milar type of fuel.

NOx limits:

• Mass burn waterwall – 205 ppm at 7% O2

• Mass burn rotary waterw all – 250 ppm at 7% O2

• Refuse-derived fuel com bustor – 250 ppm at 7% O2

• Fluidized bed combustor – 240 ppm at 7% O2

• Mass burn refractory combustors - no limit

• Fluidized bed combustor – 180 ppm at 7% O2

4. 40 CFR 63 Subpart DDDDD (NESHAP fo r Industrial, Commercial, and

Institutional Boilers and Process Heaters)

40 CFR 63 Subpart DDDDD establishes emission limits and work practice standards for boilers and process heaters to regulate hazar dous air pollutants such as arsenic, cadmium, chromium, hydrogen chloride, hydr ogen fluoride, lead, manganese, mercury, and nickel. NESHAP applies to any boiler process or heaters lo cated at a major source. Existing units are units that commenced construction before January 13, 2003; new units are units built on or after January 13, 2003.

5. EPA Policy on Start-up or Shutdown

Section 5.3 of Rule 4352 establishes certai n operational standards that must be met during start-up or shutdown of boilers, steam generators, a nd process heaters. District

staff believes that t he proposed start-up or shutdown prov isions are consistent with the EPA policy as discussed in an EPA memor andum, dated February 15, 1983, “Policy on Excess Emissions During Start-up, Shutdow n, Maintenance and Malfunctions” which prohibits automatic exemption during periods of start-up or shutdown of a unit.

6. EPA Policy on Recordkeeping

The recordkeeping requirement in Section 6.2 of Rule 4352 is consistent with EPA’s policy to keep and maintain record s for at least five years.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

There is no NESHAP or MACT for this category.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-64 How does District Rule 4352 compare to rules in other air districts?

District staff compared NOx lim its, exemptions, and control r equirements in District Rule 4352 to comparable requirements in rules from the following California nonattainment

areas:

• South Coast Air Quality Management District

• Bay Area Air Quality Management District

• Sacramento Metro Air Q uality Management District

• Ventura County Air Poll ution Control District

1. South Coast Air Quality Management District Rule (SCAQMD) 1146 (Emissions of oxides of Nitrogen from Industrial, Institutional, and Commercial Boilers, Steam Generators, and Process Heater s) last amended September 5, 2008

SCAQMD Rule 1146 applies to boilers, st eam generators, and proc ess heaters of equal to or greater than 5 million Bt u per hour rated heat input capacity used in all industrial, institutional, and commercial op erations with the exception of:

• boilers used by electric utilities to generate electricity; and

• boilers and process heaters with a rat ed heat input capacity greater than 40 million Btu per hour that are us ed in petroleum refineries; and

• sulfur plant reaction boilers.

SCAQMD Rule 1146 establishe s a 40ppm NOx emissi on limit for all units fired on nongaseous fuel.

Comparison of SCAQMD Rule 1146 and District Rule 4352

SCAQMD Rule 1146 applies to all large bo ilers, steam generator s and process heaters, regardless of fuel type. NO x emission limits in SCAQMD Rule 1146 are more stringent

than emission limits for solid fuel fired units in District Rule 4352.

Overall SCAQMD Rule 1146 is more stringent than District Rule 4352 when it is applied

to solid fuel fired units. The District belie ves that that a 40ppm NO x emission limit is technologically infeasible for solid fuel fired units, and is not aware of any solid fuel fired boiler, steam generator or process heater that has operated at this level.

2. South Coast Air Quality Management Dis trict (SCAQMD)Rule 1146.1 (Emissions of oxides of Nitrogen from Small Industria l, Institutional, and Commercial Boilers, Steam Generators, and Process Heater s) last amended September 5, 2008

SCAQMD Rule 1146 applies to boilers, steam generators, and proce ss heaters that are greater than 2 million BTU per hour and less than 5 million Bt u per hour rated heat input capacity used in any industrial, inst itutional, or commercial operation.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-65 SCAQMD Rule 1146.1 establishes a 30ppm NO x emission limit for all units fired on non-gaseous fuel.

Comparison of SCAQMD Rule 1146.1 and District Rule 4352

SCAQMD Rule 1146.1 applies to all sma ll boilers, steam generators and process heaters, regardless of fuel type. NOx emission limits in SCAQMD Rule 1146.1 are more stringent than emission limits for solid fuel fired units in District Rule 4352.

Overall SCAQMD Rule 1146.1 is more stri ngent than District Rule 4352 when it is applied to solid fuel fired units. The Distr ict believes that that a 30ppm NOx emission limit is technologically infeasible for solid fuel fired units, and is not aware of any solid fuel fired boiler, steam generat or or process heater that has operated at this level.

3. Bay Area Air Quality Management District (BAAQMD) Regulation 9 Rule 7 (Nitrogen Oxides and Carbon Monoxide fr om Industrial, Institutional, and Commercial Boilers, St eam Generators, and Proc ess Heaters) adopted November 7, 2007

BAAQMD Regulation 9 Rule 7 applies to indu strial, institutional, and commercial boilers, steam generators, and process heat ers. Exemptions include:

• Boilers, steam generators, and proce ss heaters with a rated heat input of 2 MMBtu/hour or less, if fired exclusively with natural gas , liquefied petroleum gas, or any combination thereof

• Boilers, steam generators and process heaters with a rated heat input less than 1

million BTU/hour fir ed with any fuel

• Boilers, steam generators, and process heaters that are used in petroleum refineries

• Boilers used by public electr ic utilities or qualifying sma ll power production facilities,

as defined in Section 228.5 of the Public Utilities C ode, to generate electricity;

BAAQMD Regulation 9 Rule 7 establishes emission limits of 40ppm for NOx and 400ppm for CO when boilers 1MMBtu/hour or greater are fired with non-gaseous fuel.

Comparison of BAAQMD Regulation 9 Rule 7 and District Rule 4352

BAAQMD Regulation 9 Rule 7 applies to all small boilers, steam generators and process heaters, regardless of fuel type. NOx emission lim its in BAAQMD Regulation 9 Rule 7 are more stringent than emission limits fo r solid fuel fired units in District Rule

4352.

Overall BAAQMD Regulation 9 Rule 7 is more stringent than District Rule 4352 when it is applied to solid fuel fired units. The Dis trict believes that that a 40ppm NOx emission limit is technologically infeasible for solid fuel fired units, and is not aware of any solid fuel fired boiler, steam generat or or process heater that has operated at this level.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-66 4. Sacramento Metropolitan Air Quality Manage ment District (SMAQMD) Rule 411 (NOx from Boilers, Process Heater s, and Steam Generat ors) last amended August 23, 2007

SMAQMD Rule 411 applies to units (i.e., boilers, steam generators and process heaters) fired on gaseous or nongaseous fuels wit h a rated heat input capacity equal to or greater than 1 MMBtu/hr. Exemptions include:

• Any unit that is exclusively used by an electric utility to generate electricity

• Process heaters, kilns, and furnaces wher e the products of combustion come into

direct contact with the material to be heated

• Waste heat recovery boilers

Units 1.0-2.5 MMBtu/hr that use less than 40,000 therms per year are subject to a limited exemption from emission limits.

Applicable Emission Limits:
Boiler Type NOx limit CO limit
Gaseous Fuel Fired 1-5MMBtu/hr 30ppm 400ppm Non-Gaseous Fuel Fired 1-5MMBtu/hr 40ppm 400ppm Biomass Fuel Firing 70ppm 400ppm Emergency Standby Non-Gaseous Fuel Firing 150ppm N/A

Comparison of SMAQMD Rule 411 and District Rule 4352

SMAQMD Rule 411 applies to units fired on gaseous or non-gaseous fired fuels. NOx emission limits for non-gaseous fuel fired units in SMAQMD Rule 411 are more stringent than emission limit s for solid fuel fired units in District Rule 4352.

Overall SMAQMD Rule 411 is more stringent than District Rule 4352 when it is applied

to solid fuel fired units. The District belie ves that that a 40ppm NO x emission limit is technologically infeasible for solid fuel fired units, and is not aware of any solid fuel fired boiler, steam generator or process heater that has operated at this level.

5. Ventura County Air Poll ution Control District (VCA PCD) Rule 74.15 (Boilers, Steam Generators, and Process Heater s) last amended November 8, 1994

VCAPCD Rule 74.15 applies to boilers, steam generators and process heaters used in all industrial, institutional and commercial operations with a rated heat input capacity of equal to or greater than, 5 million BT Us per hour. Exemptions include:

• Utility electric power generating units

• Auxiliary boilers used with a ut ility electric power generating unit

• Water heaters

VCAPCD Rule 74.15 establishe s a 40ppm NOx emissi on limit for units subject to the

rule.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-67 Comparison of VCAPCD Rule 74.11.1 and District Rule 4352

VCAPCD Rule 74.15 applies to a ll large boilers, steam generators and process heaters, regardless of fuel type. NOx emission limit s in SMAQMD Rule 411 are more stringent

than emission limits for solid fuel fired units in District Rule 4352.

Overall VCAPCD Rule 74.15 is more stringent than District Rule 4352 when it is applied

to solid fuel fired units. The District belie ves that that a 40ppm NO x emission limit is technologically infeasible for solid fuel fired units, and is not aware of any solid fuel fired boiler, steam generator or process heater that has operated at this level.

6. Ventura County Air Pollut ion Control District (VCAPCD) Rule 74.15.1 (Boilers, Steam Generators, and Process Heat ers) last amended June 13, 2000

VCAPCD Rule 74.15.1 applies to boilers, steam generators and pr ocess heaters with a rated heat input capacity equal to or greater than 1 million BTU per hour and less than 5 million BTU per hour.

VCAPCD Rule 74.15.1 establishes a 30ppm NOx emission limit for units subject to the

rule.

Comparison of VCAPCD Rule 74.15.1 and District Rule 4352

VCAPCD Rule 74.15.1 applies to all sma ll boilers, steam generators and process heaters, regardless of fuel ty pe. NOx emission lim its in SMAQMD Rule 411 are more stringent than emission limit s for solid fuel fired units in District Rule 4352.

Overall VCAPCD Rule 74.15.1is more stri ngent than District Rule 4352 when it is applied to solid fuel fired units. The Distr ict believes that that a 30ppm NOx emission limit is technologically infeasible for solid fuel fired units, and is not aware of any solid fuel fired boiler, steam generat or or process heater that has operated at this level.

Conclusion

The District maintains that the ARB RACT/B ARCT guidelines for non-gaseous fired units were not meant to apply to solid fuel fired boilers based on the description of control technology options. The District applie s the 40ppm emission limit to liquid fired

units.

Permitted units subject to Rule 4352 are all equipped with non-catalytic selective reduction systems which the Dis trict considers to be BARCT for this application.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-68 Further, the District does not believe that a 40ppm NOx emission limit is technologically infeasible for solid fuel fired units, and is not aware of any solid fu el fired boiler, steam generator or process heater that has operated at this level.

After careful evaluation of federal rules or regulations covering emissions from this source category as well as prohibitory rule s in other California nonattainment areas,

District staff concludes that District Rule 4352 satisfies RACT for solid fuel boilers, steam generators, an d process heaters.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-69 

### Rule 4354 – Glass Melting Furnaces

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 9.38 8.02 8.56 8.73 9.08 9.64 10.12 10.65

VOC 0.337 0.39 0.415 0.423 0.440 0.469 0.49 0.515
(Source: District 2007 Ozone Plan)

District Rule 4354 Description

This rule controls NOx, SOx, VOC, and CO emissions from any glass-melting furnace located at facilities that have the total potentia l to emit of at least ten tons per year of NOx or at least ten tons per year of VOC. The emission limits depend on type of glass produced, furnace firing technology and emi ssion averaging period. NOx emission limits range from 4.0 to 9.2 pounds NOx per ton of glass pulled (lb/ton glass); CO limits are 300 ppmv or 0.9 to 1.0 lbs/ton glass; and VOC emission limits are 20 ppmv or range from 0.1 to 0.25 lbs/ton glass.

Operators of multiple fur naces have the option to average emissions across the furnaces in order to comply with the emission limits. Operators w ho select this option are required to meet emission limits that ar e 10% lower than if they had controlled each furnace individually.

Operators meet current emissi on limits through a selection of furnace firing technology and glass raw materials. There are a range of NOx control strategies to achieve the current emission limits. These strategies go beyond low-NOx or ul tra-low-NOx burners

and electric boost to advanced controls like oxygen-enriched air staging (OEAS), replacement of combustion air with pure o xygen (oxy-fuel firing), and fuel re-burn technology (the proprietary 3-R pr ocess). One source is in the process of converting to selective catalytic reduction (SCR) for NOx c ontrol. This SCR system will be the first in the US on a glass furnace.

How does District Rule 4354 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

There is no CTG for this source category.

B. EPA – Alternative Control Technology (ACT)

EPA-453/R-94-037 Alternative Contro l Techniques Document – NO
x Emissions from Glass ManufacturingSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-70 This document outlines the available control techniques for three types of glass melting furnaces – container glass, flat glass and pressed-and-blown glass. The document lists no specific NOx emission limit, although it does suggest estimated percent NOx

reduction from uncontrolled levels. In not ha ving a specific NOx limit for any of the subject furnaces, the document does not defi ne RACT for the three types of glass.

There is no ACT for glass melting furnaces at either wool fiberglas s or strand fiberglass manufacturing facilities.

C. Standards of Performance fo r New Stationary Sources (NSPS )

40 CFR 60 Subpart CC – Standards of Perform ance for Glass Manufacturing Plants; and 40 CFR Subpart PPP – Standards of Performance for Wool Fiberglass

Insulation Plants

These NSPSs target the control of parti culate matter from the specified glass manufacturing processes. As such, neither NSPS defines applicable RACT for these sources. There is no NSPS for fiberglass strand furnaces.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

There is one NESHAP that could apply to gl ass melting furnaces – 40 CFR 61 Subpart N (National Emission Standard for Inor ganic Arsenic Emissions from Glass Manufacturing Plants). An arsenic-contai ning compound could be used in the glass recipe to improve glass quality, although no glass manufacturer subject to the District rule uses the arsenic compound in their opera tions. The NESHAP specifically targets inorganic arsenic emissions, and therefore, does not appl y to NOx or VOC emission

limits. The NESHAP does not define applicable RACT for this source category.

There are two MACT standards that apply to glass melting furnaces – 40 CFR 63 Subpart NNN (National Emission Standards fo r Hazardous Air Pollutants for Wool Fiberglass Manufacturing Plants) and 40 CF R 63 Subpart SSSSSS (National Emission

Standards for Hazardous Air Pollutants for Glass Manufacturing Area Sources). The portions of both MACTs that appl y to the glass melting furnac es are particulate emission limits and subsequent recordkeeping. As su ch, they do not regulate NOx or VOC for this source category; therefore the MACT standard does not define applicable RACT for this source category.

How does District Rule 4354 compare to rules in other air districts?

District staff compared NOx lim its, optional control require ments, and work practice standards in District Rule 4354 to comparable requirements in rules from the following

California nonattainment areas:San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-71 • South Coast AQMD Rule 1117, as amended January 1984

• Bay Area AQMD Regulation 9 Rule 12, as adopted January 1994

• Ventura County APCD and Sacramento Me tro AQMD do not have a specific prohibitory rule for this source category.

A. South Coast AQMD Rule 1117 (Emissions of Oxides of Nitr ogen from Glass Melting Furnaces)

South Coast AQMD Rule 1117 has a single NOx limit of 4.0 pounds per ton glass pulled, however the limit does not apply to tableware glass, flat glass, or fiberglass furnaces – these are specifica lly exempt under Rule 1117. This means that Rule 1117 applies only to container glass furnaces. Al ternative emission control plans are allowed which let emissions to be averaged over mo re than one furnace as long as the total emissions are no greater than if each furnace was individually meeting the emission

limit. Recent amendments to District Rule 4354 have reduced NOx limits for container glass which are lower than South Coast Rule 1117. The District rule also goes beyond
the South Coast AQMD rule to limit NOx emissions from flat glass and fiberglass furnaces. Additionally, the alternative emission control plan in District Rule 4354 requires a 10% reduction in total emissions for the averaged group of furnaces over controlling the furnaces individually.

B. Bay Area AQMD Regulati on 9 Rule 12 (Nitrogen Oxide Emissions from Glass Melting Furnaces)

Bay Area AQMD Regulation 9 Rule 12 has a single NOx emission limit of 5.5 pounds NOx per ton glass pulled, which is lower than current District Rule 4354 NOx emission limits for flat glass. However, there are no flat glass furnaces within Bay Area AQMD, meaning the emission limit has not been achieved in practice in the Bay Area AQMD for flat glass furnaces. On April 3, 2009, Mr. Weyman Lee of BAAQMD has verified that there are no flat glass furnaces within t he BAAQMD. With the most recent amendments to District Rule 4354, the NOx emission limit for every category of glass is more stringent than the NOx limit in Bay Area AQMD Regulation 9 Rule 12.

Are additional cost-effective controls available?

As noted above, the current furnaces are already utilizing advanced control technologies for NOx. Tabl e 2 below details the NOx co ntrol technologies being used within the District. All 14 glass melting furn aces in the District are using lo w-NOx or ultralow NOx burners in conjunction with th e advanced NOx controls. The estimated emission reductions are taken from EPA’s ACT fro glass furnaces. Cost effectiveness

was taken from the recent rule amendment project where only SCR and oxy-fuel firing

were considered sufficient to meet the new NO x limits. While SCR is new to US glass furnaces, it has been in use in Europe for several years.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-72 Table 2 – NOx Control Strategies, Cost E ffectiveness, and Actual Technology Utilization

NOx Control Technology Estimated Emission

Reduction over

Uncontrolled

Furnaces Estimated Cost

Effectiveness ($/ton reduced) Number District Furnaces Currently Using This Technology

Low-NOx or Ultra-low

NOx burners 30% to 40% --- 14

Electric Boost 10% to 30% --- Unable to tell from individual permits Oxygen Enriched Air Staging (OEAS) 30% to 75% --- 3

Oxygen Fuel (oxyfuel) Firing 75% to 85% $51,700 6

Fuel Re-burn (3-R) 50% to 65% --- 1 Selective Catalytic Reduction (SCR) 75% to 90% $2,180 – $10,800 1

Were relevant public comments received recently about Rule 4354?

Relevant public comments received during t he public process for adopting the District’s 2008 Ozone Plan have been addressed in Appendix L of the plan.

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, Distric t staff concludes that District Rule 4354 satisfies RACT for glass melting furnaces.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-73 

### Rule 4401 – Steam Enhanced Crude Oil Production Well Vents

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

VOC 13.5 13.2 12.6 12.5 11.7 11.3 11.0 12.1
(Source: District 2007 Ozone Plan)

District Rule 4401 Description

This rule controls VOC emissions from steam-enhanced crude oil pr oduction well vents. The primary source of VOC emissions from the wells is the casing vent. The emissions from a casing vent are usually controlled th rough the operation of a VOC collection and

control device.

This rule prohibits the operation of a st eam-enhanced crude oil production well, except cyclic wells meeting certain requirements, unless the uncontrolled VOC emissions from any well vent are reduced by at least 99 percent by weight, or, if several steamenhanced crude oil production well vents ar e connected to a vapor collection and control system, this rule requires that to tal uncontrolled VOC emissions be reduced by at least 99 percent.

Fugitive VOC emissions can also occur fr om oil and gas flowing through the various components (such as valves and flanges) that ar e part of the piping from the wells to the emission control system. Rule 4401 contai ns a schedule that specifies the number of allowable component l eaks based on the number of we lls connected to a vapor collection and control system. Rule 4401 requir es an operator, upon detection of a leak, to affix a readily visible tag bearing the dat e on which the leak is detected. Rule 4401 further requires an operator to repair a leak within fifteen ( 15) calendar days; failure to repair the leak would constitute a violation of the rule.

How does District Rule 4401 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

There is no CTG for this source category.

B. EPA – Alternative Control Technology (ACT)

There is no ACT for this source category.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-74 C. Standards of Performance fo r New Stationary Sources (NSPS)

There is no NSPS for this source category.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

There is no NESHAP or MACT for this source category.

How does District Rule 4401 compare to rules in other air districts?

District staff compared control requirements, and work practice standards in District Rule 4401 to comparable requirements in rules from the following California

nonattainment areas:

• South Coast AQMD Rule 1148, as amended November 5, 1982

• Bay Area AQMD, Sacramento Metropolit an AQMD, and Ventura County APCD do not have a prohibitory rule that cove rs the same emission source category

South Coast AQMD Rule 1148

South Coast AQMD Rule 1148 (Thermally Enhanced Oil Recovery Wells) requires that

ROG emissions from a steam dr ive well not to exceed 4.5 lb /day or if steamed drive wells are connected to vapor control system ROG emissions from the control system shall average no more than 4.5 lb/day/connected well.

Using CARB emissions factor for uncontrolle d steam drive well of 220 lb-VOC/day, Rule 4401’s 99% control requirement equates to 2.2 lb /day/well, which is more stringent than 4.5 lb/day/well (heavy oil production result s in no methane or ethane, meaning 100% of ROGs are considered VOCs).

South Coast AQMD Rule 1148 does not spec ify any fugitive VOC leak detection and repair provisions where as Rule 4401 spec ifies the number of allowable component

leaks based on the number of wells connected to a vapor collection and control system. Rule 4401 requires an operator, upon detection of a leak, to affix a readily visible tag bearing the date on which the leak is detect ed. Rule 4401 further requires an operator to repair a leak within fifteen (15) calendar days; failure to repair the leak would

constitute a violation of the rule.

South Coast AQMD Rule 1148 contains a six month exemption for steam drive wells if steam is injected more frequently than 45 days and amount of steam injection expressed as water is more than 2,000 barre ls. Rule 4401 provides exemptions for up to 40 cyclic wells owned by a company that are undergoing pilot testing and well stimulation. Rule 4401 also exempts for up to 5 cyclic wells (20 cyclic wells for small producer) if wells are located more than 1000 f eet from an existing well control systemSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-75 operated by the company and operation is under District permit. South Coast AQMD

Rule 1148 does not limit number of wells t hat can be exempt and Rule 4401 does not limit duration of exempt ion, therefore exemptions in t he both rules can not be compared directly.

Both South Coast AQMD Rule 1148 and Ru le 4401 require annual testing of vapor control systems. However District Rule waiv es this testing requirement if uncondensed vapors are incinerated in f uel burning equipment, internal combustion engine or in a

smokeless flare.

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, Distric t staff concludes that District Rule 4401 satisfies RACT for steam-enhanced crude oil production well vents.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-76 

### Rule 4402 – Crude Oil Production Sumps

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

VOC 0.42 0.41 0.40 0.39 0.37 0.36 0.35 0.39
(Source: District 2007 Ozone Plan)

On April 1, 2009, the United State Environmental Protec tion Agency (EPA) Region IX sent a comment recommending the RACT analys is clarify how the 3 to 60 tons/day emissions inventory cited in the District’s 2007 Ozone Plan was in error. The District consultant’s emissions inventory methodolog y which estimated 60 tons/day VOC from sumps was based on Department of Oil, Gas, and Geothermal Energy (DOGGR) database of sumps compiled in early 1990s including surface area of sumps and characteristic of fluids, data on sump clos ures from Central Valley Regional Water Quality Control Board (RWQCB) and District survey in 1997. It is important to note that DOGGR and RWQCB data on number of sumps and surface areas are not as accurate as the recent data submitted by oil producers in the San Joaquin valley (Valley) to the District during the emissions inventory surv ey in late 2007. The 60 tons/day VOC estimated by the consultant in Nove mber 2003 was based on an estimated total 660 sumps with a total surface area of 9,590,945 square feet 1 . In contrast, the 2007 District sump emissions inventory 2 of oil producers in the Valle y showed that there are only a total of 95 sumps with a total surface ar ea of 308,763 square feet. Furthermore, the

consultant used the California Air Resources Board’s default emissi on factors for sumps while the recent District inventory used t he emission factors developed by the District based on data from source testing of sump s in Kern County. The updated emission factors were published in the District’s co rrected “Technical Guidance for Emissions Inventory Criteria and Guidel ines Regulation for AB 2588 (A ir Toxics “Hot Spots” Information and Assessment Act of 1987). The 2007 District em issions inventory estimated VOC emission from sumps is about 2.6 tons/day. The District expects to

finalize the area source emissions invent ory methodology report by end of April 2009 and thereafter submit an updated sumps inventory to the California Air Resources

Board.

District Rule 4402 Description

District Rule 4402 controls VOC emissions fr om crude oil producti on sumps located at facilities that produce heavy crude oil. Rule 4402 requires sumps to have a flexible floating cover, rigid floating cove r, or fixed roof cover. The flexible floating cover has to be equipped between the sump wall and the cover edge, and the gap between the wall

1 “Emission Inventory Methodology- Oil and Gas Sump s (Methods Document STI-903340-242f-MD)”, Sonoma Technology, Inc., November 7, 2003.

2 Draft 2007 Area Source Emissions Inventory Methodology , 310 – Oil Production Sumps and Well Cellars posted in www.valleyair.org/busind/draft-policies/sumpscellars 2007.pdf.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-77 and at every point around the per imeter must not exceed 1 inch. The fixed-roof cover must have a PV and meet certain specific r equirements. If sumps are replaced with above-ground fixed roof tanks, the tanks must comply with t he provisions of Rule 4623.

How does District Rule 4402 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

District staff’s review of the EPA CTG list i ndicates that there is no CTG for crude oil production sumps.

B. EPA – Alternative Control Techniques (ACT) Document

District staff’s review of the EPA ACT list in dicates that there is no ACT for crude oil production sumps.

C. Standards of Performance fo r New Stationary Sources (NSPS)

District staff’s review of 40 CFR 60 (St andards of Performanc e for New Sources)

indicates that there is no NSPS for crude oil production sumps.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

District staff’s review of 40 CFR 61 (NESHAP) and 40 CFR (NESHAP for Source Categories) indicates that there is no NESHAP or MACT for crude oil production sumps.

How does District Rule 4402 compare to rules in other air districts?

District staff compared District Rule 4402 with the rules of ot her California ozone nonattainment air districts’ rules (South Coast Air Quality Management District, Bay Area Air Quality Management District, Sacramento Metropolitan Air Quality Management Air District, and Ventura County Ai r Pollution Control District on crude oil production sumps. The results of the analysis are discussed below.

The control requirements of Rule 4402 are e ssentially the same as Ventura County Air Pollution Control District (VCAPCD) Rule 71.4. South Coast AQMD, Bay Area AQMD, Sacramento AQMD do not have any rule on crude oil production sumps.

Although VCAPCD Rule 71.4 pr ohibits the use of first stage sumps, District staff

believes that other VCAPCD ei ther do not have first stage sumps or such sumps have been replaced with tanks. Although use of first stage sumps is allowed by District Rule 4402, it does not necessarily m ean that the rule is less stri ngent than other air districts’ rules, for the following reason. If first stage sumps are r eplaced with tanks, the tanksSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-78 would be subject to another rule that cont rol emissions from the storage of organic liquids. District Rule 4623 (Storage of Organi c Liquids) applies to tanks that have a capacity of at least 1,100 gallons that stor e organic liquids with a true vapor pressure (TVP) of 0.5 psia or greater. The tank VO C control requirements are based on the tank size and true vapor pressure (TVP) of the stored organic liquid. Organic liquids with a TVP less than 0.5 psia would not be subject to the VOC control r equirements of Rule 4623. Replacing first stage sump with a tank could result in an unintended consequence that the tank would either be totally uncontrolled or less effectively controlled compared to Rule 4402 because t he TVP might be lower than the control trigger level specified in Rule 4623.

Based on the District’s Permit database, sta ff has determined that t here are only very few permitted small-size first-stage sumps for processing heavy crude oil that were issued to very small producers (less than 150 barrels of oil/day production) and they are not major sources (less than 10 t ons per year of VOC or NOx) 3 . The source testing required by Rule 4623, shows the TVP of the heavy crude oil is less than 0.5 psia. As discussed above, prohibiting the use of fi rst stage sumps would essentially force operators to replace the sumps with tanks, which could result in the tanks being exempt

from Rule 4623 because the TVP is less than 0.5 psia. Although Rule 4402 allows the use of first stage sumps, the controls are equal to or be tter than that which would be required for such materials stored in tanks. Fu rthermore, it is important to mention that the District’s 2007 survey of crude oil sumps 4 revealed that there are no active first stage sumps operating in the San Joaquin Valley. Therefore, st aff believes that existing control requirements of the rule sa tisfy RACT for this operation.

District staff reviewed other air districts’ ru les for this source category and found that, except for SBCAPCD Rule 344, other air districts rules t hat control VOC emissions from sumps have no exemption for small producer sumps; no minimal emissions exemption; and have a lower limit (based on a lower VO C content) for the clean produced water exemption. SBCAPCD Rule 344 exempts sump s of oil producer producing 150 barrels of oil/day regardless of the type of oil (light or heavy crude oil).

Rule 4402 exempts small producers’ se cond and third stage sumps less than 1,000 square feet surface area used exclusively fo r heavy crude oil. Another exemption is provided for very small producer second and third stage sumps less than 5,000 square feet used exclusively for heavy crude oil. Sm all producer is defined in the rule as a producer whose oil production does not ex ceed 6,000 barrels/day. Very small oil producer is defined in Rule 4402 as a pr oducer whose oil production does not exceed 150 barrels/day, similar to SBCAPCD Rule 344.

3 Smilodon Oil Company (Facility ID S-2771); Woodward Oi l Company (Facility ID S-780); Arthur McAdams (Facility ID S-2288); Gotland Oil (Facility ID S-2803 and S-2804). T he total controlled VOC emissions from these five heavy oil first stage sumps are estimated at 0.04 tons per day. Recent District’s survey indicated no first stage sumps operating in the District.

4 Draft 2007 Area Source Emissions Inventory Methodology , 310 – Oil Production Sumps and Well Cellars posted in http://www.valleyair.org/busind/draft-policies/sumpscellars2007.pdf

.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-79 Rule 4402 exemption for small/very sm all producers’ second stage and third stage sumps are exclusively for heavy crude oil and only for small size sumps. As discussed above, the TVP of heavy crude oil is less than 0.5 psia. Low-TVP heavy crude oil emits less VOC than higher TVP light crude oil. The VOC emissions from small size second and third stage sumps are relatively low. Requi ring small/very small producers to install and operate a fixed or floating cover would no t be economically feasible because they have much less revenue than large oil producers. The estimated cost effectiveness of a rigid floating cover for a 5,000 square feet second stage sump containing heavy crude oil is about $64,800 per ton of VOC reduced 5 . The cost effectiveness value for heavy crude oil third stage sump cover would be much higher than for a second stage sump. Due to economic infeasibility, District staf f believes the exemption is still appropriate.

The exemptions for minimal VOC emissi ons (0.007 lb/sq.ft/day) and clean produced water (35 milligrams/liter) are also considered to still be appropr iate. It is important to note that the emissions from clean produced water are significantly less than heavy crude. The cost of controlling VOC emissions from clean produced water sumps would be significantly higher than heavy crude oil su mps. Due to economic infeasibility, District staff believes the exemptions in Rule 4402 are appropriate. Based on the discussion above, District staff deems Rule 4402 to satisfy RACT for this category.

Conclusion

District staff concludes that District Rule 4402 satisfies RACT for Crude Oil Production Sumps.

5 SBCAPCD Staff Report for Rule 344 (Sumps, Pits, and Well Cell ars). Rigid floating cover annualized cost for 5,000 sq.ft. sump is $78,111 (1986 dollars). A ssuming 3% per year consumer price index (inflation rate) for 22 years, the 1986 dollars would be adjusted by an additional 66% to 2008 dollars. The 2008 adjusted annualized cost is $129,664 [($78,111) + (78,1 11 x 0.66)]. Assuming a VOC emission reduc tion from heavy crude second stage sump is about 2 tons per year, the cost effectiveness would be $64,832.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-80 

### Rule 4404 – Heavy Oil Test Station - Kern County

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

VOC 0.0 0.0 0.0 0. 0 0.0 0.0 0.0 0.0
(Source: District 2007 Ozone Plan)

District Rule 4404 Description

District Rule 4404 controls VOC emissions fr om operation of heavy oil test stations (HOTS). HOTS is a tank setting comprised of both a family tank and one or more test tanks. A family tank directly receives crude oil production from more than one steam drive well through individual production lines wh ich discharge into the tank. A test tank tests the production rate from a single steam drive well.

Rule 4404 prohibits operati on of HOTS unless the VOC em issions are reduced by at least 99%. Except during sampling, gauging, and PV valve vent, any tank roof opening must be equipped with a cover, seal, or lid with no visible gap and maintained in a gastight condition.

Requirements of this rule ar e applicable to heavy oil test stations (HOTS) that are atmospheric tanks. A review of the Distr ict’s permit database and observations of Compliance Division staff indica te that there are no atmospheric HOTS operating in the District. All HOTS operations are now employi ng pressure vessels which do not vent to atmosphere. These unvented pressure vessels are exempt from District permitting per

section 6.13 of District Rule 2020. Therefor e, the VOC emissions from this source category are considered to be zero.

How does District Rule 4404 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

District staff’s review of the EPA CTG list i ndicates that there is no CTG for HOTS.

B. EPA – Alternative Control Techniques (ACT) Document

District staff’s review of the EPA ACT list indicates that there is no ACT for HOTS.

C. Standards of Performance fo r New Stationary Sources (NSPS)

District staff’s review of 40 CFR 60 (St andards of Performanc e for New Sources)

indicates that there is no NSPS for HOTS.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-81 D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

District staff’s review of 40 CFR 61 (NESHAP) and 40 CFR (NESHAP for Source Categories) indicates that there is no NESHAP or MACT for HOTS.

How does District Rule 4404 compare to rules in other air districts?

District staff reviewed other nonattainment Ca lifornia air districts’ rules (SCAQMD, BAAQMD, SCMAQMD, and VCAPCD) and found that they do not have rules for this source category.

Conclusion

Since there are no HOTS currently operatin g in the District that are subject to requirements of this rule and the VOC em issions from this source category are

considered to be zero. Therefor e District staff concludes that District Rule 4404 satisfies

RACT.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-82 

### Rule 4407 – In-Situ Combustion Well Vents

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 0 0 0 0 0 0 0 0

VOC 0 0 0 0 0 0 0 0
(Source: District 2007 Ozone Plan)

District Rule 4407 Description

District Rule 4407 controls VOC emissions from in situ-combustion well vents. The rule applies to all crude oil production wells w here production has been enhanced by in-situ

combustion. In situ-combustion is defined in the rule as a thermal crude oil recovery process in which air is injected into an oil reservoir and in-place petroleum oxidizes at

an accelerated rate. The heat of com bustion and combustion products enhance oil production by decreasing oil viscosity and pressuri zing the reservoir. In situ combustion well is defined in the rule as any crude oil production well which produces from the same zone in which an air injection well is completed and lies within 1,000 feet from an injection well.

District Rule 4407 prohibits operation of any in -situ combustion well unless the well vent

is connected to an emission control device which abates 85% by weight of entering VOC gases or is connected to a fuel burni ng equipment (furnace, boiler, etc.) or a smokeless flare. All components (piping, valves, fittings, pumps, compressors, etc.) should be maintained in good repair and must be inspected for leaks on a quarterly basis. If no more than 2% of all component s of the collection syst em are found to be leaking during each three consecutive quarterl y inspections, the inspection frequency may be changed from quarterly to annual. The total number of leaks in a collection system should not exceed 2% of all the components in the colle ction system. Upon detection of a leak, the operator should affix a visible tag indicating the date of detection of the leak and the tag must remain in place until the leak is repaired. A leaking component must be repaired withi n 15 days of leak detection, but a 10 day extension to repair a leak may be granted provided the op erator demonstrates that necessary and

sufficient actions have been taken to correct the leak. Failure to repair a leak after the 10 day extension constitutes a violation of the rule.

District Rule 4407 requires annual testing of the VOC control efficiency of the control and collection system (testing should be co nducted during June, July, August, or September each year if t he system’s control effici ency is dependent upon ambient temperature). The APCO may waive the test requirement if all uncondensed VOC emissions is collected by a collection and control system are burned in fuel burning equipment or a smokeless flare.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-83 Currently, there are no in-situ combustion cr ude oil wells operating in the San Joaquin Valley Air Basin. A review of the Calif ornia Division of Oil, Gas, and Geothermal Resources’ oil and gas wells database showed that there are only 16 in-situ combustion wells in SJVAB, but all these wells were shut -in (i.e., not producing). Wells that are shut-in do not emit air pollut ants; therefore, t here are no emissions from this source category.

How does District Rule 4407 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

District staff’s review of the EPA CTG list i ndicates that there is no CTG for in-situ

combustion crude oil wells.

B. EPA – Alternative Control Techniques (ACT) Document

District staff’s review of the EPA ACT list in dicates that there is no ACT for in-situ

combustion crude oil wells.

C. Standards of Performance fo r New Stationary Sources (NSPS)

40 CFR 60 (Standards of Performance for New Sources) does not specify any NSPS for

in-situ combustion crude oil wells.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

40 CFR 61 (NESHAP) and 40 CFR (NESHAP for S ource Categories) does not specify any NESHAP or MACT for in-situ combustion crude oil wells.

How does District Rule 4407 compare to rules in other air districts?

District staff reviewed other California ozone nonattainment air districts’ rules (South Coat Air Quality Management District, Bay Area Air Quality Management District, Sacramento Metropolitan Air Q uality Management Air Distric t, and Ventura County Air Pollution Control District) and found that other air district s do not have any rules on insitu combustions crude oil wells.

Conclusion

Since there are no federal rules and regulations as well as prohibitory rules in other

California nonattainment areas for in-sit u-combustion crude oil we lls, District staff

concludes that District Rule 4407 satisfies RACT.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-84 

### Rule 4408 – Glycol Dehydration Systems

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023
VOC NQ NQ NQ NQ NQ NQ NQ NQ The emission inventory for this s ource category is not available.

District Rule 4408 Description

Rule 4408, adopted on Decem ber 19, 2002, reduces emissions of volatile organic compounds (VOCs) from glyco l dehydration systems used on nat ural gas streams. This rule provides the following three control options.

• Condenser/Vapor Disposal - all uncondens ed VOC emissions are directed to a vapor recovery system, a fuel gas system, or a sales gas system.

• Flare/Incinerator - all VOC emissions are combusted by a flare, an incinerator, a reboiler, or a thermal oxidizer.

• Any other system to control VOC emissions by at least 95% or to no higher than 1.7 pounds of VOC emitt ed per million dry standard cubic feet of gas.

How does District Rule 4408 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

There is no CTG for this source category.

B. EPA – Alternative Control Techniques (ACT) Document

There is no ACT for this source category.

C. Standards of Performance fo r New Stationary Sources (NSPS)

There is no NSPS for this source category.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

40 CFR 63 Subpart HH: National Emission Standar ds for Hazardous Air Pollutants for

Oil and Natural Gas Production

For major oil and natural gas production fac ilities, this subpart requires controls at process vents if actual flowrate of natural gas to the glycol dehydration unit is greaterSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-85 than 85 thousand m 3 /day, on an annual average basis; or the actual average benzene emissions from the glycol dehydrati on unit are greater than 0.90 Mg/ yr.

The control system must reduce emissions: (1) by 95.0 percent or more of HAP, or (2) by connecting the process vent to a process nat ural gas line, or (3 ) Pollution prevention measures, such as process modifications or combinations of process modifications and

one or more control devices that reduce the amount of HAP em issions generated, are allowed as an alternative provided they achieve the required emission reductions. ( CFR Volume 64, Number 116, page 32633 )

The control requirements as described above ar e the same as required by Rule 4408.

For this subpart controls are required if more than 85 thousand m 3 /day is processed which is equal to 1,095 million standard cubic f eet. While Rule 4408 controls required if

more than 5 million standard cubic feet of gas processed. Therefore Rule 4408 requirements are more stringent than requi rements of 40 CFR 63, subpart HH.

How does District Rule 4408 compare to rules in other air districts?

District staff compared control requirem ents in District Rule 4408 to comparable requirements in rules from the follo wing California nonattainment areas:

• Ventura County APCD Rule 71.5, as amended December 13, 1994

1. Ventura County APCD Rule 71.5

Ventura County APCD Rule 71.5 requirements ar e same as requirem ents of Rule 4408.

Conclusion

District staff concludes that District Rule 4408 satisfies RACT for Glycol Dehydration Systems.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-86 

### Rule 4409 – Components Serving Light Crude Oil or Gases at Light

Crude Oil and Gas Production Fac ilities and Components at Natural Gas Processing Facilities

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

VOC 5.0 4.9 4.8 4.7 4.5 4.3 4.3 11.6 VOC* adj 9.943 3.94 3.80 3.76 3.68 3.57 3.47 3.40
* Emissions inventory does not reflect reductions re sulting from recently adopted Rule 4409. This adjustment to the baseline inventory accounts for the 60% reduction from previ ously controlled emissions level resulting from Rule 4409 implementation effective April 2006.

District Rule 4409 Description

Rule 4409, adopted on April 20, 2005, concerns fugitive emissions from various components at Light Crude Oil and Gas Pr oduction Facilities and Components at Natural Gas Processing Facilities. The main r equirement of this rule is to reduce the number and severity of leaking components by regular inspection, repair, and replacement requirements, as well as manda ting violations and penalties above certain

leak thresholds.

On March 23, 2006, EPA took direct final acti on to approve revisions to the San Joaquin Valley Unified Air Pollution Control District portion of the California State Implementation Plan. These revisions included approval of District Rule 4409. EPA, in evaluating and approving Rule 4409 included the following:

“We believe these rules are consistent with the relevant policy and guidance regarding enforceability, RACT, and SIP relaxations.” ( CFR Volume 71, Number

56 )

Since Rule 4409 was approved by EPA as meet ing RACT requirements, the District did not pursue a detailed RACT analysis.

How does District Rule 4409 compare wi th federal rules and regulations?

The District did not conduct a detailed analysis of federal rules and regulations for Rule

4409.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-87 How does District Rule 4409 compare to rules in other air districts?

The District did not conduct a detailed comparison to rules in other air districts for Rule

4409.

Conclusion

District staff concludes that District Rule 4409 satisfies RACT for Components Serving Light Crude Oil or Gases at Light Cr ude Oil and Gas Production Facilities and Components at Natural Gas Processing Facilities.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-88 

### Rule 4453 – Refinery Vacuum Producing Devices or Systems

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023
VOC NQ NQ NQ NQ NQ NQ NQ NQ
(Source: District 2007 Ozone Plan)

District Rule 4453 Description

Rule 4453, amended on December 17, 1992, applies to any vacuum producing device or system, including hot wells and accumulators in a refinery. The rule requires hot wells and accumulators to be covered. In addition, the rule requires the vapors from vacuum producing devices or systems, hot wells , and accumulators to be compressed and added to refinery gas, controlled and combusted to a firebox or inciner ator with at least 90% VOC control efficiency, or controll ed by other methods approved by the APCO.

How does District Rule 4453 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

EPA-450/2-77-025 (Control of Refinery Vacuum Producing Systems, Water Separators and Process Unit Turnarounds), October 1977, indicate s that RACT requires noncondensable vapors from vacuum producing syst ems be combusted in a firebox. Also, process units should be depressurized to a flar e, fuel gas system, or other combustion device before being opened for inspection or maintenance. The District Rule 4453 requirements are as stringent as the CTG.

B. EPA – Alternative Control Techniques (ACT) Document

District staff’s review of the EPA ACT list in dicates that there is no ACT for refinery vacuum producing device or system.

C. Standards of Performance fo r New Stationary Sources (NSPS)

District staff’s review of 40 CFR 60 (St andards of Performanc e for New Sources)

indicates that there is no NSPS for re finery vacuum producin g device or system.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-89 D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

40 CFR 63 Subpart CC (NESHAP from Petroleum Refineries) does not have specific control requirements for refinery vac uum producing device s or systems.

How does District Rule 4453 compare to rules in other air districts?

District staff compared District Rule 4402 with the rules of ot her California ozone nonattainment air districts’ rules (South Coast Air Quality Management District, Bay Area Air Quality Management District, Sacramento Metropolitan Air Quality Management Air District, and Ventura County Air Pollution Control District) on open burning. The results of the analysis are discussed below.

A. SCAQMD Rule 465 (Refinery Vac uum-Producing Devices or Systems) amended August 13, 1999

SCAQMD Rule 465 requires hot wells and a ccumulators to be eq uipped with covers. Rule 465 also requires the exhaust gases from vacuum-producing devices or systems, including hot wells and accumulators to be continuously collected and added to a fuel system or a combustion device. In com parison, Rule 4453 requires hot wells and accumulators to be covered, and the v apors from vacuum producing devices or systems, hot wells, and accumulators have to be compressed and added to refinery gas, controlled and combusted to a firebox or incinerator with at least 90% VOC control efficiency. Based on this evaluation Distric t staff deems Rule 4453 is as stringent as
SCAQMD Rule 465.

B. BAAQMD Regulation 8, Rule 9 (V acuum Producing Systems) amended July,20,1983

BAAQMD Regulation 8, Rule 9 requires hot wells and accumulators to be covered and the organic vapors must be incine rated or treated so as to prevent their emission into the atmosphere. The rule also requires the non-condensable org anic emissions from vacuum producing systems to be controlled and piped to an appropriate firebox or incinerator for combustion, or collected, compressed, and added to the fuel gas system, or be contained and treated so as to prevent their emission into the atmosphere. In comparison, Rule 4453 requires hot wells and accumulators to be covered, and the vapors from vacuum producing devices or syst ems, hot wells, and accumulators have to be compressed and added to refinery gas, contro lled and combusted to a firebox or

incinerator with at least 90% VOC control e fficiency. Based on this evaluation District staff deems Rule 4453 is as stringent as BAAQMD Regulation 8, Rule 9.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-90 C. VCAPCD Rule 74.8 (Refinery Vac uum Producing Systems, Wastewater Separators and Process Turnarounds) amended July 5, 1983

VCAPCD Rule 74.8 requires all uncondensed organic vapors emitt ed from vacuum producing systems to be contain ed and piped the vapors to a firebox, a flare, or added to refinery fuel gas or feedbacks. In co mparison, Rule 4453 requires hot wells and accumulators to be covered, and the v apors from vacuum producing devices or systems, hot wells, and accumulators have to be compressed and added to refinery gas, controlled and combusted to a firebox or incinerator with at least 90% VOC control efficiency. Based on this evaluation Distric t staff deems Rule 4453 is as stringent as

VCAPCD Rule 74.8.

D. Sacramento AQMD has no rule for this source category.

Conclusion

District staff concludes that District Rule 4453 satisfies RACT for Refinery Vacuum Producing Devices or Systems.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-91 

### Rule 4454 – Refinery Process Unit Turnaround

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023
VOC NQ NQ NQ NQ NQ NQ NQ NQ
(Source: District 2007 Ozone Plan)

District Rule 4454 Description

Rule 4454 applies to any refinery vessel cont aining VOC. The rule exempts any process vessel that has been depressurized to less than five psig (1020 mm Hg). The rule requires VOC-containing vessels to be depressurized to less than 5 psig or as close to atmospheric pressure as possible, and the re covered vapors must be directed to a fuel gas system, incinerator, or a flare for combustion before venting/opening to the atmosphere.

How does District Rule 4454 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

EPA-450/2-77-025 (Control of Refinery Vacuum Producing Systems, Water Separators and Process Unit Turnarounds), October 1977, indicates t hat RACT requires process units to be as close to atmospheric pressu re as practicable as possible. The CTG indicated that most refineries should easily d epressurize processing units to 5 psig or below before venting to the atmosphere. At mospheric emissions wil l be greatly reduced if vapors are combusted as fuel gas or flared until the pressure in the vessel is as close to atmospheric. The District Rule 4454 r equirements are as stringent as the CTG.

B. EPA – Alternative Control Techniques (ACT) Document

District staff’s review of the EPA ACT list in dicates that there is no ACT for refinery process unit turnarounds.

C. Standards of Performance fo r New Stationary Sources (NSPS)

District staff’s review of 40 CFR 60 (St andards of Performanc e for New Sources)

indicates that there is no NSPS fo r refinery process unit turnarounds.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-92 D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

40 CFR 63 Subpart CC (NESHAP from Petroleum Refineries) does not have specific control requirements for refi nery process unit turnarounds.

How does District Rule 4454 compare to rules in other air districts?

District staff reviewed other nonattainment Calif ornia air districts’ rules (South Coast Air Quality Management District (SCAQMD), Ba y Area Air Quality Management District (BAAQMD), Sacramento Air Quality M anagement District (SMAQMD) and Ventura County Air Pollution Control District (VCAPC D) that control the VOC emissions from depressurizing process vessels as discussed below.

A. SCAQMD Rule 1123 (Refinery Process Turnarounds), amended December 12,

1990

SCAQMD Rule 1123 prohibits depressurizi ng any vessel containing organic materials unless the vapors released from the vessel ar e collected and contained for use as fuel or sent to a gas disposal system until the pr essure in the vessel is below 5 psig, or is within 10 percent above minimum gauge pressure at which the vapors can be collected, whichever is lower. If inert gas displace ment or vacuum eduction is used for process turnaround, an operator has to submit a plan to the executive officer for approval which describes at a least the following: the proc edure used for gas displacement or eduction; the disposition of the displaced or educed or ganic gases, the stage in the displacement or eduction procedure at which disposit ion is changed from control facility to atmospheric venting; and t he criteria by which said stage is identifiable.

B. BAAQMD Regulation 8, Rule 10 (Organic Compounds - Process Vessel Depressurization), amended January 21, 2004

BAAQMD Regulation 8, Rule 10 require s organic compounds emissions from depressurizing any process vessel to be cont rolled by venting them to a fuel gas system, firebox, incinerator, therma l oxidizer, flare or containi ng and treating them so as to prevent their emissions into the atmos phere. The depressurizing procedure should continue until the pressure within a process vessel is as close to atmospheric pressure as practically possible, in no case should a process vessel be vented to the atmosphere until the partial pressure of the organic compounds in t he vessel is less than 1,000 mm Hg (4.6 psig). The rule prohibits openi ng a process vessel to the atmosphere unless

the internal concentration of total or ganic compounds has been reduced to less than 10,000 ppm expressed as methane. However, a process vessels may be opened to the atmosphere when the internal pressure is 10, 000 ppm or greater if the total number of vessels opened with such concentration duri ng any five consecutive years does not

exceed 10% of the total vesse l population and the organic compound emissions do not exceed 15 pounds/day.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-93 Although Rule 4454 does not have a requirem ent like BAAQMD Regulation 8, Rule 10 that prohibits opening a process vessel to the atmosphere unless the internal concentration of total organic compounds ha s been reduced to less than 10,000 ppmv, based on District’s staff field inspection experience and observations, operators would not start opening a process vessel for inspec tion or maintenance unless the internal vapor concentration is less than 5,000 ppmv or less than 10% of the lower explosive limit (LEL) for safety reasons in order to comply with applicable OSHA regulations. Additionally, such vessel is also consider ed a tank as defined in Rule 4623 (Storage of Organic Liquid) and is subject to the more stringent degassing provisions which require the vessel to be degassed to less than 5, 000 ppmv or less than 10% of the LEL, whichever is lower. As such, the proce ss vessel depressurization requirements of Rule 4454 in conjunction with the degassing contro l requirements of Rule 4623 are more

effective than other air districts’ rules.

C. VCAPCD Rule 74.8 (Refinery Vac uum Producing Systems, Wastewater Separators and Process Turnarounds), amended July 5, 1983

VCAPCD Rule 74.8 prohibits venting or ganic compounds to the atmosphere during depressurization or the vessel purging steps of a refinery process turnaround. All uncondensed organic gases should be vented to a fuel gas system or to a flare, or other methods which district has determined will pr event said gases from being emitted into the atmosphere.

D. Sacramento AQMD has no rule for this source category.

Conclusion

District staff concludes that District Rule 445 4 satisfies RACT for Refinery Process Unit

Turnaround.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-94 

### Rule 4455 – Components at Petroleum Refineries, Gas Liquids Processing Facilities, and Chemical Plants

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

VOC 0.120 0.120 0.120 0.120 0.120 0.120 0.120 0.190 VOC* adj 0.233 0.026 0.026 0.026 0.026 0.026 0.026 0.026

* Emissions inventory does not reflect reductions re sulting from recently adopted Rule 4455. The adjusted inventory accounts for the 89% reduction fr om previously controlled emissions level resulting from Rule 4455 implementation effective April 2006.

District Rule 4455 Description

Rule 4455, adopted on April 20, 2005, concerns fugitive emissions from various components at petroleum refineries and chemical plants. The main requirement of this rule is to reduce the number and severity of leaking components by regular inspection, repair, and replacement requirements, as well as mandating violations and penalties

above certain leak thresholds.

On March 23, 2006 EPA took direct final acti on to approve revisions to the San Joaquin Valley Unified Air Pollution Control District portion of the California State Implementation Plan. These revisions included approval of District Rule 4455. EPA, in evaluating and approving Rule 4455 included the following:

“We believe these rules are consistent with the relevant policy and guidance regarding enforceability, RACT, and SIP relaxations.” ( CFR Volume 71, Number

56 )

Since Rule 4455 was approved by EPA as meet ing RACT requirements, the District did not pursue a detailed RACT analysis.

How does District Rule 4455 compare wi th federal rules and regulations?

The District did not conduct a detailed analysis of federal rules and regulations for Rule

4455.

How does District Rule 4455 compare to rules in other air districts?

The District did not conduct a detailed comparison to rules in other air districts for Rule

4455.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-95 Conclusion

District staff concludes that District Rule 4455 satisfies RACT for Components at Petroleum Refineries, Gas Liquids Proc essing Facilities, and Chemical Plants.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-96



### Rule 4565 - Biosolids, Animal Manure, and Poultry Litter Operations

Emissions Inventory : Tons per day - summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 0 0 0 0 0 0 0 0

VOC 9.7 9.8 9.9 10.0 10.1 10.2 10.3 10.4
(Source: District 2007 Ozone Plan)

District Rule 4565 Description

District Rule 4565, recently adopted on March 15, 2007, to limit VOC emissions from facilities whose throughput consists entirely or part of biosolids, animal manure, or poultry litter and the operator who landfills , land applies, composts, or co-composts these materials. Sewage treatme nt plants or other wastewat er treatment facilities are not subject to this rule unless the operatorlandfills, land applies, composts, or cocomposts the treated materi al (biosolids) on site.

How does District Rule 4565 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

There is no EPA CTG guidance document for biosolids, animal manure, and/or poultry litter operations.

B. EPA - Alternative Control Technology (ACT)

There is no EPA ACT guidance document for biosolids, animal manure, and/or poultry litter operations.

C. Standards of Performance fo r New Stationary Sources (NSPS)

There is no NSPS guidance document for biosol ids, animal manure, and/or poultry litter operations.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

There is no NSPS guidance document for biosolid s, animal manure, and/or poultry litter operations.

How does District Rule 4565 compare to rules in other air districts?

District staff compared VOC lim its, optional control require ments, and work practiceSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-97 standards in District Rule 4565 to comparable requirements in rule s from the following

California nonattainment areas:

• South Coast AQMD Rule 1133.2 - Em ission Reductions from Co-Composting Operations (Adopted January 10, 2003

• Bay Area AQMD, Sacramento Metropolit an AQMD and Ventura County APCD do not have rules that apply to composting or co-composting operations.

South Coast Air Quality Management District (S CAQMD) Rule 1133.2 (Emission Reductions from Co-Composting Operations)

SCAQMD Rule 1133.2 applies to all new and existing co-composting operations.

Staff notes that there are some significant differences between District Rule 4565 and
SCAQMD Rule 1133.2. This should not be interpreted to mean that one rule is more stringent than the other, but due inst ead to the following factors:

1. Technology has changed significantly since SC AQMD Rule 1133.2 was adopted; 2. Additional research projects regarding mitigation measures have been completed since SCAQMD Rule 1133.2 was adopted; and

3. The socioeconomic climate of the SCAQMD is significant ly different from that of

the District.

The table below summarizes the significant differences between SCAQMD Rule 1133.2

and SJVUAPCD Rule 4565. Below are the important differenc es between the two rules.

Category SCAQMD Rule

1133.2 SJVUAPCD Rule 4565 Reason

Rule does not apply to these operations Management practice requirements Knowledge of VOC control options has increased since Rule 1133.2 adoption

and staff believes that cost-effective

methods of contro lling VOC emissions

from these facilities exist.

Co-Composting

Threshold for Applicability Facilities with at least 1,000 tpy throughput Facilities that handle 100 tpy or more of biosolids, animal manure, or poultry litter Staff believes that there are reasonable, cost effective options for facilities with throughputs of ≥ 100 tpy that would not impose an undue burden on operators.

Composting Control Requirements In-vessel composting with
70 – 80% VOC

control efficiency VOC control efficiency 10% - 80% depending on type of operation and facility throughput Management practices (mitigation measures) are effect ive, reasonable, and have been achieved in practice for

smaller facilities.

In-vessel composting is not costeffective for smaller or medium facilities and there are no known, unsubsidized
facilities in the SCAQMD that would comply with such rule requirements.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-98 Furthermore, in order to acknowledge that some VOC mitigation measures are only cost-effective for larger facilities, SJVA PCD staff developed the concept of Class One and Class Two mitigation measures. Class O ne mitigation measures are considered BARCT and cost-effective options for all facilit ies, regardless of size. These measures are management practices found to be best practices for all composting operations.

Class Two mitigation measures are the te chnology options and achieve reductions greater than Class One mitigation measures, however they are not cost effective for facilities with throughputs of less than 100,000 wet tons per year (s ee Appendix C of the Final Rule 4565 Draft Staff Report details t he costs and cost effectiveness analysis).

SJVAPCD Rule 4565 requires reductions fr om two addition categories (landfilling and land applying) when compared to SCAQMD Ru le 1133.2. For the third category, composting, SJVAPCD staff dete rmined it is not cost effective to require in-vessel (enclosed) composting.

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, Distric t staff concludes that District Rule 4565 satisfies RACT for biosolids, anima l manure, and poultry litter operations.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-99 

### Rule 4570 – Confined Animal Facilities

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

VOC

without 4570 65.4 68.7 72.5 74.0 76.9 81.4 85.9 90.4

VOC

* adjusted 65 68 53 55 57 60 64 67

* Baseline adjusted to reflect recently adopted Rule 4570 reductions & current estimated control

efficiencies.

Note: The RACT analysis for Rule 4570 follows a different format due to the innovative nature

of the rule.

1. BACKGROUND – CONFINED ANIMAL FACILITIES IN TH E SAN JOAQUIN

VALLEY

Confined Animal Facilities ar e used for the raising of animals including, but not limited to, cattle, calves, chickens, ducks, goats, horses, sheep, swine, rabbits, and turkeys, which are corralled, penned, or otherwise ca used to remain in restricted areas for commercial agricultural purposes and fed by a means other than grazing. (CH&SC 39011.5 (a)(1))

1.1. TYPES OF CONFINED ANIMAL FACILITIES

1.1.1 INDUSTRIES THAT USE CAFs

Confined animal facilities are used in the ra ising of livestock for the purpose of providing dairy products, meat, and eggs. The raising of livestock (livestock agriculture) has gone through significant changes since the 1990s. Today, meat and dairy products typically originate on farms whose herds of cattle or hogs, or flocks of chickens are much larger than in the past. These farms usually hous e a single species in buildings or open-air pens, and provide them with feed that has b een purchased rather than grown onsite. While most such farms are still family-ow ned and operated, they rely heavily on hired labor and are tightly linked to other stages of production and processing through formal contracts, alliances, and joint financi ng or common ownership of assets.1

The growth of all types of livestock agriculture farms continues to increase. A big driver in the structural change in livestock agriculture is increased productivity and, through that, lower production costs to the farmer. The largest dai ry farms (1,000+ head) have production costs that are 15% lo wer than the next largest size class (500-999 head). This kind of production cost-saving is also true of layers (chickens raised to lay eggs), broilers (chickens raised for meat), hog, and beef producers. For livestock agriculture, evidence to-date suggests that production costs fall as the farm size increases up to

some threshold level. Production costs then level out, meaning that there is no unique optimal size. Dairies with 2,000 cows have av erage costs similar to dairies with 1,000San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-100 cows, for example. Therefore, these liv estock operations can get quite large without experiencing increased production co sts from being “overly” large.

One example of the shift to large-scale produc tion is the dairy industry. Nationally, only about 10% of all dairy cows were housed on farms with more than 1,000 head in 1992. By 2007, that ratio rose to 36% of all dairy cows. The shift to ve ry-large dairies (1,000+ head) had its origin in California and other western states. Looking at California specifically, the state has becom e the largest producer of milk in the nation. The eight counties of the San Joaquin Valley are all in the top-ten Californ ia counties for milk production, with Tulare County heading the lis t. Tulare County alone produced almost as much milk as the entire state of Pennsyl vania, the state ranked number five on the 2007 list of top milk-producing states and Tu lare County was well ahead of Minnesota, the sixth largest m ilk producing state.

The State of California tra cks the number of dairies and t he number of dairy cows by county. By dividing the number of cows by the number of dairies, the average number of cows per dairy for each county is dete rmined. The simple math done by the state does not reveal the extent to which larger dairies have appeared in the District. The SCAQMD Staff Report for the adoption of Rule 223 points out the relative contribution of

all CAFs to the South Coast emissions invent ory in the near future is expected to be significantly lower than what the current figures indicate. 6 Consistent with the assumptions made by SCAQMD, many dairies have already moved to the San Joaquin Valley (SJV). Much of this is due to t he encroachment of residential areas close to South Coast CAF operations. That, coupled wit h the less-expensive land in the Valley and proximity to the Gr eater Los Angeles market, makes the SJV the perfect destination

for dairies from the South Coast air basin. Kern County is about 50 minutes away from the Greater Los Angeles area and has direct access via Interstate 5 and California State Route 99. The county with t he highest head-per-dairy in 2007 was Kern County with an average of 3,137 head per dairy , up 50% from the 2002 level of 2,093 head per dairy.

Although dairies are notable in their shift to large-scale production, other types of livestock agriculture have also increased the average farm size. Nationally, the median production of broilers (50% larger and 50% smaller) is 600,000 broilers per year. In 2002, the median production was 520,000. Active District permits echo this national

trend.

1.1.2 MAJOR CAF CATEGORIES

Industries employing confined animal facilities (CAFs) provi de several majo r nutritional commodities, including dairy produ cts, meat, and eggs. There are many different types of CAFs in the San Joaquin valle y. The majo r categories are des cribed below.

6 Page 7 of the SCAQMD Staff Report Rule 223San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-101 1.1.2.1 Dairy Operations

Dairy operations are defined as those operations producing milk or animals for facilities that produce milk. In order to produce milk , the cows must be bred and give birth. Typically, the gestation period for dairy cattl e is nine (9) months and dairy cows are bred again approximately four (4) months after calving. M ilk production typically peaks shortly after calving and then declines. Comm only a cow will produce milk for ten (10) to twelve (12) months and then be dry approximately two (2 ) months. Thus, a dairy operation may have several types of animal gr oups present including heifers, lactating cows, dry cows, calves, and bulls (for br eeding purposes). Approximately 25% of a milking herd is replaced each year, but replacement levels can be as high as 40% for intensively managed herds (EPA 2001).

Feeding and watering practices vary for eac h animal type. In general, calves are nursed for four (4) to five (5) days after birt h. Calves are then f ed a milk replacement until weaning, which generally occurs at abo ut eight (8) weeks of age. During this period, a feed grain based starte r diet is introduced. This st arter diet is fed to calves until they are approximately thre e (3) months old. At appr oximately three (3) months, calf rumen development allows a shift to a roughage-based diet.

Older cattle and calves being raised for m ilk production are commonly fed a roughagebased diet. The principal constituents of t hese diets are corn or grain sorghum silage and legume or grass and legume hays with f eed grains and byproduct foodstuff added in varying amounts to satisfy energy, protei n, and other nutrient requirements. The manure tends to be generated in a semi-solid state.

1.1.2.2 Poultry Operations

Poultry facilities operate either as layer r anches for egg production or as broiler ranches where birds are grown for the fresh meat market. Poultry facilities, called ranches in reference to their specialized operation, ma y consist of one or more farms on properties that may be several miles apart. Several barn-like houses may make up a farm. A chicken layer house may have over 100,000 layers; a typical chicken broiler house contains approximately 20,000- 25,000 birds; and a typical turkey broiler house contains approximately 10,000 birds at any one time.

1.1.2.3 Beef Cattle Feeding Operations

This animal sector includes adult beef cattl e (heifers and steers). Beef cattle may spend all, part, or none of their lives on a CAF. There are three types of operations in the beef industry: cow-calf operations , backgrounding operat ions, and finishing operations. These operations are typically conducted at separate locations that specialize in each phase of production, but may occur at a single location.

Cow-calf operations are a source of heifers and steers fed for slau ghter. These animals are fed primarily hay with some grain and other foodstuff. Backgrounding or stockerSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-102 operations prepare weaned calves for finishi ng. The backgrounding process is highly dependent on feed prices. Typically the animals are fed the lowest priced feed at the time, which may be forages or crop residues , with the objective of building muscle and

bone mass at a low cost. The duration of t he backgrounding process may be from thirty (30) days to six (6) months old. Typicall y, high grain prices favor longer periods of backgrounding by reducing feed costs for finish ing or fattening. After approximately 150 to180 days, animals in finishing operations will reach slaughter we ights of 1,050 to 1,250 pounds. Although, some feedlots star t with younger or older cattle and the finishing cycle may be less than 100 days or ov er 270 days. Accordingly, feedlots typically have between 1.5 to 3.5 cattle turnovers per year.

In any case, animals are typically segr egated by production stage in pens with feed truck access. The animals are typically fed tw o (2) to three (3) time s per day using feed bunks located along feed alleys that separate the individual pens.

1.1.2.4 Swine Operations

The production cycle for hogs has three (3) phas es: farrowing, nursing, and finishing. The first phase begins with breeding and gesta tion over a 114-day period followed by farrowing (giving birth). After farrowing, t he newly born pigs or piglets normally are nursed for a period of three (3) to four (4) weeks until they reach a weight of approximately ten (10) to fi fteen (15) pounds. Typically, t here are from nine (9) to eleven (11) pigs per litter. Sows can be bred again within a week after a litter is weaned. Sows normally produce five (5) to six (6) litters before they are sold for slaughter at a weight of 400 to 460 pounds.

Weaned pigs are fed a starter ra tion until they reach a weight of approximately fifty (50) to sixty (60) pounds. At this poi nt, they are typically eight (8) to ten (10) weeks of age. Then the animals are fed a growing and fina lly a finishing ration until they are approximately 240 to 280 pounds at which point they are approximately 26 weeks of age and ready for slaughter. The diet varies, but it typically includes small grains such as wheat and barley, corn and soybean meal.

1.1.3 VARIETY OF CAFS

CAFs can vary significantly in size from one CAF to another (e.g., dairy to feedlots, poultry, etc.) and within the same category of CAFs (dairy to dairy). For example, a dairy can be as small as 10 acres to well over 100 acres, depending on the number and types of cows on the facility. The majority of the sources on a dairy or a cattle facility are large open areas and cannot be easily controll ed, specifically by a single control device. Dairies cannot be compared to feedl ot cattle nor can either be compared to poultry operations. Poultry operations, even within themselves have many different characteristics and practices.

Due to the different methods of conf inement and associated manure management, there is no typical CAF. The design and ope ration of a CAF varies depending on animalSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-103 type, regional climatic conditions, busi ness practices, and preferences of the owners/operators. No t all of the mitigation measures included as an option in Rule 4570 can be reasonably adopted by all facilities due to infrastructure, conditional use permits, water board permits, so il types, production contracts, and other limitations.

A description of the different types of housing and management systems are described

below:

1.1.3.1 Dairy Cattle Manure Management

1.1.3.1.1 Flush

The vast majority of the dairy cows in t he Valley are located at dairies with a flush manure management system, which removes the manure by using a flushing system. A large volume of water is introduced at the head of a paved area, and the cascading

water removes the manure. Flush water c an be introduced from st orage tanks or highvolume pumps. The required volume of flus h water varies with the size of the area to be flushed and slope of the area. In a flus h system, the manure gener ated by the cows next to the freestalls (near the feed lanes) is flushed by large amounts of water a few times a day generally to the lagoon. The lagoon serves as the basis of holding and decomposing the manure.

1.1.3.1.2 Scrape

Scrape manure management removes the manure and bedding from the barns and pens by a tractor or a mechanical scraper . Scrape manure management dairies may also have a mechanical alley scraper that co nsists of one or more blades that are wide enough to scrape the entire alley in one pass. A timer can be set so that the scraper runs two to four times a day . Scrapers reduce daily labor requirements, but have a higher maintenance cost due to corrosion and deterioration.

The rate of manure accumulation in dryl ots (open corrals) and pens for the cattle is highest along feed bunks and watering tr oughs and therefore these areas will be scraped more frequently than other areas. These areas are usually paved with

concrete.

1.1.3.1.3 Vacuum

There is a small percentage of dairies that utilize a vacuum system to collect as

excreted manure with a vacuum truck. Generally, the trucks collect approximately 4,000 gallons per load. The manure can be hauled to a disposal site rather than to an intermediate sump. Vacuum collection is a slow and tedious process. The advantage

is that the collected manure is undiluted and approximately equal to the as excreted concentration and can be applied directly to land. Generally no lagoons are needed for this type of system, however there may be a need to maintain slurry pits if the facility

does not have sufficient land available.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-104 1.1.3.2 Dairy Cattle Housing and Manure Management

Majority of Milk cows in the Valley are hous ed in freestalls while the vast majority of other cows (dry cows and heifers) are hous ed in open corrals. However, dairies may have a single type of housing or consist of both types of housing. Baby calves are generally housed in calf hutches, but vary in type (aboveground or on-ground). A brief description of each of the types of housing is included below:

1.1.3.2.1 Freestalls

In the freestall barn cows are grouped in la rge pens with free access to feed bunks, waterers, and stalls for resting. A standard free-stall barn design has a feed alley in the center of the barn separat ing two feed bunks on each side. Animals stand on the concrete feed lane to eat; this is where the majority of the animal excretion occurs. A variety of types of bedding materials are us ed for animal comfort and to prevent animal injury.

1.1.3.2.2 Open Corrals (drylots)

An open corral is a large open area (fenced in) where cows are confined, with unlimited access to feed bunks, water, and possibl y an open structure to provide shade.

1.1.3.2.3 Special Needs Housing

The special needs area serves the gestating co ws at the dairy or any cow that may have a medical condition. This area acts as a veterinary area and gives the cows special attention as they move from dry co w (a mature cow that is gestating but not lactating) to maternity to milking st atus or until their health improves.

1.1.3.2.4 Calf Housing

The calves are generally housed individually until they are r eady to wean (to accustom to take nourishment other than by suckling).

1.1.3.3 Feedlot Cattle Housing and Manure Management

Feedlot cattle are segregated in pens desig ned for efficient movement of cattle, optimum drainage, and easy feed truck access. Pens are large open areas where cattle are confined, with unlimited access to feed bunks, water, and possibly an open structure to provide shade. A typical pen holds 150- 300 head of cattle but the size can vary substantially. Required pen space may range from 75 to 400 square feet of pen space per head, depending on the climat e. A dry climate requires 75 square feet of pen space per head whereas a wet climate may require up to 400 square feet (Thompson, O'Mary, 1983). Space needs vary with the amount of paved space, soil type, drainage, annual rainfall, and freezing and thawing cycles. Thes e types of operations may use mounds toSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-105 improve drainage and provide areas that dry quickly, sinc e dry resting areas improve cattle comfort, health, and feed utilization.

For these types of operations, the manur e is commonly handled as a solid. Solid manure is typically scraped or moved by tracto rs to stockpiles. Manure accumulates in areas around feed bunks and water troughs most r apidly, thus these areas may need to be cleaned during the finisher cycle. Howeve r, there is signific ant concern and risks

associated with enter ing areas where beef cattle are housed.

1.1.3.4 Poultry Housing and Manure Management

In the United States, approxim ately 61% of the chicken layer houses and a majority of the breeder and broiler houses use power ventila tion instead of natural ventilation. The most common type of power ventilation is tunnel ventilation. In tunnel-ventilated houses, all the fans are clustered at one end of the house and the fans push the air to

the other end of the house. Curtains on the houses may be used on a non-routine basis for ventilation, particularly during colder weather.

Studies indicate that most chicken layer houses produce approximately two cubic yards of waste per week per five hundred chick ens. Although a small amount of liquid waste may occur from egg washing operations loca ted on the facility and a small amount of bedding may be collected as waste, poultry excr etions account for a majority of the waste. Typically, hens are confined in a la yer house that consists of many layer boxes positioned above the ground. On average, ev ery seven (7) to nine (9) days workers remove waste from under the layer boxes , and every fourteen (14) to eighteen (18)

weeks workers remove waste from the fl oor of the layer houses. However, many facilities list less frequent waste removal, ranging from one (1) to three (3) times per year (every 17-52 weeks) as a control tec hnique used to comply with District Rule 4550 Conservation Management Plan (CMP). Severa l mitigation measures in Proposed Rule

4570 and Rule 4550 that the owners/operators could choose do not affect waste removal frequency. Therefore, owners/oper ators can comply with both Rule 4550 and

4570.

In broiler facilities, comple te litter removal from the hous e occurs one (1) to four (4) times per year. Litter removal frequencies vary from every two (2) to seven (7) flocks (approximately 90-315 days); more commonly, it is removed ev ery third flock. Before introducing a new flock, the house is left empty, typically for five (5 ) days. During this interlude, the operator adjusts the temperature and other ambient conditions in the house. In the broiler industry, the new flocks of birds are brought into the houses as chicks and are raised for approximately 45 days, until they reach the desired weight. Shortly thereafter, the grow n birds are removed and the house is again left empty for approximately five (5) days to sanitize. This approximately 55-day cycle is the production period for one flock. Depending on management practices, litter production ranges from 0.5 to 0.7 pounds per pound of liv e bird weight. On average, for each pound of live weight gained, meat birds produced 0.52 pou nds of litter during the production period.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-106 Poultry excretions and bedding materials, such as rice hulls, are removed either by scraping or by flushing. In a scrape system, the litter is either swept or scraped from the house into a pile or piles outside the house. Typically, concerns about transmitting diseases among birds and flocks necessitate trucking the scraped litter offsite shortly after removal. The liquid hand ling system is similar to da iry flush systems, explained later in this report. However, less than 15% of the poultry operations in the San Joaquin Valley use liquid manur e handling systems.

1.1.3.5 Swine Housing and Manure Management

The animals are typically housed in confi nement buildings that are either totally enclosed or open-sided with curtains. Tota lly enclosed facilities are mechanically ventilated throughout the year . Open-sided buildings are naturally ventilated the majority of the year, but may be mechanica lly ventilated when the curtains are closed due to weather conditions. Manure may be fl ushed from the floor of the housing or fall through slats in the floor to a pit underneath t he floor. Manure in the pit may be flushed or scraped.

1.1.3.6 Miscellaneous Emission Units at CAFs

1.1.3.6.1 Manure St ock Piles-Storage

Almost all cattle facilities maintain uncovered storage stockpiles. Because open piles are subjected to rain, they exhibit em ission profiles of bot h aerobic and anaerobic

conditions over time. When stacked for stor age, a significant increase in temperature may occur depending on moisture content due to microbial heat production.

1.1.3.6.2 Storage Ponds

Manure with a total solid content of 10% or le ss can be handled as a liquid. In slurry or liquid systems, the manure is fl ushed from alleys or pits to a storage facility. A flush manure management needs a place to flush the manure to and generally consist of small to very large basin(s) designed for temporary collection and storage of their organic waste. Storage ponds are not designed to treat wast e but to simply store it or hold it. Storage ponds may completely be emptied when pumped, and the design storage periods are about 90 to 180 days.

1.1.3.6.3 Land Applicat ion of Animal Waste

Liquid manure from flush systems stored in lagoons or solid manure scraped from facilities eventually may be land applied wit h or without prior treatment such as composting or anaerobic digestion. Typically , animal waste is applied to cropland at rates adequate to supply crop nutrient needs. Historically the determination of application rates has been based on crop ni trogen requirements due to concern about the impact of excess nitrogen on surface and gr ound water. In cases where treatmentSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-107 methods, such as aerobic digestion, increase the nitrate content in the waste stream, the waste may need to be applied over a greater number of acres in order to comply with the Regional Water Qua lity Board’s regulations.

Surface application of manure waste may be done with a spreading device known as a box manure spreader. This is simply a rectangul ar box that is eit her tractor drawn or truck mounted with a spreading device at t he rear end. During sp reading, the manure moves to the rear of the box by either a bel t or chain-and flight conveyor. Box type spreaders are typically loaded with tractor mounted front-end loaders . Manure handled as slurry or liquid may be spread with a trac tor drawn or truck mounted tank known as a liquid manure spreader. The manure may be forced out of the tank under pressure against a distribution plate to create a spray pattern. Another option is to force the

manure from the tank under pressure through a manifold with a series of hanging or trailing pipes to create parallel strips of manure on the soil surface. A second type of spreader for manure slurries is a flail spreader. This is a partially open tank with chains attached to a rotating shaft positioned parallel to the direction of travel. Manure is discharged perpendicular to the direction of travel by the momentum transferred from rotating chains.

Manure may be land applied and land incorp orated through the use of a manure injection device, typically attached to a tr actor; tilling surface applied manure under the soil; applying liquid manure at such a rate t hat is rapidly absorbed into the soil; or

another method in which the manure is covered with soil.

Facilities choosing to use conservation tillage options will likely apply any liquid manure at a rate such that it is rapidly absor bed into the soil and apply any solid manure only

after it has been treated with an anaerobic di gestion process, treated with an aerobic digestion process, or dried to a moisture content of le ss than 50%. In any of these cases the animal waste land applied would not need to be tilled under the soil in order to comply with rule requirements. Simila rly, such methods may be used when crop height prevents the owner /operator from tilling the land-applied waste.

1.1.3.6.4 Windrow Composting

Some dairies in the Valley also compost the manure generat ed from their facility. Composting is the aerobic decomposition of manure or other organic materials in the thermophilic temperature range (1 04 -149 degrees F) . It is the same process that decays leaves and other organic debris in nature. Co mposting merely contro ls conditions so that materials decompose faster. Composting is generally perfor med through windrow compost piles. A windrow pr ocess involves forming long piles turned by specially designed machines. Typically the rows are 1 to 2 meters high and 2 to 5 meters at the base. The piles are turn ed periodically to mix and introduce and rebuild bed porosity. This helps to insure that all the ma terial is uniform ly composted.

Composting improves the handling characterist ics of any organic resi due by reducing its volume and weight. Composting also kills pathogens and weed seeds. CompostingSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-108 reduces material volume thr ough natural biologica l action and produces a product that

enhances soil structure and benefits new grow th. However, wi ndrow composting operations also result in si gnificant VOC emissions.

1.2 EMISSION FACTORS AND EMISSION INVENTORY

1.2.1 BIOLOGICAL PROCESSES ARE CO MPLEX, NOT WELL-UNDERSTOOD

Unlike other traditional stati onary sources (many of which are combustion sources for which there is a very good understanding of emissions), agriculture sources are biological sources that c onsist of hundreds of differ ent VOCs among other major pollutants. Perhaps the most important finding of all is t hat CAFs are extraordinarily complex sources of air emissions, varying not only season to season, but from CAF to CAF, and from place to place within a CAF. Emissions can vary substantially depending on weather, types of feed, and m anagement styles along with many other factors. The same methodologies and standar ds used to establish emissions from traditional stationary sources cannot be used in determining the emissions from CAFs. Development of strategies to reduce envir onmental impacts of animal agriculture requires a better understanding of the mechanism s involved in the production, emission, and consumption of ammonia, odors, and greenhouse gases. In order to understand and ultimately reduce the negative impacts of these gaseous emissions, it is important

to understand the circumstances under which t hey form. Understanding the sources

and mechanisms of these emissions is a fi rst step to developing effective control strategies.

However, as discussed earlier, prior to January 1, 2004, the only available emission factor for dairies, swine, rabbits, horses, sheep, and goats was based on a metabolism study conducted in 1938 by Benedi ct and Ritzman. No other data was availa ble at that time. Since 2004, multiple studies have been performed, each subsequent study providing more insight into how the biology of the animals and their waste plays a large role in emission production. Although numerous studies have been completed in evaluating the emissions profile from CA Fs and a significant amount has been learned through this process, much is still not well understood. Each new study performed sheds new light in regards to how the different biological factors effect emissions.

1.2.2 STATE OF THE SCIENCE

Due to the relatively new status of CAFs as a regulated stationary source, the body of scientific knowledge that is useful in underst anding CAFs’ impact on air pollution is not as well established compared to other tr aditional stationary sources under the jurisdiction of the District. Even afte r the adoption of Rule 4570, the science significantly lags in comparison to other stationary sources. New scientific findings characterizing and quantifying dairy, poultry, and other animal emissions and possible

control measures are still bei ng developed and completed. The District developed RuleSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-109 4570 using relevant findings from previous and on-going research efforts as they were finalized, published, and peer-reviewed. Thes e include, but are not limited to:

• A study at UC Davis, led by Dr. Frank Mitloehner, which focused on emissions from

cows housed in environmental chambers to evaluate the emissions produced directly from cows and their fresh manure.

• A study at two operating dairies in t he San Joaquin Valley, led by Dr. Chuck Schmidt, in which measurements were made at various locations at the dairies, including the corrals and turnouts, bedding areas, lagoons, feed storage areas, flush lanes, and bunker feed.

• A study by Dr. Schmidt to validate the effectiveness and capture efficiency of using flux chambers that were used to quant ify emissions in the dairy studies.

These studies have provided many findings t hat provided a better understanding of the

emissions at CAFs.

1.2.3 EMISSION FACTORS

Accurate Emission Factors are needed in or der to calculate source emissions, reductions, and cost effectiveness of control m easures. However, prior to January 1, 2004 (the date the exemption was lifted from agriculture sour ces), the only available emission factor for dairies, swine, r abbits, horses, sheep, and goats was based on a metabolism study conducted in 1938 by Benedi ct and Ritzman. This study measured methane from animals including an elephant, a horse, seven Holsteins, four Jerseys,

and a Hereford cow.

To address the need for better science, the Dis trict, other regulatory agencies, industry and the scientific community put forward multiple research projects to close the gap on the emissions data. This study and the subsequent research papers were the most current published and reviewed source of em ission factors for several species during the Rule development process. Although multiple studies were completed in time for Rule 4570 development that proved useful, a significant amount of additional questions were raised and even more data gaps still rema in. Several most recent articles have reported different emissions from these operations and emi ssion sources. However,

those emission factors tend to be incons istent, possibly due to variation between facilities, and are not complete and have yet to be vetted by District Staff. As a note, the District is reevaluating the emissions fr om dairy and cattle operations taking into account all the latest studies completed. This effort will be taking place over the next

several months.

1.2.4 EMISSION INVENTORY

Staff utilized the 2002 USDA census, industry data, and California Air Resources Board documents to estimate the VOC's emitted by CAFs in the SJVAB. The methodology is further explained below; Tabl e 1 summarizes the results.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-110 Table 1: Total 2005 VOC Emissions from CAFs in the SJVAB

VOC Emission Factor (lb/hd/yr) Total VOC Emitted by CAFs (tons/day) Total VOC Emitted by Large CAFs (tons/day)

Milk Cows 21.00 51.28 36.92

Beef Cattle 11.90 2.80 2.66

Other Cattle 8.30 15.56 14.79 Poultry 7.20 3.54 2.16

Swine 1.00 0.57

Other Animals 6.60 0.00 0.00

Total Animals 74.57 57.09

1.2.4.1 Dairy

Staff utilized the California Department of Food and Ag (CDFA) report entitled

“ California Agricult ural Statistics 2004 ." The numbers are shown in Table 2. These numbers only include milking and dry cows, not heifers that have not calved or calves.

Table 2: Number of Milk a nd Dry Cows (CDFA Data 2004)

County 2002 2003 2004 Projected

2005* Fresno 86,115 90,345 95,577 99,878 Kern 85,830 98,478 121,147 126,599 Kings 146,545 153,475 162,656 169,976
Madera 49,899 57,099 63,934 66,811 Merced 224,895 224,734 237,854 248,557
San Joaquin 99,828 106,162 103,619 108,282

Stanislaus 164,558 177,432 178,420 186,449
Tulare 424,643 437,476 442,853 462,781 Total 1,282,313 1,345, 201 1,406,060 1,469,333
*The growth from 2002 to 2003 was approximately 4.9% and the growth from 2003 to 2004 was 4.5%. In order to be conservative, staff assumed a growth of 4.5% for 2004 to 2005.

In order to estimate the number of support stock at a dairy, ratios were developed using 216 dairy applications submi tted to the District. Based on those applications the following ratios, listed in Table 3, were dev eloped. These ratios represent the number of each type of animal.

Table 3: Ratio of Each Type of Dairy Cow to Milkers

Support

Animals to

Milkers Dry

Cows

to

Milkers Heifers (15- 24 mo) to

Milkers Heifers (7-14 mo) to

Milkers Heifers (4-6 mo) to

Milkers Calf (<4 mo) to

Milkers

107% 16% 34% 29% 16% 11%San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-111 Total

Animals VOC Factor
(lb/hd/yr)

from Table 4 Total VOC

Emissions

(lb/yr) Animal

Included In

Rule VOC Factor
(lb/hd/yr) Total VOC

from Animals

Included in

Rule ( lb/ y r ) Milk Cows 1,266,666 21.00 26,599,994 912,000 21.00 19,151,996 Dry Cows 202,667 11.90 2,411,733 145,920 11.90 1,736,448 Heifers (15-24) 430,667 8.30 3,574,533 310,080 8.30 2,573,663 Heifers (7-14) 367,333 7.20 2,644,799 264,480 7.20 1,904,256 Heifers (3-6) 202,667 6.60 1,337,600 145,920 6.60 963,072
Calves 139,333 6.20 863,866 100,320 6.20 621,984
Total Cows 2,609,333 37,432,525 1,878,720 26,951,418 Table 4: Total 2005 Dairy Animals in SJVAB Before the above ratios can be applied to the CDFA milk and dry cow numbers to

estimate a total number of head, the number of dry cows needs to be subtracted from the milk and dry cow numbers. Based on the ratios above, 16% of cows are dry cows when compared to milk cows, therefore the calculations would be as shown in the example below:

1,469,333/1.16 = 1,266,666 milk cows 1,266,666 x 0.16= 20 2,667 dry cows 1,266,666 x 0.11 = 139,333 calves

Now we can use the ratios in Table 7 to estima te all the other types of cows at a dairy.

Staff assumed, based on the ARB's June 23, 2005 Staff Report for Confined Animal Facilities page iii, that 72% of the dairy cows would be included in this regulation.

Furthermore, since the APCO Report noted that t he 19.3 lb/hd-yr factor did not consider all emission sources and that the majority of facilities have freestalls, in order to be conservative, Staff utilized the weighted emission factor of 21.0 lb/hd-yr listed on the District's web page for dairies.

1.2.4.2 Beef and Other Cattle

The following table includes other cattle fac ilities in the San Joaquin Valley, from a USDA California Agricultural Statisti cs 2004 Report and beef on feedlots from the

California Farm Bureau Federation. Staff assumed, based on the ARB's June 23, 2005 Staff Report for Confined Animal Facilities page 8, that 95 % of the beef cattle and other cattle would be included in this regulation. This is based on the assumption that a

similar number of beef and other cattle would be included in th is rule as feedlot cattle listed in the ARB Staff Report.

Furthermore, staff assumed that there were equal numbers of each type of heifers and

calves at the other cattle facilities theref ore, averaged the emissi on factors for heifers

and calves in order to obtain the emission fa ctor for other cattle. This was used to develop Table 9.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-112 Total

Animals VOC Factor
(lb/hd/yr)

from Table 4 Total VOC

Emissions

(lb/yr) Animal

Included In

Rule VOC Factor
(lb/hd/yr) Total VOC

from Animals

Included in

Rule ( lb/ y r )

Total Beef 184,050 11.10 2,042,955 174,848 11.10 1,940,807

Total Other Cattle 1,605,000 7.08 11,355,375 1,524,750 7.08 10,795,230

Total 1,789,050 13,398,330 1,699,598 12,736,037 Table 5: Total 2005 Beef and Other Cattle

Total

Animals VOC Factor
(lb/hd/yr)

from Table 4 Total VOC

Emissions

(lb/yr) Animal

Included In

Rule VOC Factor
(lb/hd/yr) Total VOC

from Animals

Included in

Rule ( lb/ y r )

La y ers 11,717,799 0.050 585,890 7,265,035 0.050 363,252

Broilers 47,608,059 0.025 1,190,201 29,540,054 0.025 738,501

Turke y s 8,071,297 0.100 807,130 4,728,720 0.100 472,872

Total 67,397,155 2,583,221 41,533,809 1,574,625 Table 6: Total 2005 Poultry Animals 1.2.4.3 Poultry and Other Animals

Staff obtained an estimate of the number of layers in t he SJVAB from USDA census data. Since the ARB Propos ed Emission Methodology assume d no significant growth for layers, staff assumed that the layer population has been relatively constant since 2002. Based on ARB June 23, 2005 Public Hearing to Cons ider the Adoption of a Regulation Establishing a Defi nition of BACT, staff assumed that 62% of the layers are housed in large CAFs.

Staff obtained estimates of the number of broilers and turkeys in the SJVAB from the California Poultry Federation. Based on this information, staff determined the number of turkeys and broilers housed in large CAFs.

Staff obtained an estimate of the number of rabbits, goats, sheet, and swine in the

SJVAB from the USDA census data. Since ARB Proposed Emission Methodology assumed no significant growth for non-cattl e, staff assumed that the non-cattle population has been relatively constant sinc e 2002. Based on the District's permit database, staff found that approximately 90,000 swine ar e housed in large CAFs and no rabbits, goats, or sheep in the SJVAB are housed in large CAFs. This is

illustrated in Table 7.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-113 Total

Animals VOC Factor (lb/hd/yr)

from Table 4 Total VOC

Emissions

(lb/yr) Animal

Included In

Rule VOC Factor (lb/hd/yr) Total VOC

from Animals

Included in Rule (lb/yr)

Rabbits 3,903 0.190 742 - 0.190 -

Goats 34,160 0.960 32,794 - 0.960 -
Sheep 273,800 0.960 262,848 - 0.960 -

Swine 158,536 4.600 729,266 90,000 4.600 414,000

Total 470,399 1,025,649 90,000 414,000 Table 11: Total 2005 Other Animal s

1.3 LACK OF AIR POLLUTION CONTROLS BEFORE RULE 4570

As discussed earlier, prior to January 1, 2004, agriculture sources were exempt from air permitting requirements in California. Theref ore, prior to 2004 and in most cases prior to the passage of Rule 4570 in 2006, agricultu re sources had practically no pollution control systems in place. Agriculture s ources were primarily managed and operated completely at the operator’s discretion wit hout any thought to t he effects of their operation to air emissions. In addition, as di scussed above, prior to recent studies, the science was completely lacking which would a llow for any reasonable control to be used that would effectively reduce VOC emissions.

The District’s efforts to develop Rule 4570 sparked new scientific research into understanding the emissions prof ile and potential strategies to reduce emissions. A great deal of research has already been conducted and research is ongoing and will

continue far into the future.

With the changes to the CH&SC and the result ing loss of exempti on from permitting of agricultural sources of air pollution ( CH&SC 39011.5 (b)), new or expanded CAFs are now required to undergo the BACT process as a requirement under New Source Review (NSR). District Rule 2201 (New and Modified Stationary Source Review Rule) implements state and federal requirements under Title I, Part D and requires BACT for new sources or sources undergoi ng modification with emission increases that are above the de minimis value (two (2) pounds per day of VOC). BACT provisions would apply to sources which are subject to District permitt ing requirements and that emit or may emit one or more affected pollutant, ei ther as a “major” source subj ect to Title V permitting or

as a source with actual emissions which are 50% or more of any major source

thresholds.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-114 2 OVERVIEW OF RULE 4570

2.1 REASONS FOR IMPLEMENTATION

2.1.1 FEDERAL AND STATE PLANNING REQUIREMENTS

In mid-2003, the San Joaquin Valle y Air Pollution Control Distr ict started the process of revising its attainment plan to meet t he federal one-hour ozone standard. The July 2003 workshops for the Extreme Ozone Attainment Demonstration Plan included a

control measure for confined animal feedi ng operations. The Plan was adopted in

October 2004 and established a CAF rule adoption deadline of 2 nd Quarter 2006, and set a 2010 VOC emission reduction goal of 15. 8 tons per day based on a 61.3 ton per day emission baseline.

Since Rule 4570 was a control measure in t he District’s 2004 1-Hour Ozone Plan, it is subject to Federal Register, Clean Air Act (CAA), and California Health and Safety Code (CH&SC) requirements. Additionally, despite the federal revocation of the federal 1- hour ozone standard, ant i-backsliding provisions commit the District to develop all

control measures listed in the 2004 1-Hour Ozone Plan (Federal Register Volumes 69 and 70). These federal and state planni ng requirements are summarized in the following table.

Federal and State Planning Requirements

and District 2004 1-Hour Ozone Plan Commitments

Subject Reference Requirement

RACT CAA 182(b)(2) and 182(f) Ozone attainment plans sha ll assure that reasonable available control technology (RACT) for volatile organic compounds (VOC) is in use at sources and on source categories at or above the RACT

threshold.

RACT

Threshold 70 Federal Register

30592-30596 The applicable RACT threshol d for control measures shall be the threshold in effect on June 15, 2004. The Districts threshold on June 15, 2004 was 10 tons per year (tpy ) for VOC. Ther efore, 10 tpy was

the RACT threshold for Rule 4570.

Timeline CAA Section 172(c)(1) Ozone attainment plans shall implement control measures as expeditiously as practicable, and provide for attainment.

Antibacksliding 69 Federal Register 23955 Districts shall develop all c ontrol measures listed in

the one-hour Ozone Plan until the District isSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-115 Federal and State Planning Requirements

and District 2004 1-Hour Ozone Plan Commitments

Subject Reference Requirement

designated as attainment for the 8-hr NAAQS.

BARCT CH&SC 40919(a)(3)

Ozone Plan Ozone attainment plans should provide for best

available retrofit technol ogy (BARCT) for existing permitted sources.

Feasible

Controls CH&SC 40914(a)(2) Ozone attainment plans should include "all feasible

control measures."

Deadlines Ozone Plan Rule adopti on by the 2nd quarter of 2006.

Reductions Ozone Plan The rule shall reduce VOC emissions by at least 25% from the baseline by 2010. Twenty-five percent

of the baseline used for t he Ozone Plan (63.1 tpd) is 15.8 tpd.

In addition, the California Health and Safety Code (CH&SC) Section 40914(a)(2) states

that ozone attainment plans should include All Feasible Control Measures ( AFCMs). The ARB interprets “every feasible contro l measure to mean that, at a minimum, a district considers regulations that have been successfully implem ented elsewhere. They should also consider going beyond what has already been accomplished by evaluation of new technologies and innov ative approaches that may offer potential emission reductions. Further, districts should consider not only technological factors, but also social, environmental, economic (e .g., cost effectiveness), and energy factors which prevail in the District, al ong with the resources realistica lly available to the district to adopt, implement, and enfor ce the measures.”

In the context of rule development, Distric t staff considers AFCM to mean that each rulemaking project seeks to obtain as much emission reduction from the rule’s source category as is expeditiously practicable, technologically feasib le and economically reasonable, as determined by the District’s Gove rning Board. To this end, District staff compares the current emission limits or control technology agai nst what limits or control technology has been promulgated in other districts, as well as reviewing the federal, state, and local BACT clearinghouses for the most recent control technology available for the source category. The information obtai ned through this research is used to craft the proposed emission limits or imposed control technology.

2.1.2 STATE LAW – SB 700

On September 22, 2003, Governor Gray Davi s signed into law Senate Bill 700. The bill amended air pollution control requirements in the California Health and Safety Code to include requirements for agricultural sources of air pollution. Agricultural sources of airSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-116 pollution were the focus of the bill for tw o main reasons. Firs t, California law had previously exempted these s ources from requirements to obtain air permits. This

resulted in a conflict between state and federal law, and California faced sanctions if it failed to correct the problem. Had t he bill not been signed, new and expanding

businesses in the state would have faced si gnificant and costly hurdles to obtain air permits required under federal law, and the state would have lost billions of dollars in federal transportation funding.

The bill did six main things: (1) It defines "agricultural source" in state law; (2) It

removes the restriction from state law that prevented air di stricts from requiring permits for agricultural sources; (3) It est ablishes specific permitting and exemption requirements for agricultural sources; (4) It requires emission control regulations in

areas that do not attain Nati onal Ambient Air Quality Standards for PM10; (5) It requires permits and emissions mitigation for Confined An imal Facilities (CAF s) that are defined by ARB as "large" (based on a review of current scientific data about emissions from CAFs and the impact of those emissions on a ttainment of ambient air standards); and (6) It requires CAPCOA to compile a clearinghouse of information about available emissions control and mitigation for agricultural activities. It is impo rtant to note that the bill did not remove the exemption for agr icultural operations fr om the general odornuisance provisions of the Health and Safety Code. 7

In addition to satisfying District Planning commi tments, Rule 4570 was also designed to fulfill the following requirem ents created by SB 700.

SB700/California Health and Safety Code Requirements

Subject CH&SC

Sections SB700 / CH&SC Requirements

Large Confined Animal Facility Definition (large CAF) 40724.6(a) The District shall use the "large CAF" definition developed by the California Air Resources Board (ARB).

Deadline 40724.6(b) By July 1, 2006 the District shall adopt, implement, and submit for inclusion in the state implementation plan a rule requiring owners of "large" CAF to obtain a permit. Degree of Mitigation Required 40724.6(d)(1)(B) Best Available Retrofit Control Technology (BARCT) is the degree of mitigation required of large CAF.

Compliance

Schedule 40724.6(d)(4) Owner/operators shall implement control measures within one year of the permit

issuance date.

Permit Requirements

to be Included 40724.6(d) 1. The permit shall include an emission mitigation plan that demonstrates use of BARCT,

7 CAPCOA White Paper on SB700San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-117 SB700/California Health and Safety Code Requirements

Subject CH&SC

Sections SB700 / CH&SC Requirements

in the Rule 2. The District s hall provide for a 30-day public noticing and commenting period for proposed permits, (The District shall review and update permits at least once every three (3) years, 3. The District shall act on completed permit applications within six (6 ) months of receipt, 4. The permit shall include sufficient information to prepare an emission inventory of all regulated air pollutants emitted from the facility, and 5. The owner/operators of large CAF shall submit a permit application within six (6)

months of Rule 4570 adoption.

Impact

Assessment 40724.6(d) Prior to adopting a rule, the District shall analyze the following: 1. Category, number, and size of facilities affected, 2. Nature, quantity, and significance of emissions in adversely affecting public health, the environment, and attainment of air quality standards, 3. Emission reduction potential, 4. Costs, 5. Impact on employment and the economy, 6. Alternative controls, and

7. Technical and Prac tical Feasibility.

2.1.2.1 RULE DEVELOPMENT PROCESS

As part of the rule development process, District staff conducted public scoping meetings in April 2005, public workshops and Socioeconomic Focus Group meeting in March 2006 in order to present, discuss, and solicit comments on Rule 4570. In addition to the workshops, staf f met with representatives of the impacted industries, and control technology vendors to receive comments on the technical aspects and compliance costs of the proposed rule. The comments received from the public, affected sources, California Air Resource s Board, and United States Environmental Protection Agency during the public workshop process and technical consultation meetings were incorporated into the ru le as appropriate. Comments received and District responses are discussed in Appendi x A of the Final Draft Staff Report.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-118 Rule 4570 and the Final Draft Staff Repor t including the analyses mandated by CH&SC were published prior to a public hearing on June 15, 2006 for the District Governing Board to consider the adoption of the rule. T he notice of the public hearing for this rule project was published in a general circulat ion newspaper in eac h of the eight San Joaquin Valley counties, and was mailed to a ffected sources and interested parties. The public notice solicited written comments to be submitted by mail, and identified the name and telephone numbers of the District staff that could answer questions and respond to comments. The June 15, 2006 adopt ion schedule satisfied the requirement

of the CH&SC for the District to a dopt a regulation by July 1, 2006.

2.1.2.2 Main Issues Addressed in the Rulemaking Process

2.1.2.2.1 Difficulty of Cont rolling Fugitive Emissions

Because of the large amount of land required to sustain the growth of crops and raising of animals, agricultural facilities, by their nat ure, tend to be very ex pansive. Agricultural production areas can span over a hundred ac res with air contaminants primarily produced as fugitive emissions from multip le sources and operations at the facility. Fugitive emissions are defined as “those emissions which could not reasonably pass through a stack, chimney, vent, or other functionally- equivalent opening.” Examples of fugitive emission sources at agricultural fa cilities include enteric emissions from

livestock and emissions from animal waste that is applied to land.

As discussed in above, it was demonstrated that the majority of emissions from confined animal operations are fugitive. The fugitive nature of the emissions from agricultural sources and their expansive size impose challenges and limitations to the type of controls that can be feasibly applied to reduce emissions. Unlike other stationary sources, where the majority of emissions are collected and released through a chimney, pipe, vent, or stack, which facilitates the use of traditional emission controls (e.g. fabric filters, catalysts, scrubbers, etc.), emissions from agric ultural sources are spread out over large areas and are very dilute at the point of release. These emissions cannot reasonably be captured since ca pture of these emissions would entail monumental changes, which have not yet been developed and are likely infeasible, to the methods that are currently used for agricultural producti on. An additional consideration is that, unlike traditional stationary sour ces, potential adverse affects to livestock must also be considered when changes in production methods are undertaken, such as those needed to capture emissions.

As mentioned, it would be exceedingly di fficult to design and construct a system capable of capturing the majo rity of emissions from these sources without even considering control of these emissions; howev er, even if it were possible to capture most of the fugitive emissions, the extremely dilute nature of the emissions emitted from animals at agricultural sources would still cause the use of traditional point source

controls to be infeasible and ex ceedingly expensive. Becaus e of these constraints, the District has adopted an approach in which the best management practices are utilized

to minimize emissions from confined anima l facilities prior to their release.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-119 2.1.2.2.2 Considerations for Animal Health and Food Safety

Emission control mitigation measures, espec ially those that will be applied to animals, must take into consideration the health, welfare and productivity of the animals, food safety, and bio-security issues. Animal deat hs, expenses for treatme nt or disposal of dead animals, as well as loss of productivity due to poor animal health can all be devastating to a farmer. Government agencies such as the USDA are also deeply

concerned about animal health and the related food safety and bio-security issues that affect not just individual farmers but also the entire farm industry and the public. Diseases such as foot and mouth disease, m ad cow disease, or avian flu are all of grave concern to the govern ment because of their ability to destroy the entire farm industry and/or cause enormous loss of human life. In addition, animal welfare is a significant public issue, as demonstrated by the recent pass age of Proposition 2 8 by voters in California. While in the past, product boycotts and bad publicity were the main threats linked to animal welfare issues, t he passage of laws such as Proposition 2 brings the additional possibilit y of litigation that can put farmers out of business.

It is therefore critical for fa rmers to have the flexibility to decide the kind of mitigation measures that will work best for their specific operation by taking into consideration animal health and welfare, producti vity, food safety and overall bio-security issues, while at the same time achieving the required leve l of emission control. For instance, some dairy farmers have pointed out that high moistu re levels in animal pens increase cases

of mastitis infections in thei r herds. In such cases, it w ould be unfair to compel farmers to implement mitigation measures that incr ease moisture levels in their animal pens because of the potential harm to animal hea lth, cost of treat ment and loss of productivity. Instead, an option to implement another mitigation meas ure that achieves

the same level of emission control should be provided. On the other hand, if certain mitigation measures such as housing dairy co ws in completely enclosed barns were to be required across the board, many farmers , depending on case-by-case factors such as size of operation, location or financial resources, may find t hemselves exposed to

serious animal welfare issues and devastating litigation.

8 Proposition 2 was a California ballot proposition in that state's general election on November 4

, 2008

. known as the Standards for Confining Farm Animals initiative. The official title of the statute enacted by the proposition is the Prevention of Farm Animal Cr uelty Act. The proposition adds a chapter to Division

20 of the California Health and Safety Code to prohibit the confinement of certain farm animals in a

manner that does not allow them to turn around fr eely, lie down, stand up, and fully extend their limbs. The measure deals with three types of confinement: veal crates, battery cages , and sow gestation crates

.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-120 2.1.2.2.3 Considerations fo r the Wide Variety of CAFs

Due to the different methods of confi nement and associated manure management, for any animal type there is no single design t hat encompasses every CAF. Consequently,

a universal method to control emissions from all CAFs is not only not available, but not suitable. In fact, multiple measures are required to implement BARCT for this source category. The design and operation of each CAF varies depending on animal type, sub-regional climatic conditions, subsurface geologic structure, business practices, and preferences of the owner s/operators. This is why the Dis trict structured the rule such that facilities must comply with rule r equirements utilizing management practices and machinery that owners/operators already have access to. This also acknowledges that not all facilities can implement the same opt ions due to infrastructure, conditional use permits, water board permits, soil types, prod uction contracts, and other limitations.

2.1.2.3 Rule 4570 is not arbitrary nor capricious

CAFs are newly-regulated and the supporting science for air emissions from these sources is still developing. In the miti gation measure menus of District Rule 4570,

District staff considered all of the operations within each type of CAF, the available information about emission reduction potential, as well as the feasibility and cost of implementing required mitigati on measures. CAF operators c ontrol emissions in every phase of the CAF operation. Many of the assumptions were based on studies and data showing that these practices would result in some reduction, but there was insufficient science to know exactly what the reductions would be. The menu approach of Rule 4570 allows flexibility as the science of ai r emissions from CAFs evolves. The mitigation measures can be further focused on the operations that are shown to have the highest emissions. Independently, the miti gation measures themselves can be revised or expanded to includ e those that are most efficient and cost-effective each

CAF emission source.

In calculating the cost effectiveness of Rule 4570, District staff determined cost effectiveness for those Class One mitigation m easures that had the lowest cost. Class Two mitigation measures, although having potentially higher emission reduction potential, were not included in the cost effect iveness calculation because they are costly to implement and are consider ed beyond the BARCT level of control. However, the Class Two mitigation measures were included in the mitigation measure menus in order to encourage voluntary practice s exceeding BARCT. It is r easonable to assume that CAF operators would opt not to use those me asures so expensive that the cost far outweighs annual profits. Distr ict staff calculated the potentia l emission reduction of its rule based on the likelihood that only the c heapest options will be chosen. This is a prudent and reasoned approach, neit her an arbitrary nor a capricious one. This opinion was echoed in a recent court decision by the California Fifth Appellate District in

Association of Irritated Citiz ens vs. San Joaquin Valley Air Pollution Control District (2008).San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-121 2.2 REQUIREMENTS OF RULE 4570

2.2.1 APPLICABILITY

Rule 4570 controls VOC emissions from “Lar ge Confined Animal Facilities,” as defined by the California Health & Safety Code and the Air Resources Board. According to CH&SC 39011.5(a) and 39011.5(a)(1) a CAF is defined as “a source of air pollution or a group of sources used in the...(fill in the mi ssing text – don’t summarize) raising of fowl or animals located on contiguous property under common ownership or control...including, but not limit ed to, any structure, building, installation, barn, corral, coop, feed storage area, milking parlor, or system for the co llection, storage, treatment, and distribution of liquid and solid manure, if domesticated animals are corralled, penned, or otherwise caused to remain in rest ricted areas for comm ercial purposes and feeding is by means other than grazing.”

The ARB was required by CH&SC 40724.6 to revi ew all available scientific information, including, but not limited to, em ission factors for confined anim al facilities; the effect of those facilities on air quality in the basin; and other relevant scientific information and to develop a definition for a “large” confined animal facility. ARB's board adopted the following thresholds for a large CAF, based on air emissions from CAFs:

ARB Large CAF Thresholds Livestock Category Number of Animals Dairy 1,000 lactating cows Beef Feedlots 3,500 beef cattle Other Cattle Operations 7,500 ca lves, heifers, and other cattle Chickens-Broilers & Egg Layers 650,000 head Turkeys 100,000 head Swine 3,000 head Sheep and Goats 15,000 head
Horses 2,500 head
Ducks 650,000 head

Other Livestock Not Prev iously Mentioned 30,000 head
Source: http://www.arb.ca.gov/regact/l caf05/lcaf05.htm accessed 2/24/06

2.2.2 EMISSION CONTROL REQUIREMENTS

Rule 4570 requires multiple mitigation meas ures from all large CAFs covering the following CAFs: Dairy, Beef F eedlots, Other Cattle, Swine, Poultry, and various other smaller operations. Each of these facilities consists of multiple sources of emissions within the facility. Since these facilities generally cover a large area and have different processes, a single mitigation measure or technology is generally not sufficient in reducing overall emissions from the facility. Rather than allow facilities to select a

number of measures at the em ission source of their choosi ng, Rule 4570 specifically requires a certain number of mi tigation measures at the majority, if not all, of the emission sources. Mitigation measures requi red by Rule 4570 have been tailored forSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-122 each source of emission, thereby ensuring that the overall emissions from a facility are reduced rather than from only a part of the facility, which w ould be the case if that was left as an option in the Rule. The current methodology in Rule 4570 provides for the greatest overall contro l from the facility.

Rule 4570 recognized the following five source s for all of the CAFs: Feed, Housing, Solid Waste, Liquid Waste and Land Applicat ion of Manure. Rule 4570 requires each CAF to implement a certain number of mi tigation measures (ranging from 1 to 8 measures) for each of these sources. Rule 4570 also disti nguishes between the different types of housing configurations (f reestall vs open corrals) for the cattle and the different types of feed (feed stuff vs silage) and as such requires additional mitigation measures for each type. In addition, dairies are also required to implement a mitigation measure for the milking parlor. By requiring mitigatio n measure(s) for each source of emissions at a facility, Rule 4570 ensures that reductions are achieved throughout the entire facility.

Rule 4570 requires operators of a CAF to im plement multiple VOC mitigation measures for the major emission sources at each facilit y. The sources covered by the Rule and the number of measures required are shown in the following table. This menu approach not only provides flexibility to facilities to select measures that are suitable to their particular operation, but the requirement to implement multiple mitigation measures in each source category results in a larger emission reduction.

Summary of the Minimum Number of VOC Mitigation Measures Per Animal Type and Area Compared to Total Number of Options Area Dairy Beef Other

Cattle Swine Poultry

Feed 4 of 8 5 of 8 5 of 8 5 of 12 5 of 10 Silage 1 of 6 1 of 6 1 of 6 0 of 0 0 of 0

Milk Parlor 1of 3 0 of 0 0 of 0 0 of 0 0 of 0 Housing 8 of 26 7 of 15 7 of 23 5 of 10 4 of 17

Solid Manure 2 of 8 1 of 8 1 of 8 1 of 8 1 of 8 Liquid Manure 1 of 11 1 of 11 1 of 11 1 of 11 1 of 11 Land Application 2 of 7 2 of 7 2 of 7 2 of 7 0 of 0

TOTAL 19 of 69 17 of 55 17 of 63 14 of 48 11 of 46

2.3 ECONOMIC COSTS OF RULE 4570

The socioeconomic analysis within the Distric t’s Staff Report indicated that, although there are approximately 247 la rge CAFs subject to Rule 4570 that would need to implement additional mitigation measures to comply with rule requirements. The table below summarizes the number and type of CAFs that would need to implement additional mitigation measures to comply with the rule and its estimated annual compliance costs.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-123 Summary of Estimated Total Annual Compliance Cost

Type of CAF Number of
CAFs Estimated Total Annual Compliance

Costs Dairy 233 $18,324,074 Beef Feedlots 6 $590,112 Other Cattle Facilities 5 $7,147,266 Swine 3 $540 TOTAL 247 $26,061,922

Source: District and stakeholder comments

The socioeconomic impact analysis also show ed that the total annual compliance costs represented 9.6 percent of the net profits of la rge dairies, 13.0 percent of the net profits of large cattle operators (beef feedlots), 13. 5 percent of the net pr ofits of other large CAF cattle stakeholders, and <1 percent of the net profits for large CAF swine stakeholders;. Annual compliance costs associated with the District’s costs for impacted “other cattle industries” exceed the thre shold of significance, resulting in direct employment impacts of approxim ately 17 jobs. Factoring in indirect impacts associated with the direct loss of 17 jobs, the rule coul d result in the loss of an additional 23 jobs across different industries, for a total job impact of 40 jobs.

By far, the largest cost involved with Rule 4570 will be borne by dairy operators. This section of the report discusses the methodology employed in calculating costs borne by affected dairy farms. The sa me methodology was used for beef feedlots, other cattle facilities, and swine facilities.

It is important to note that agriculture in general, and livestock products in particular, are “price takers”, meaning that they have little ability to set price of their goods, and little ability to pass on costs to the consumer. As prices of basic goods like beef increase, consumers may switch to other products, such as poultry. Alternatively, consumers might continue to buy beef, but they may switch to products from other regions or states that could be less expensive.

2.3.1 EXAMPLES OF DESIGN/OPERAT IONAL INCOMPATIBILITY WITH

CONTROLS

As discussed above, due to the different methods of confinement and associated manure management, there is no typical CA F. The design and operation of a CAF varies depending on animal type, regional clim atic conditions, business practices, and preferences of the ow ners/operators. Not a ll of the mitigation measures included as an option in Rule 4570 can be reasonably adopted by all facilities due to infrastructure, conditional use permits, water board permits, soil types, produc tion contracts, and other limitations. This is why the District structur ed the rule such that facilities comply with rule requirements utilizing management prac tices and machinery that owners/operators already have reasonably available to them. Examples of some of the mitigation measures that may not be adaptable to all facilities due to facility limitations are

discussed below:San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-124 Mitigation Measure: “ Collect leachate from the silage piles and send it to a waste treatment system such as a lagoon at least once every 24 hours ”

Many existing facilities were not initially designed to handle or collect the leachate from the silage piles. Although Rule 4570 is a retrof it rule, for many of facilities it is not

reasonable to retrofit their ent ire facility to accommodate this mitigation measure. Obstacles in achieving this mitigation measure are listed below:

1. The Lagoon placement is on the opposite side of the silage piles, making it almost impossible to transfer the sm all amount of leachate to the lagoon system 2. Grading and transfer system ar e non-existent and would require a significant amount of c onstruction and demolition 3. This mitigation measure generally works well with a concrete pad and would require a large pad generally an acre in size to be poured

Therefore, Rule 4570 consis ts of multiple mitigation measures and operators are required to choose measures that are appropr iate for their method of operation, to

ensure emission reductions.

Mitigation Measure: “ Use a dry animal waste handling syst em, such as scraping, instead of a liquid animal waste handling system, su ch as a flush system”

A significant portion of dairies in the Valley are designed around a flush system and a considerable amount of cost goes into buildin g such a dairy. There are also several air benefits in having a flush system as long as mitigation measures are implemented. Therefore, a dairy that has invested a signifi cant amount of capital and has elected to operate their dairy as a liq uid manure management will not be able to change the makeup of their entire dairy by c onvert it over to a scrape syste m. As stated earlier, Rule 4570 was specifically structured so that fac ilities would comply with the rule regardless of the type of facility or manure management system.

There are specific measures available for facilities that have a liquid manure management system, just as there are measur es for scrape systems. However since the flush dairies generate waste at the l agoons, a mitigation measure is also required under the liquid manure mitigation category to ensure that the emissions associated from that system ar e also mitigated.

Mitigation Measure: “Use non-animal waste-based be dding and non-separated solids based bedding for at least 90% of the beddi ng material, by weight , for freestalls (e.g. rubber mats, almond shel ls, sand, or waterbeds)”

This measure requires that a non-animal waste bedding material be used in lieu of manure or separated solids. Ho wever, not every dairy in the Valley has access to non-San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-125 manure based material due to the limited res ource of these materials (almond hulls, etc).

Sand on the other hand has many disadvantages such as clogging of main drains and pipes including breakdowns from the consi derable amount of w ear and tear on pumps and equipment. If the infrastr ucture does not exist to handl e this material it is unreasonable to implement this mitigation measure; which is why Rule 4570 consists of multiple mitigation measures to allow operators the flexibilit y to choose measures that are appropriate for their method of operation, while still ensu ring emission reductions.

Mitigation Measure: “Use lime or a similar ab sorbent materi al in the pens according to the

manufacturer's recommendations to minimize moisture in the pens.”

Lime is extremely costly and in many case s not feasible due to soil quality and water quality issues. Therefore, while this mitigat ion measure may work for one facility it may

not work for another.

Mitigation Measure : “Manage the facility such that ther e are no lagoons at the facility.”

Considering the uniqueness from one facility to another, Section 5.13 of Rule 4570 also

allows CAF facilities to submit an emissi on mitigation plan demonstrating facility wide

reductions of at least 30% in lieu of se lecting the required mitigation measures.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-126 

### 3 REVIEW OF FEDERAL RACT REQUIREMENTS

3.1 FEDERAL APPLI CABILITY OF RACT

The Clean Air Act (CAA) Secti on 182(b)(2) states that ozone at tainment plans shall assure

that ract for volatile or ganic compounds (VOC) is app lied at certain sources.

“The State shall submit a revision to the applicable implementation plan to include provisions to require the implementation of reasonably available control technology under section 172(c)(1) of this title with respect to each of the following:

(A) Each category of VOC sources in the area covered by a CTG document issued by the Administra tor between November 15, 1990, and

the date of attainment.

(B) All VOC sources in the area covered by any CTG issued before November 15, 1990.

(C) All other major stationary sources of VOCs that are located in the

area.”

Because EPA has not issued a CTG for Confined Animal Facilities, the only applicable provision above for the San Joaquin Vall ey, is the need for RACT to be applied to “major stationary sources.” Because the San Joaquin Valley Air Basin is classified as an extreme ozone area, “major sources” are t hose that generate more than 10 tons per year of NOx or VOC.

3.2 DEFINITION AND STRINGENCY OF RACT

Although the Clean Air Act itself does not define Reasonably Available Control Technology, 40 CFR 51.100(o) defines RACT as:

”devices, systems, process modifications, or other apparatus or techniques that are reasonably available, taking into acc ount (1) the necessity of imposing such

controls in order to attain and maintain a national ambient air quality standard; (2) the social, environmental, and economic impact of such controls; and (3) alternative means of providing for attainment and maintenance of such a

standard.”

The foregoing definition applies to a specific federal provision regarding approval of extension requests for attainment plans fo r secondary air quality standards, but in the absence of a more definitive regulatory description, it is concise and useful. EPA also

defined RACT in the Strelow memorandum 9 as:

9 The Strelow RACT Memorandum, published in BNA Environmental Reporter, December 9, 1976, pages 1210-1212San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-127 “the lowest emission limitation that a particular source is capable of meeting by the application of cont rol technology that is reasonably available, considering technolog ical and economic feasibility”.

3.3 PURPOSE OF FEDERAL RACT

The Clean Air Act requires RACT for certain sources in all nonattainment areas nationwide, regardless of the seve rity of the ozone problem.

“172(c) Nonattainment plan provisions

The plan provisions (including plan items) required to be submitted under this part shall comply wit h each of the following:

(1) In general

Such plan provisions shall provide fo r the implementation of all reasonably available control measures as expediti ously as practicable (including such

reductions in emissions from existi ng sources in the area as may be obtained through the adoption, at a mi nimum, of reasonably available control technology) and shall provide fo r attainment of the national primary ambient air quality standards.”

From this section, it is clear that RACT is intended as the minimum level of control that

all ozone nonattainment areas must achieve for ex isting sources. It is also clear that RACT not intended as the only level of c ontrol needed for all nonattainment areas to attain the ozone standard. Two key conclusi ons are drawn from the section above: first, states must adopt RA CT for existing sources regardless if they are needed for attainment, and second, states may need addi tional measures beyond RACT to attain

the standard. This second conclusion lead s to the understanding that RACT is not intended to be the most stringent level of cont rol in an area’s attainment strategy.

In the greater context of air pollution contro l levels, RACT is understood as the “floorlevel” of air pollution controls, not the “ceilin g-level.” More effective levels of emissions

control are termed Best Ava ilable Control Technology (BAC T) and Lowest Achievable Emission Rate (LAER). BACT and LAER are r equired for new sources, and for existing sources undergoing modification. Under stat e and federal air pollution programs, new facilities face more stringent pollution contro l requirements than existing facilities, with the understanding that better controls can be more easily implemen ted before a facility is built, than after it is built. Ne w sources must generally implement BACT 10 and

10 Federal regulations for permitting new facilities require Best Available Control Technology (BACT) for new sources in attainment areas, and Lowest Achievable Emission Rate (LAER) – a generally more stringent level –for new

sources in nonattainment areas. LAER differs from BACT in that economic costs are not considered for candidate

LAER controls that are considered “Achieved in Practice.” Un der California state law, the District is required to apply “BACT” for new sources under essentially the same requirements as federal LAER. The District’s “BACT”

determinations thus fulfill the f ederal LAER requirements.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-128 existing sources must implement a less stri ngent level of control such as Reasonably Available Control Technology (RACT). A dditionally, California law establishes an

intermediate level of control that is the “bes t available” for “retrof it” to existing sources (entitled Best Available Retr ofit Control Technology – BARCT 11 ), recognizing that the state’s worst ozone problems demands more effective pollution co ntrol than what is usually considered “reasonably available.”

As discussed above, the purposes of BACT, RACT, and BARCT are different. BACT is designed to minimize the growth in futu re stationary source emissions with the installation of best available controls; RA CT is designed to reduce current stationary source emissions from existing sources with the application of reasonably available controls; and BARCT is designed to reduce cu rrent stationary source emissions even further with the application of best available retrofit controls. BACT is identified and prescribed in the permitting process on a case -by-case administrative basis. RACT and BARCT are developed on an industry-wide basis in the rule development process, which concludes with quasi-legislative ac tion by the District Governing Board.

3.4 RACT GUIDANCE FROM EPA REGION IX

A letter from EPA, Region IX 12 outlined documents that could be useful in establishing RACT. Those documents include EPA’s Control Techniques Guidelines (CTGs), Alternative Control Techniques (ACTs), New Source Performance Standards (NSPS),

National Emissions Standards for Hazar dous Air Pollutants (NESHAPs), EPA Best Available Control Technology (BACT) Cl earinghouse, California Suggested Control Measures (SCM) and RACT/Best Available Retrofit Control Technology (BARCT) determinations, regulations adopted in ot her Districts, and guidance and rules developed by other state and local agencies.

To date, EPA has not developed any federal regulations (NSPS, MACT, NESHAP) or guidance (CTG, ACT) specific to CAFs. Best Available Cont rol Technologies and regulations adopted in other dist ricts are discussed below.

3.5 ISSUES REGARDING FEDE RAL EXPECTATIONS FOR RACT

RACT is a “moving target.” Technology cons idered RACT at the time of SIP-approval has always been made obsolete by more effectiv e technology at a later date. This view of moving-target RACT requirements precl udes using only comparing CTGs/ACTs or simply relying on EPA SIP-approval of ru les as satisfying RACT requirements; therefore, other requirem ents must be considered.

11 California Health and Safety Code (CH&SC) 40406: ... "best available retrofit control technology" means an emission limitation that is based on the maximum degree of reduction achievable, taking into account environmental, energy, and economic impacts by each class or category of source.

12 United States Environmental Protecti on Agency – letter from Andrew Stecke l, EPA Region IX to Kurt Karperos,
ARB dated March 9, 2006 – RACT SIPSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-129 It should also be noted that since District rules usually fulfill BARCT requirements for state purposes, and the control technology est ablished by a BARCT rule is the most

effective retrofit control fo r the existing emission category; it can be assumed to, at a minimum, satisfy RACT require ments, if not go beyond RACT.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-130 4 DEMONSTRATION THAT RULE 4570 SATISFIES RACT REQUIREMENTS

This section of the Document shows how Rule 4570 satisfies federal RACT requirements. It focuses on the three br oad elements that EPA generally reviews when evaluating a district rule for inclusion in the State implem entation Plan (SIP): applicability, stringency, and enforceability. When EPA approves a rule for inclusion into the SIP, EPA must evaluate, at a minimum, if the rule fulfills RACT requirements. Rule 4570 was submitted to EPA for SIP approv al on October 5, 2006, but has not yet been acted on by EPA.

4.1 APPLICABILITY OF RULE 4570 COVERS ALL CAFS THAT ARE MAJOR

SOURCES AND MANY SM ALLER FACILITIES

Pursuant to Section 3.25 of District Rule 2201 (New and Modifi ed Stationary Source Review Rule), a major source is a stati onary source with post-project emissions or a Post Project Stationary Source Potential to Emit, equal to or exceeding one or more of the specified threshold values. In determi ning whether a facility is a major source, fugitive emissions are not counted unless the facility belongs to certain specified source categories. 40 CFR 71.2 (Definitions, Ma jor Source (2)) states the following:

(2) A major stationary source of air pollut ants or any group of stationary sources as defined in section 302 of the Act, that direct ly emits, or has the potential to emit, 100 tpy or more of any air pollutant (including any major source of fugitive emissions of any such pollutant, as determined by rule by the Administrator). The fugitive emissions of a stationary source shall not be considered in determining whether it is a major stationary source for the purposes of section 302(j) of the Act, unless the source belongs to one of the following cat egories of stationary source: (i) Coal cleaning plants (with thermal drye rs); (ii) Kraft pulp mills; ( iii) Portland cement plants; (iv) Primary zinc smelters ; (v) Iron and steel mills; (vi) Primary aluminum ore reduction plants; (vii) Primary copper smel ters; (viii) Municipal incinerators capable of charging more than 250 tons of refuse per day; (ix) Hydrof luoric, sulfuric, or nitric acid plants; (x) Petroleum refineries; (xi) Lime plants; (xii) Phosphate rock processing plants; (xiii) Coke oven batteri es; (xiv) Sulfur recovery plants; (xv) Carbon black plants (furnace process); (xvi ) Primary lead smelters; (xvii) Fuel conversion plants; (xviii) Si ntering plants; (xix) Secondary metal production plants; (xx) Chemical process plants; (xxi) Foss il-fuel boilers (or combination thereof) totaling more than 250 million British t hermal units per hour heat input; (xxii) Petroleum storage and transfer units wit h a total storage capacity exceeding 300,000 barrels; (xxiii) Taconite ore processi ng plants; (xxiv) Glass fiber processing plants; (xxv) Charcoal producti on plants; (xxvi) Fossil-fuel -fired steam electric plants

of more than 250 million Brit ish thermal units per hour heat input; or (xxvii) Any other stationary source category which, as of August 7, 1980, is being regulated under

section 111 or 112 of the Act.

Because agricultural operations do not fall under any of the specific source categories listed above, fugitive emissions are not counted when determining if an agriculturalSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-131 operation is a major source. 40 CFR 71.2 defines fugitive emissions as “those emissions which could not reasonably pass th rough a stack, chimney, vent, or other functionally-equivalent opening.”

4.1.1 Dairy

Since emissions at a dairy are not actua lly collected, a determination of whether emissions could be reasonably collected must be made by t he permitting authority. The

California Air Pollution Control Associat ion (CAPCOA) prepared guidance in 2005 for estimating potential to emit of Volatile Organic Compounds from dairy farms. The guidance states that “VOC emissions from the milk ing centers, cow housing areas, corrals, common manure storage areas, and land application of manure are not physically contained and could not reasonably pa ss through a stack, chimney, vent, or other functionally-equivalent ope ning. No collection technologies currently exist for VOC

emissions from these emissions units. T herefore, the VOC emissions from these sources are considered fugitive.” The guidance also concludes that, because VOC collection technologies do exist fo r liquid waste systems at dairies, “... the VOC emissions from waste lagoons and st orage ponds are considered non-fugitive.” The

District has researched this issue and c oncurs with the CAPCOA assessment, as

discussed in more detail below.

Milking Center : The mechanical system for the milk ing parlors can be utilized to capture the gases emitted from the milking parlors; however in or der to capture all of the gases, and to keep an appropriate negative pressure throughout the system, the holding area would also need to be entirely enclosed. No facility currently encloses the holding area since cows are continuously going in and ou t of the barn throughout the day. The capital required to enclose this large area would al so be significant. Since the holding area is primarily kept open, the District cannot reas onably demonstrate that emissions can pass through a stack, chimney, vent, or ot her functionally equivalent opening.

Cow Housing : Although there are sma ller dairy farms that have partially enclosed freestall barns, these barns are not fully enclosed and none of the barns have been

found to vent the exhaust thr ough a collection device. The ai rflow requirements through dairy barns are extremely high, primarily for herd health purposes. The airflow requirements will be even higher in the San J oaquin valley, where temperatures reach in excess of 110 degrees in the hot summer. Collection and control of the exhaust including the large amounts of airflow have not yet been achieved by any facility. Due to this difficultly, the District cannot reas onably demonstrate that emissions can pass through a stack, chimney, vent, or ot her functionally equivalent opening.

It must also be noted that EPA has determi ned that emissions from open-air cattle feedlots are fugitive in nature. 13 In the District’s judgment, this determination for emissions from open feedlots necessitates a similar determination for the open-sided

13 Letter from William Wehrum, EPA Acting Administrator, to Terry Stokes, Chief Executive Officer –

National Cattlemen’s Beef A ssociation (November 2, 2006) ( http://www.epa.gov/Region7/ programs/artd/air/nsr/nsrmemos/cowdust.pdf )San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-132 freestalls (usually with open access to corrals or pens and free movement of cattle in and out of the covered area) typical of t he San Joaquin Valley since the typical open freestall barn in the San Joaquin Valley bears a far greater resemblance to an extensive shade structure located in a large open lot than an actual enclosed build ing. Therefore, emissions from open freestall barns are most appropriately treated as fugitive.

Manure Storage Areas : Many dairies have been found to cover dry manure piles. Covering dry manure piles is also a mitigati on measure included in District Rule 4570. However, the District was not able to find any facility, which currently captures the emissions from the storage or handling of manure piles. Al though many of these piles are covered, the emissions cannot reasonably be captured. Therefore, the District cannot reasonably demonstrat e that these emissions can pass through a stack, chimney, vent, or other functionally equiva lent opening. In addition, emissions from manure piles have been shown to be in significant in recent studies.

Land Application : Emissions generated from the applic ation of manure on land cannot reasonably be captured due to the extremely la rge areas, in some cases thousands of acres, of cropland at dairies. Therefore, the District cannot reasonably demonstrate that these emissions can pass through a stack, chimney, vent, or other functionally equivalent opening.

Feed Handling and Storage : The majority of dairies stor e the silage piles underneath a tarp or in an Agbag. The entire pile is cove red except for the face of the pile. The face of the pile is kept open due to the continual need to extract the silage for feed purposes. The silage pile is disturbed 2-3 times per day. Because of the ongoing disturbance to these piles, it makes it extremely difficult to design a system to capture the emissions from these piles. In fact, as far as the District is aw are, no system has been designed to successfully extract the gases from the face of the pile to capture them, and, as important, no study has assess ed the potential impacts on sil age quality of a continuous air flow across the silage pile, as would be required by such a collection system. Therefore, the District c annot demonstrate that these emissions can be reasonably expected to pass through a stack, chimney, vent, or other functionally equivalent opening.

As discussed above, the VOC emissions from the milking center, co ws housing, manure storage areas, land application of m anure and feed handling and storage are considered fugitive. The District has deter mined that control technology to capture emissions from lagoons (biogas collection system s, for instance) is in use; therefore, these emissions can be reasonably collected and are not fugitive. Therefore, only emissions from the non-fugitive sources, such as lagoons, storage ponds, IC engines, and gasoline tanks, will be used to determine if dairies are major sources.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-133 4.1.2 Poultry Houses

As discussed in section 1.1.3. 4, majority of poultry opera tions consist of ventilated houses. Since these houses have the potentia l of being fully enclosed and reasonably vented to a stack, the emissions from t hese sources will be cons idered non-fugitive.

4.1.3 Conclusion – Rule 4570 App licability Covers All Major Sources

Based on the discussion above, the majority of the agricultural source s in the Valley will be considered fugitive sources of emission s. Since fugitive emissions are not considered in the determination of a major sour ce, then the majority of facilities in the Valley will not be considered as major source s. The following tabl e shows the number of facilities that will potentially be major sources in the Valley:

Livestock Category Applicability

of Rule 4570 # of facilities Subject to Rule

4570 Major Source

Thresholds # of major

sources

Dairy 1,000 lactating

cows ≈ 550 7,407 milk cow equivalents 22-29

Beef Feedlots 3,500 beef

cattle 12 12,500 cattle only if lagoons on-site 0

Other Cattle Operations 7,500 calves, heifers, and

other cattle --- 16,667 heifers & 22,222 calves 0

ChickensBroilers & Egg Layers 650,000 head 32 400,000 broilers & 800,000 layers 31

Turkeys 100,000 head 35 200,000 turkeys 11 Swine 3,000 head 1 ≈ 4,500 1 Sheep and

Goats 15,000 head 0 --- ---

Horses 2,500 head 0 --- --- Ducks 650,000 head 0 400,000 ducks 0

Other

Livestock Not Previously

Mentioned 30,000 head --- --- ---

Given that RACT only applies to major sour ces of emissions, based on the table above, only a small percentage of fac ilities subject to Rule 4570 are actually subject to federal RACT requirements. However, Rule 4570 requires facilities greater than the thresholds listed above to comply with the requirements of Rule 4570, which is a much larger set of facilities, and hence more stringent.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-134 4.2 THE REQUIREMENTS OF RULE 4570 ARE SUFFICIENTLY EFFECTIVE TO

BE CONSIDERED RACT

Rule 4570 requires oper ators of a CAF to implement mu ltiple VOC mitigation measures for the major emission sources at each facility. The sources covered by the Rule and the number of measures required are shown in the following table:

Summary of the Minimum Number of VOC Mitigation Measures Per Animal Type and Area Compared to Total Number of Options Area Dairy Beef Other

Cattle Swine Poultry

Feed 4 of 8 5 of 8 5 of 8 5 of 12 5 of 10 Silage 1 of 6 1 of 6 1 of 6 0 of 0 0 of 0

Milk Parlor 1of 3 0 of 0 0 of 0 0 of 0 0 of 0

Housing 8 of 26 7 of 15 7 of 23 5 of 10 4 of 17

Solid Manure 2 of 8 1 of 8 1 of 8 1 of 8 1 of 8 Liquid Manure 1 of 11 1 of 11 1 of 11 1 of 11 1 of 11

Land Application 2 of 7 2 of 7 2 of 7 2 of 7 0 of 0

TOTAL 19 of 69 17 of 55 17 of 63 14 of 48 11 of 46

As discussed earlier, there is no typical CA F. This menu option not only provides flexibility to facilities to select measures that are suitable to their particular operation, but the requirement to implement multiple miti gation measures in each source category results in a larger emission reduction.

4.2.1 RULE 4570 REQUIREMENTS HAVE BEEN APPROVED BY EPA AS BACT

The District has issued permits to well over 40 new and expanding dairies over the last few years. These permits were issued with Rule 4570 mitigation measures as a part of the Best Available Control Technology (BACT) requirements. The District also issued permits to a couple of new and modifying poul try operations. These permits were also issued with Rule 4570 mitigation measures as part of BACT. Since these measures

have been considered to be BACT for these fa cilities, Rule 4570 exceeds the RACT requirements. In addition, BACT advances te chnology more so than the Rule process does. A copy of the poultry BACT anal ysis is attached as attachment xxx.

4.2.2 RULE 4570 IS AS EFFECT IVE AS OTHER AIR DISTRICTS

As the largest agriculture area in the state, the District took the lead in developing the variety of mitigation measures li st in District Rule 4570. This list is essentially identical

for all air districts that identif y mitigation measures in their ru les. While other air districts have adjusted some of the original miti gation measures; District Rule 4570 list still serves as the primary source for avai lable emission controls for large CAFs.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-135 Of all the air districts analyzed, only Sa cramento Metropolitan AQMD and the District

claimed emission reductions fr om adopting their rules. Emi ssion reductions affected the various types of CAFs differently, however, in the final staff report fo r District Rule 4570,

overall emission reductions were estima ted at 28% of the calculated baseline emissions. Sac Metro used similar methodology for sources in their area and claimed a

24% reduction from the total CAF baseline emissions.

The following California air district rules were compared to District Rule 4570:

• South Coast AQMD Rule 223

• Bay Area AQMD Regulation 2 Rule 10

• Ventura County APCD Rule 23

• Sacramento Metropolit an AQMD Rule 496

• Imperial County AQMD Rule 217 and Policy 38

• Butte County APCD Rule 450

It is important to note that only Distric t Rule 4570 and Sacramento Metropolitan AQMD Rule 496 are prohibitory rules. For th is reason, these rules include detailed recordkeeping as well as monitoring and test ing requirements. Ge nerally, the level of detail in a prohibitory rule is absent from permits rules because the purpose of a permit rule is different from the pur pose of a prohibitory rule.

4.2.2.1 South Coast AQMD Rule 223

4.2.2.1.1 Applicability/Exem ption/Large CAF Definition

South Coast AQMD adopted ARB’s definition of large CAF. District Rule 4570 defines large CAF the same way except for a lar ge horse CAF. District Rule 4570 defines a large horse CAF as 3,000 head, whereas South Coast AQMD defines it as 2,500 head.

4.2.2.1.2 Requirements for Dairy Large CAFs

Feed Mitigation Measures

District Rule 4570 has seven Class One mitigat ion measures for feed and three Class One mitigation measures for silage. There are three Class Two mitigation measures for silage. Operators must implement four feed mitigation measures and one silage mitigation measure for five to tal feed mitigation measures. In the South Coast AQMD rule, there are nine feed miti gation measures, from which the operator must implement five. In the South Coast AQMD rule, there is no requirement to control emissions from silage. In this respect, Distr ict Rule 4570 is more stringent.

Within the Class One mitigation measures, removal of excess/spoilt feed from feed lanes/aprons , is more stringent under the South Coast AQMD rule. The South Coast AQMD rule requires excess/spoilt feed to be removed every 7 days, whereas Rule 4570 requires this to be done every 14 days.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-136San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-137 Milk Parlor Mitigation Measures

The milk parlor mitigations measures are identical. Each rule has one Class One and one Class Two mitigation measure, from which operators are required to implement at

least one.

Freestall Mitigation Measures

District Rule 4570 has eight Class One and one Class Two mitigation measures, from which facilities are required to implement at least two. South Coast AQMD Rule 223 has eight Class One mitigations measures (no Class Two mitigation measures), from which facilities are required to implement at least two. The extra (Class Two) mitigation measure option offered by District Rule 4570 is vacuuming waste instead of scraping or flushing and injecting or incorporating into land with 72 hours of removal.

South Coast AQMD Rule 223 has three Class One mitigation measures that are more stringent than the corresponding District Rule 4570 measures: ( inspect water pipes and troughs and repair leaks; remove animal wast e that is not dry from individual cow freestall beds; and rake, harrow, scr ape, or grade bedding in freestalls ). The South Coast rule requires pipes and troughs to be in spected daily, and manure from freestall beds to be removed daily, whereas District Ru le 4570 requires both of these measures to be carried out only once only every 14 days. The South Coast rule also requires freestall beds to be raked/harrowed/graded at least twice every seven days, whereas District Rule 4570 requires this measure to be carried out only once every 14 days. Although, South Coast rule has a higher frequency for these measures, the emissions generated from these sources are not significant, including the reductions achieved from the overall dairy. In addition, the frequency required by the South Coast Rule exceeds RACT when compared to inspecti on leak requirements in other Rules and regulations.

Corral Mitigation Measures

District Rule 4570 has 15 Class One mitigation measures and three Class Two mitigation measures, from whic h facilities are required to c hoose at least six. South
Coast AQMD Rule 223 has 14 Class One mitigation measures and two Class Two mitigation measures, from which facilities are required to choose at least six.

South Coast AQMD Rule 223 has one Class One mitigation measure ( inspect water pipes and troughs and repair leaks ) that is more stringent than the corresponding

District Rule 4570 measure. The South Coast rule requires this measure to be carried out daily, whereas District Rule 4570 requires it to be carried out only once every 14 days. Although, South Coast rule has a higher frequency for this measure, the emissions generated from this source is not significant, including the reductions achieved from the overall dairy. In additi on, the frequency required by the South Coast Rule exceeds RACT when compared to inspec tion leak requirements in other Rules and regulations.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-138 The two rules also differ slightly in the categorization (Class One vs. Class Two) of mitigation measures relating to shade struct ures and corrals soil additives, but these differences are not expected to have any ef fect on the stringency of the mitigation

measures.

Solid Waste and Separated Solids Mitigation Measures

District Rule 4570 has five Class One mitigation measures and three Class Two mitigation measures, from whic h operators are required to c hoose at least two. South
Coast AQMD Rule 223 has three Class O ne mitigation measures and three Class Two mitigation measures, from whic h facilities are required to choose at least two.

South Coast AQMD Rule 223 has one Class Two mitigation measure ( send at least

51% of the animal waste removed from animal housing to a digester ) that is more stringent than the corresponding District Rule 4570 measure. The South Coast rule specifies that the animal waste must be sent to a digester within 72 hours of removal from housing, whereas District Rule 4570 does not specify a timeline within which this measure must be implemented.

Since Class Two options are not required, they do not affect the stringency of the rule. In addition, the emissions from solid manure a ccount for a fraction of emissions from the overall dairy, thus resulting in a very small reducti on in emission regardless of the practice selected.

Liquid Waste Mitigation Measures

District Rule 4570 has five Class One mitigation measures and five Class Two mitigation measures, from whic h operators are required to c hoose at least one. South
Coast AQMD Rule 223 has five Class One mitigation measures and five Class Two mitigation measures, from whic h operators are required to choos e at least one. All the mitigation measures are similar in stringency.

Land Application of Ma nure Mitigation Measures

District Rule 4570 has six Class One mitigati on measures, from which facilities are required to choose at least two. Sout h Coast AQMD Rule 223 has four Class One mitigation measures, from whic h facilities are required to c hoose at least two. All the mitigation measures are similar in stringency.

4.2.2.1.3 Requirements for Poultry Large CAFs

Feed Mitigation Measures

District Rule 4570 has nine Class One mitigati on measures, from which facilities are required to choose at least five. Sout h Coast AQMD Rule 223 has nine Class OneSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-139 mitigation measures, from which facilities are required to choose at least five. All the mitigation measures are similar in stringency.

Housing Mitigation Measures

District Rule 4570 has twelve Class One mitigation measures and four Class Two mitigation measures, from whic h facilities are required to c hoose at least four. South
Coast AQMD Rule 223 has twelve Class O ne mitigation measures and four Class Two mitigation measures, from whic h facilities are required to choose at least four. South
Coast AQMD Rule 223 has four Class One mitigation measures (remove caked manure; clean under poultry cages; adjust the height, volume, and location of drinkers; and inspect water pipes and drinkers and repair leaks ) that are more stringent than the corresponding District Rule 4570 measures. The South Coast rule requires these measures to be carried out daily, whereas Dist rict Rule 4570 requires them to be carried out only once every 14 days.

Solid Waste and Separated Solids Mitigation Measures

District Rule 4570 has four Class One mitigation measures and two Class Two mitigation measures, from whic h facilities are required to choose at least one. South
Coast AQMD Rule 223 has four Class O ne mitigation measures and three Class Two mitigation measures, from whic h operators are required to choos e at least one. District Rule 4570 has one Class One mitigation measure ( send all animal waste to a lagoon ) that is more stringent than the corresponding South Coast AQMD Ru le 223 measure. District Rule 4570 requires this measure to be carried out within 72 hours of manure being removed from housing, whereas Sout h Coast AQMD Rule 223 does not specify any timeline within which the measure is to be carried out.

South Coast AQMD Rule 223 has one Class Two mitigation measure ( send at least

51% of the animal waste removed from animal housing to a digester ) that is more stringent than the corresponding District Rule 4570 measure. The South Coast rule specifies that the animal waste must be sent to a digester within 72 hours of removal from housing, whereas District Rule 4570 does not specify a timeline within which this measure must be implemented.

Since Class Two options are not required, they do not affect the stringency of the rule. In addition, the emissions from solid manure a ccount for a fraction of emissions from the overall dairy, thus resulting in a very small reducti on in emission regardless of the practice selected.

Liquid Waste Mitigation Measures

District Rule 4570 has five Class One mitigation measures and five Class Two mitigation measures, from whic h facilities are required to choose at least one. South
Coast AQMD Rule 223 has five Class One mitigation measures and five Class TwoSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-140 mitigation measures, from which facilities are required to choose at least one. All mitigation measures are similar in stringency.

4.2.2.1.4 Requirements for Other Large CAF Categories

In addition to dairy and poultry CAF mitigati on measures discussed above, District Rule 4570 provides specific mitigation measure op tion tables for beef cattle feedlots, other cattle, and swine CAFs. South Coast AQ MD Rule 223 does not address mitigation

measures for these additional CA F categories. For these types of large CAFs, District Rule 4570 is more stringent.

4.2.2.1.5 Requirements – Suspension and Substituti on of Mitigation Measures

Both rules allow the temporary sus pension of a mitigat ion measure upon the determination by a certified veterinarian or nutritionist that such a suspension is necessary for animal health purposes. The District must be notif ied within 48 hours, and a new measure must be impl emented if the suspension is expected to last longer than 30 days. In addition, both rules allow fo r substitution of one mitigation measure with an equivalent or more stringent one with the submission of the appropriate application.

4.2.2.1.6 Testing, Monitoring, Recordkeeping Requirements

District Rule 4570 requires records to be maintain ed and retained for at least five years, whereas South Coast AQMD Rule 223 require s records to be retained for three years for non-Title V facilities and five years for Titl e V facilities. District Rule 4570 therefore has a more stringent record retention requirement.

District Rule 4570 requires facilities not subj ect to the mitigation measure requirements

to maintain sufficient records to demonstrat e their exemption status . Facilities subject to the mitigation measure requirements must monitor, test, and maintain sufficient records to demonstrate implementation of eac h mitigation measure selected. Facilities

must also maintain anim al population records.

South Coast AQMD Rule 223 requires t he maintenance of animal population records but does not require specific records needed to demonstrate implementation of each mitigation measure selected. District Rule 4570 is therefore more stringent in the type of records required to be maintained.

4.2.2.1.7 Conclusion – Comparison with South Coast AQMD Rule 223

Under the dairy and poultry CAF categories, District Rule 4570 and South Coast AQMD Rule 223 have nearly identical mitigation meas ure options and require ments. There are slight differences in the frequency with which some mitigation measures are to be implemented. Specifically, ther e are a few measures that must be carried out weekly or daily under South Coast AQMD Rule 223 re quirements, but only once every two weeksSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-141 under District Rule 4570 requirements. Howe ver, as stated earlier, many of these sources are a small portion of a dairy’s over all emissions. For the larger emission sources, such as feed handli ng and cow housing, emission st rategies for both rules are fairly equivalent, resulting in larger emission reductions. Therefore, District staff does

not consider the differences between the miti gation measures from the two rules to be significant overall.

District Rule 4570 also provides mitigation fo r more CAF categories (beef feedlots, other cattle, and swine) that are not addressed by South Coast AQMD Rule 223, and also has

much more detailed recordk eeping requirements to dem onstrate implementation of selected mitigation measures. District Rule 4570 is, therefore, mo re stringent overall
than South Coast AQMD Rule 223.

4.2.2.2 South Coast AQMD Rule 1127

4.2.2.2.1 Applicability/Exem ption/Large CAF Definition

South Coast AQMD Rule 1127 applies to dairi es with 50 or more cows, heifers, and/or calves. The rule applies to dairy farms and related operations such as heifer and calf farms and the manure produced on them. By co mparison, District Rule 4570 applies to large CAFs regardless of animal species and covers all major processes within the CAF. For dairies, District Rule 4570 appl ies to those CAFs with more than 1,000 milking cows, but applies to mo re than manure-handling operations.

4.2.2.2.2 Requirements for Dairy Large CAFs

Feed, Milking Parlor, and Freestall Mitigation Measures

District Rule 4570 has seven Class One mitigat ion measures for feed and three Class One mitigation measures for silage. There are three Class Two mitigation measures for silage. Operators must implement four feed mitigation measures and one silage mitigation measure for five to tal feed mitigation measures. For the milking parlor, the

District rule has one Class One and one Class Two mitigation measure, from which operators are required to impl ement at least one. District Rule 4570 has eight Class One and one Class Two freestall mitigation measur es, from which facilities are required to implement at least two. South C oast AQMD Rule 1127 does not address these operations. District Rule 4570 is more stri ngent than South Coast AQMD Rule 1127 for these dairy operations.

Corral Mitigation Measures

South Coast AQMD Rule 1127 requires a tota l of four corral mitigation measures. District Rule 4570 has 15 Class One mitigation measures and three Class Two mitigation measures, from whic h operators are required to c hoose at least six. While the mitigation measures in the two rules are not phrased the same way, they cover similar requirements.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-142 Solid Waste, Separated Solids, and Liqui d Waste, and Land Ap plication Mitigation

Measures

District Rule 4570 has five Class One mitigation measures and three Class Two mitigation measures for solid waste/separated solids, from which operators are required to choose at least two. For liquid waste, District Rule 4570 has five Class One mitigation measures and five Class Two miti gation measures, from which operators are required to choose at least one. Distric t Rule 4570 has six Class One mitigation measures for land application, fr om which operators ar e required to choose at least two.

A dairy is able to comply fully with Sout h Coast AQMD Rule 11 27 by applying its manure to approved cropland, since com posting and anaerobic digestion are options rather than requirements. Simila rly, a dairy is able to comply fully with District Rule 4570 by applying its manure to cropland, since co mposting, storage in enclosed containers and anaerobic digestion are all op tion rather than requirements.

There is therefore no differ ence at all in stringency between South Coast AQMD Rule 1127 and District Rule 4570 as far as disposal of manure is concerned. In this category, District Rule 4570 is as stringent as South Coast AQMD Rule 1127.

4.2.2.2.3 Requirements for Other Large CAFs

District Rule 4570 provides specific mitigati on measures for beef cattle feedlots, other cattle, poultry, and swine CAFs. South Coast AQMD Rule 1127 does not address mitigation measures for these additional CAF categories. For these types of large CAFs, District Rule 4570 is more stringent.

4.2.2.2.4 Requirements – Suspension and Substituti on of Mitigation Measures

South Coast AQMD Rule 1127 provides one exem ption per year from one of the corral clearings required every 90 days if the moisture content in the corrals is greater than 50%. The operator is required to notify t he AQMD 30 days before the required cleaning, and test moisture content weekly. If mois ture content is still above 50% when the cleaning is due, the operator may claim the exemption.

In comparison, District Rule 4570 allows an operator to temporarily suspend any mitigation measure as long as the su spension is recommended by a licensed

veterinarian of animal nutritionist on the basis of animal health. The operator must notify the District within 48 hours prior to the suspension. If the suspension is expected to last longer than 30 days, then the oper ator must submit a new mi tigation plan that identifies a new mitigation measure to be implement ed in place of the suspended one.

District Rule 4570’s exemption under this cat egory is much more stringent because it is only a temporary suspension that cannot ex ceed 30 days, whereas South Coast AQMD Rule 1127’s exemption is permanent, without any requirement to makeup for theSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-143 skipped mitigation. In addition, th e exemption provided by Rule 1127 is very likely to be claimed much more frequently than the su spension provided by Rule 4570. This is because cattle corrals are usually waterlogge d during winter rains and dairies whose corral clean-outs are due during such a period will qualify for the exemption. It is very unlikely that any of the mitigation measures required by District Rule 4570 will require suspension on animal health reasons, since most of the measures have been used in various dairies without any reported animal heal th issues. The District has not received any requests for suspension of any mitigation measure since the rule came into effect.

In this category of mitigation measure exempt ions, therefore, District Rule 4570 is more stringent than South Coast AQMD Rule 1127.

4.2.2.2.5 Testing, Monitoring, Recordkeeping Requirements

Both South Coast AQMD Rule 1127 and Distri ct Rule 4570 require monitoring, record keeping and source testing as appropriate and sufficient to provide evidence of each mitigation measure being implemented.

In addition to record keeping, Rule 1127 requires an annual report of manure being shipped out of the dairy. No annual reporti ng is required by Rule 4570. Rule 1127 requires records be retained for 3 years for minor sources and 5 years for major sources, whereas Rule 4570 requires records be retained for five years for all sources.

Overall, the monitoring, testing and record keeping requirements are fairly similar for

both rules.

4.2.2.2.6 Conclusion – Comparison wi th South Coast AQMD Rule 1127

For dairy CAFs, District Rule 4570 is more stringent than South Co ast AQMD Rule 1127 in one out of four comparabl e categories and as stringent as South Coast AQMD Rule

1127 in an additional two out of t he four comparable categories.

Although District Rule 4570 is less stringent in the exemptions category (herd size exemption), it is more stri ngent overall because it requi res emission reductions from

four additional emission ca tegories - milk parlors, f eed, freestall barns, and liquid

manure - that are not addre ssed at all by South Coast AQMD Rule 1127 as well as requiring emission reductions from CAFs fro other animal species.

4.2.2.3 Bay Area AQ MD Regulation 2 Rule 10 (Rule 2-10)

Bay Area AQMD Rule 2-10 is a permit rule. As such, it has fewer specifics about large CAFs than District Rule 4570, which is a prohibitory rule.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-144 4.2.2.3.1 Applicability/Exem ption/Large CAF Definition

Bay Area AQMD adopted ARB’s definition of large CAF. District Rule 4570 defines large CAF the same way except for a large horse CAF. District Rule 4570 defines a large horse CAF as 3,000 head, whereas Ba y Area AQMD defines it as 2,500 head.

4.2.2.3.2 Requirements for Large CAFs

The Bay Area permit conditions must implem ent control measures that represent reasonably available control technology (RACT) to reduce emissions of VOC, NOx and PM from the facility. Rule 2-10 requires RACT mitigation measur es rather than the more stringent BARCT controls required by Di strict Rule 4570 as specifically noted in the Bay Area AQMD staff repor t for their rule. A recent phone call to Bay Area AQMD

staff verified that there is no list of RACT mitigation measures in place should a large CAF apply for a permit. In this respect, Dis trict Rule 4570 is more stringent than Bay
Area AQMD Rule 2-10.

4.2.2.3.3 Testing, Monitoring, Recordkeeping Requirements

District Rule 4570 requires records to be maintain ed and retained for at least five years, whereas Bay Area AQMD Rule 2-10 requires re cords to be retained for three years.

District Rule 4570 therefore has a more stringent record retention requirement.

District Rule 4570 requires facilities not subj ect to the mitigation measure requirements

to maintain sufficient records to demonstrate their exemption status. Facilities subject to the mitigation measure require ments must maintain suffici ent records to demonstrate implementation of each mitigat ion measure selected. Facili ties must also maintain animal population records. Bay Area AQMD Rule 2-10 requires the maintenance of animal population records but does not requi re specific records needed to demonstrate implementation of each mitigat ion measure selected. Distr ict Rule 4570 is therefore more stringent in the type of re cords required to be maintained.

4.2.2.3.4 Conclusion – Comparison with Bay Area AQMD Re gulation 2 Rule 10

District staff concludes that District Rule 4570 is generally more stringent than Bay Area’s Rule 2-10. This is to be expected giv en the difference in ozone attainment status between Bay Area AQMD and the District.

4.2.2.4 Ventura County APCD Rule 23 – Exemptions from Permit

In response to SB 700, Ventura County APCD re vised its “Exemptions from Permit” rule to remove an exemption for agricultural oper ations, including CAFs. Ventura County APCD does not have a specific rule for CAFs. In its staff report fo r the rule revision, Ventura County APCD staff noted that no facilities in their jurisdiction would meet the “large CAF” definition and there was no expect ation that a large CAF would move into the area in the foreseeable future; theref ore, no separate CAF rule was necessary.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-145 4.2.2.4.1 Applicability/Exem ption/Large CAF Definition

Ventura County APCD adopt ed ARB’s definition of lar ge CAF. District Rule 4570 defines large CAF the same wa y except for a large horse CAF. District Rule 4570 defines a large horse CAF as 3,000 head, whereas Ventura County APC D defines it as 2,500 head. At the time of ru le amendment, there are no facili ties that would trigger the large CAF threshold withi n Ventura County.

4.2.2.4.2 Requirements for Large CAFs

There are no facilities that would trigger th e large CAF threshold within the county, as stated in the Ventura County staff report for amending Rule 23. The Ventura County

APCD New Source Review Rule does not lis t mitigation measures for large CAFs. Instead, BACT would be triggered by a new CAF that met the “large CAF” definition or BACT would be triggered if an existing CAF expanded operations enough to meet the “large CAF” definition. At that point, V entura County APCD staff would determine BACT

for the CAF.

4.2.2.4.3 Conclusion – Ventura County APCD Rule 23

Ventura County APCD does not have a specific rule for CAFs, therefore District Rule 4570 is more stringent.

4.2.2.5 Sacramento Metropolitan AQMD Rule 496

Like District Rule 4570, Sac Metro AQMD Ru le 496 is a prohibitory rule, meaning that there are detailed requir ements for operators.

4.2.2.5.1 Applicability/Exem ption/Large CAF Definition

Sacramento Metropolitan (Sac Metro) AQMD Rule 496 adopted ARB’s definition of large CAF. District Rule 4570 defines large CAF the same way except for a large horse CAF. District Rule 4570 defines a large horse CAF as 3,000 head, whereas Sac Metro AQMD defines it as 2,500 head.

4.2.2.5.2 Requirements for Dairy Large CAFs

Feed Mitigation Measures

District Rule 4570 has seven Class One miti gation measures for feed and three Class One mitigation measures for silage. There are three Class Two mitigation measures for silage. Operators must implement four feed mitigation measures and one silage mitigation measure for five to tal feed mitigation measures. Sac Metro AQMD has seven Class One mitigation measures for feed and three Class One mitigation measures for silage. There are three Class Two mitigati on measures for silage. Operators must implement four feed mitigati on measures and one silage mi tigation measure for fiveSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-146 total feed mitigation measures. The Class One and Class Two mitigation measures are

the same in both rules.

Milk Parlor Mitigation Measures

The milk parlor mitigations measures are i dentical for Sac Metro and for the District.

Each rule has one Class One and one Class Tw o mitigation measure, from which facilities are required to choose at least one.

Freestall Mitigation Measures

District Rule 4570 has eight Class One and one Class Two mitigation measures, from which facilities are required to implement at least two. Sac Me tro AQMD Rule 496 has eight Class One mitigations measures and one Class Two mitigation measure from which facilities are required to implement at least two. The Sac Metro AQMD freestall barn mitigations measures and the District Rule mitigation measures are identical.

Sac Metro AQMD Rule 496 has one Class One mitigation measures that are more stringent than the corresponding District Rule 4570 measures - inspect water pipes and troughs and repair leaks . The Sac Metro AQMD rule re quires pipes and troughs to be inspected and repaired daily, whereas Distric t Rule 4570 requires that this mitigation measure be carried out once every 14 days.

Corral Mitigation Measures

District Rule 4570 has 15 Class One mitigation measures and three Class Two mitigation measures, from which facilities are required to choos e at least six. Sac Metro AQMD Rule 496 has 15 Class One mitigation measures and three Class Two mitigation measures, from which facilities are r equired to choose at least six.

Sac Metro AQMD Rule 496 has one Class One mitigation measure ( inspect water pipes and troughs and repair leaks ) that is more stringent than the corresponding District Rule 4570 measure. The Sac Metro rule requires this measure to be carried out daily, whereas District Rule 4570 requires it to be carried out only once every 14 days.

Solid Waste and Separated Solids Mitigation Measures

District Rule 4570 has five Class One mitigation measures and three Class Two mitigation measures, from wh ich operators are required to choose at least two. Sac
Metro AQMD Rule 496 has five Class One mitigation measures and three Class Two mitigation measures, from whic h facilities are required to choose at least two. The Class One and Class Two mitigation measur es are identical in both rules.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-147 Liquid Waste Mitigation Measures

District Rule 4570 has five Class One mitigation measures and five Class Two mitigation measures, from whic h facilities are required to choose at least one. The Sac Metro rule has four Class One mitigation measures and four Class Two mitigation measures, from which facilitie s are required to choose at least one. All the mitigation measures are similar in stringency.

Land Application of Ma nure Mitigation Measures

District Rule 4570 has six Class One mitigati on measures, from which facilities are required to choose at least two. Sac Metro AQMD Rule 496 has six Class One mitigation measures, from whic h facilities are required to c hoose at least two. All the mitigation measures are similar in stringency.

4.2.2.5.3 Requirements for Poultry Large CAFs

Feed Mitigation Measures

District Rule 4570 has nine Class One mitigati on measures, from which facilities are required to choose at least five. Sac Metro AQMD Rule 496 has nine Class One mitigation measures, from whic h facilities are required to c hoose at least five. All the mitigation measures are similar in stringency.

Housing Mitigation Measures

District Rule 4570 has twelve Class One mitigation measures and four Class Two mitigation measures, from whic h facilities are required to choose at least four. Sac
Metro AQMD Rule 496 has twelve Class O ne mitigation measures and four Class Two mitigation measures, from whic h facilities are required to c hoose at least four. Except as noted below, all the mitigation m easures are similar in stringency.

Sac Metro AQMD Rule 496 has one Class One mitigation measure - inspect water pipes and drinkers and repair leaks - that is more stri ngent than the corresponding

District Rule 4570 measure. The Sac Metro AQMD rule requires the inspection and repair to be carried out daily, whereas Dis trict Rule 4570 requires the mitigation measure to be carried out once every 14 days.

Solid Waste and Separated Solids Mitigation Measures

District Rule 4570 has four Class One mitigation measures and two Class Two mitigation measures, from which facilities are required to choose at least one. Sac
Metro AQMD Rule 496 has four Class O ne mitigation measures and two Class Two mitigation measures, from whic h operators are required to c hoose at least one. All the mitigation measures are similar in stringency.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-148 Liquid Manure Handling

District Rule 4570 has five Class One mitigation measures and five Class Two mitigation measures, from whic h facilities are required to choose at least one. Sac
Metro AQMD Rule496 has five Class One mitigation measures and five Class Two mitigation measures, from which facilities are required to choose at least one. All mitigation measures are similar in stringency.

4.2.2.5.4 Other Large CAFs

In addition to dairy and poultry CAF mitigati on measures discussed above, District Rule 4570 provides specific mitigation measure op tion tables for beef cattle feedlots, other cattle, and swine CAFs. Sac Metro AQMD Rule 496 does not address mitigation

measures for these additional CA F categories. For these types of large CAFs, District Rule 4570 is more stringent.

4.2.2.5.5 Requirements – Suspension and Substituti on of Mitigation Measures

Both rules allow for substitution of one mi tigation measure with an equivalent or more stringent one with the submission of the appropriate application. District Rule 4570 also allows the temporary suspension of a mi tigation measure upon the determination by a

certified veterinarian or nutri tionist that such a suspens ion is necessary for animal health purposes. The District must be no tified within 48 hours, and a new measure must be implemented if the suspension is expe cted to last longer than 30 days. The Sac Metro AQMD rule does not have a specific provision for temporary suspension of mitigation measures.

4.2.2.5.6 Testing, Monitoring, Recordkeeping Requirements

The testing, monitoring, and recordkeeping provisions of District Rule 4570 and Sac Metro Rule 496 are essentially identical , therefore, are of equal stringency.

4.2.2.5.7 Conclusion – Comparis on with Sac Metro AQMD Rule 496

District Rule 4570 and Sac Metro Rule 496 are equivalent for large CAFs that are dairies and poultry operations, th erefore, they are equally stri ngent for dairy and poultry

CAFs. Since District Rule 4570 details miti gation measures for additional large CAFs,

District staff concludes that District Rule 4570 is more stringent for large CAFs other than dairies and poultry operations.

4.2.2.6 Imperial County APCD Rule 217 – Large Confined Animal Facilities Permits Required and ICAPCD Policy Number 38

Imperial County APCD Rule 217 is a permits rule . The rule directs operators to a policy for the mitigation measures. The policy al so spells out the number of mitigation measures the operator must implement for each operation within the CAF. TheSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-149 following discussion compares the mitigation m easures in the Imperial County policy to

the measures in District Rule 4570.

4.2.2.6.1 Applicability/Exem ption/Large CAF Definition

Although the definition of large CAF is the same for both air districts, Imperial County Policy Number 38 only lists mitigation measur es for dairy operations and beef feedlot operations. Imperial County APC D policy’s menu of mitigation measures is essentially identical to the Class One mitigation measures in District Rule 457 0. Imperial County policy does not have a separate group of mitigat ion measures equivalent to the District’s Class Two mitigation measures to offer large CAF operators.

4.2.2.6.2 Requirements for Dairy Large CAFs

Feed Mitigation Measures

District Rule 4570 has seven Class One mitigat ion measures for feed and three Class One mitigation measures for silage. There are three Class Two mitigation measures for silage. Operators must implement four feed mitigation measures and one silage mitigation measure for five total feed mitigation measur es. Imperial County APCD policy has a menu of nine mitigation measur es for feed with mitigation measures for silage included in the menu. Imperial Co unty APCD policy requires the selection of three feed mitigation measures. Including the silage mitigation measures, this is two less mitigation measures than required by Dist rict Rule 4570. Therefore, District Rule 4570 is more stringent than the Imperial County APCD policy.

Although the dairy feed mitigation measures are identical in both air districts, the compliance time for t he mitigation measures in the Imperial County APCD are longer

than for those in District Rule 4570. Fo r removal of spilled or spoiled feed the compliance time is 30 days for Imperial Coun ty APCD versus 14 days for the District. The compliance time for removing feed after a rain event is 72 hours in the Imperial County policy and 24 hours in District Rule 4570. For these mitigation measures, the District rule is more stringent.

Milk Parlor Mitigation Measures

Imperial County Policy has only on e mitigation measure for the milk parlor. The District

rule has one Class One and one Class Two miti gation measure, fr om which operators are required to choose at least one.

Freestall Mitigation Measures

District Rule 4570 has eight Class One and one Class Two mitigation measures, from which facilities are required to implement at least two. Imper ial County APCD policy has eight mitigation measures, from which operators are required to choose at least

two.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-150 The Class Two mitigation measure opti on offered by District Rule 4570 is vacuuming wasted instead of scraping or flushing and inject ing or incorporating into land with 72

hours of removal.

Imperial County APCD policy has one mitigation m easure that is more stringent than the corresponding District Rule 4570 measure. The Imperial County APCD policy requires freestall beds to be raked/harrowed/graded at l east twice every 7 days, whereas District Rule 4570 requires this measure to be carried out only once every 14 days.

Corral Mitigation Measures

District Rule 4570 has 15 Class One mitigation measures and three Class Two mitigation measures, from whic h facilities are required to c hoose at least six. Imperial County APCD Policy Number 38 has eight mitigat ion measures, from which facilities are required to choose at least four.

For five of the mitigation m easures, the compliance times differ significantly between the District rule and the Imperial County APCD po licy. For these measures, the Imperial County policy compliance times are longer than the District rule time lines. For these five mitigation measures, the District rule is more stringent because the District rule’s compliance time is much shorter for otherwise identical mitigation measures.

Imperial County APCD policy has one mitigat ion measure - inspect water pipes and troughs and repair leaks - that is more st ringent than the corresponding District Rule 4570 measure. The policy requi res that this measure to be carried out daily, whereas District Rule 4570 requires it to be carried out once every 14 days.

The two air districts also differ slightly in the categorization of t he mitigation measure relating to corrals soil additives, but this diffe rence is not expected to have any effect on the stringency of the mitigation measures.

Solid Waste and Separated Solids Mitigation Measures

District Rule 4570 has five Class One mitigation measures and three Class Two mitigation measures, from whic h operators are required to choos e at least two. Imperial County APCD policy has four mitigation measures from which facilities are required to choose at least one. Since op erators must implement fewe r mitigation measures under the Imperial County APCD policy than required by District Rule 4570, District Rule 4570 is more stringent.

There are a few differences in the Imper ial County APCD policy mitigation measures themselves, when compared to District Ru le 4570. Imperial County APCD policy requires that manure piles ar e covered year round whereas District Rule 4570 requires that the piles be covered from October thro ugh May – the months t he District is most likely to have rainfall. Storage in anaerobic di gesters or aerobic lagoons is not an optionSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-151 for Imperial County operations. Separated solid s piles not specifica lly addressed in the Imperial County policy. District Rule 4570 does not have a “no-storage” option for operators. These differences, although worth noting, are not expected to influence the

effectiveness of Rule 4570.

Liquid Waste Mitigation Measures

District Rule 4570 has five Class One mitigation measures and five Class Two mitigation measures, from whic h facilities are required to c hoose at least one. Imperial County APCD policy has five mitigation measur es, from which operators are required to

choose at least one. The District’s Class One mitigation measures and the Imperial County APCD policy mitigation m easures are identical.

Land Application of Ma nure Mitigation Measures

District Rule 4570 has six Class One mitigati on measures, from which facilities are required to choose at least two. Imper ial County APCD policy has a menu of five mitigation measures from whic h operators are required to c hoose two. Imperial County APCD allows the application of composted manure with a moisture content of less than 50% as a mitigation measure. Since the material has been through a composting process, the District views the composted ma terial as no longer animal manure, so the not-apply mitigation measure in the Distric t rule and the application of composted manure in the Imperial C ounty policy are equivalent.

4.2.2.6.3 Requirements for Beef Feedlot Large CAFs

Feed Mitigation Measures

District Rule 4570 has seven Class One mitigat ion measures for feed and three Class One mitigation measures for silage. There are three Class Two mitigation measures for silage. Operators must implement four feed mitigation measures and one silage mitigation measure for five total feed mitigation measur es. Imperial County APCD policy has a menu of eight mi tigation measures for feed wit h mitigation measures for silage included in the menu. Imperial Co unty APCD policy requires the selection of three feed mitigation measures. Including the silage mitigation measures, this is two less mitigation measures than required by Dist rict Rule 4570. Therefore, District Rule 4570 is more stringent than the Imperial County APCD policy

Although the feed mitigation measures are identical, the compliance time for the mitigation measures in the Imperial County APCD are longer than for those in District Rule 4570. For removal of spilled or spo iled feed the compliance time is 30 days for Imperial County APCD versus 14 days for th e District. The compliance time for removing feed after a rain event is 72 hours in the Imperial County policy and 24 hours in District Rule 4570. For these mitigation meas ures, the District rule is more stringent.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-152 Animal Housing Mitigation Measures

District Rule 4570 has 14 Class One mitigati on measures and two Class Two mitigation measures, from which operators are required to choose at least seven. Imperial County APCD Policy Number 38 has nine mitigatio n measures, from which facilities are required to choose at least four. Since op erators in Imperial Co unty are required to implement fewer mitigation measures from a m enu that is essentially identical to District Rue 4570, District Rule 4570 is more stringent.

For five of the mitigation m easures, the compliance times differ significantly between the District rule and the Imperial County APCD po licy. For these measures, the Imperial County policy compliance times are longer than the District rule time lines. For these five mitigation measures, the District rule is more stringent because the District rule’s compliance time is much shorter for otherwise identical mitigation measures.

Imperial County APCD policy has one mitigat ion measure - inspect water pipes and troughs and repair leaks - that is more st ringent than the corresponding District Rule 4570 measure. The policy requi res that this measure to be carried out daily, whereas District Rule 4570 requires it to be carried out once every 14 days.

Solid Waste and Separated Solids Mitigation Measures

District Rule 4570 has four Class One mi tigation measures and four Class Two mitigation measures, from whic h facilities are required to choose at least one. Imperial County APCD policy has five mitigation measur es from which facilities are required to

choose at least one.

Imperial County APCD policy requ ires manure piles to be covered year round whereas District Rule 4570 requires that the piles be covered from October through May – the months most likely to have rainfall. Dis trict Rule 4570 does not have a “no-storage” option for operators. Compos ting of manure on-site is a menu option offered by the Imperial County policy, whereas the District rule lists this as a Class Two mitigation

measure. The differences between the two districts, although noteworthy are not expected to influence the e ffectiveness of Rule 4570.

Liquid Manure Handling

Imperial County APCD policy does not address liquid manure handling for beef feedlot operations. District Rule 4570 has a menu of options – five Class One and four Class Two – from which the operator must choose one mitigation measure.

Land Application of Ma nure Mitigation Measures

District Rule 4570 has six Class One mitigati on measures, from which facilities are required to choose at least two. Imper ial County APCD policy has a menu of five mitigation measures from whic h operators are required to c hoose two. Imperial CountySan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-153 APCD allows the application of composted manure with a mois ture content of less than 50% as a mitigation measure. Since the material has been through a composting process, the District views the composted ma terial as no longer animal manure, so the not-apply mitigation measure in the Distric t rule and the application of composted manure in the Imperial C ounty policy are equivalent.

4.2.2.6.4 Requirements for Other Large CAFs

In the same manner as for dairy and beef feedlot operations, District Rule 4570 specifies mitigation methods for large confin ed animal facilities other than dairies and beef feedlots. Imperial Count y APCD Policy 38 only has miti gation measures for diary and beef feedlot operations. In comparing t he two documents, District Rule 4570 is the more comprehensive document.

4.2.2.6.5 Requirements – Suspension and Substituti on of Mitigation Measures

Both rules allow for substitution of one mi tigation measure with an equivalent or more stringent one with the submission of the appropriate application. District Rule 4570 also allows the temporary suspension of a mi tigation measure upon the determination by a

certified veterinarian or nutri tionist that such a suspens ion is necessary for animal health purposes. The District must be no tified within 48 hours, and a new measure must be implemented if the suspension is expe cted to last longer than 30 days. The Imperial County APCD policy does allow for temporary suspension of mitigation

measures under circumstances similar to District Rule 4570.

4.2.2.6.6 Testing, Monitoring, Recordkeeping Requirements

District Rule 4570 requires records to be maintain ed and retained for at least five years, whereas Imperial County AQMD Rule 217 require s records to be reta ined for two years.

District Rule 4570 therefore has a more st ringent record retention requirement.

District Rule 4570 requires facilities not subj ect to the mitigation measure requirements

to maintain sufficient records to demonstrat e their exemption status . Facilities subject to the mitigation measure requirements must maintain sufficient re cords to demonstrate implementation of each mitigati on measure selected. Facili ties must also maintain animal population records. Imperial County AQMD Rule 217 requires the maintenance of animal population records but does not require specific records needed to demonstrate implementation of each mitigation m easure selected. District Rule 4570 is therefore more stringent in the type of records required to be maintained.

4.2.2.6.7 Conclusion – Comparison wi th Imperial County AQMD Rule 217

Overall, District Rule 4570 is more compre hensive than Imperial County AQMD Rule 217 because it covers more types of CAFS and overall, is more stringent.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-154 4.2.2.7 Butte County AQMD Rule 450 – Large Confined Animal Facilities

Butte County AQMD Rule 450 is a permits rule. It outlines, in general terms, the requirements for a complete permit applicat ion and how the staff would evaluate and approve/disapprove the permit application.

4.2.2.7.1 Applicability/Exem ption/Large CAF Definition

The definition of large CAF is identical fo r both rules, with the exception of horse

facilities. District Rule 4570 defines a la rge horse CAF as 3,000 head, whereas Butte County AQMD Rule 450 defines it as 2,500 head. Also, the Butte County AQMD rule specifically mentions lambs in the sheep/goat large CAF defin ition, whereas the District rule only mentions sheep and goats.

4.2.2.7.2 Large CAF Requirements

The Butte County AQMD rule requires large CA Fs to obtain a permit and to submit and implement a mitigation plan; however the nu mber of mitigation measures required and specific mitigation measures is not listed. Additionally the mitigation measures are to meet RACT. District Rule 4570 spells out the number of mitigation measures an operator is required to impl ement and has a menu of specif ic mitigation measures. Operators are required to meet BACT. In this regard, District Rule 4570 is more stringent than the Butte County rule.

4.2.2.7.3 Testing, Records, and Reporting Requirements

The Butte County rule requires that all CAFs record the daily number of animals on-site. These records are to be kept on-site for tw o years and presented if requested. District Rule 4570 requires testing and records be k ept to demonstrate compliance with the operator’s selected mitigation measures. The records are to be kept for five years and presented upon the request of EPA, ARB, or t he District. Because District Rule 4570 covers testing, as well as having a longer reco rd retention time, it is more stringent than Butte County AQMD Rule 450.

4.2.2.7.4 Conclusion – Comparison with Butte County AQMD Rule 450

Overall, District Rule 4570 is more compre hensive than Butte C ounty AQMD Rule 450 because it covers more types of CA FS and overall, is more stringent.

4.2.3 EFFECTIVENESS OF RULE 4570

The number of mitigation measures required fo r each CAF are sufficient and effective in obtaining the required reductions regardless of the type of mitigati on measure selected.

In cases where similar measures or control efficiency exist under a category, Rule 4570 only allows one of those measures to be se lected and account towards the total overallSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-155 number of mitigation measures required, eliminatin g the possibility that the required

reductions are not achieved.

The District performed an emission reduction analysis as Appendix B in the Rule 4570 Staff report, which demonstrated that even if the least costly mitigation measures were selected, the facility would still manage to achieve the emission reductions needed to be in compliance with the Rule. The Staff Repor t also mentions that the least costly

controls are also the least efficient in reducing emissions amongst all the controls. Since facilities’ will most likely elect to impl ement measures that ar e the least costly and since the analyses in appendix B demonstr ates that the emission reduction requirements would be met by selecting the l east costly measures, then it is reasonable to state that any combination of miti gation measures will achieve the required

reductions.

4.2.4 WHY ADDITIONAL MI TIGATION MEASURES (CLA SS ONE AND CLASS TWO)

ARE BEYOND RACT

Rule 4570 has two classes of mitigation me asures available as options. Class One mitigation measures are general ly management practices su ch as washing off manure more frequently, covering feed and manure pile s, and manipulating ani mal diets. Class

one measures have been demonstrated in the Staff Rule to meet BARCT. Class Two mitigation measures are more technically advanced capture and control measures such as enclosing animal housing and venting to a control device, storing feed and manure in bags or enclosed structures and venting to a control device, and using digesters or advanced composting methods for manure tr eatment. Class two measures have been identified as measures/technology being beyond BARCT.

Although there is potential for some of the class two measures to achieve a significant amount of reductions, there exists much uncertainty as to the proper operation and control of these mitigation measures. Bas ed on the most recent information on similar installation and/or studies, some of the m easures serve to the opposite for pollution control and may not necessarily be superior to the Class one measures. The issues

associated with the Class two meas ures are demonstrated below:

Enclose silage in a bag and v ent to a VOC control device with a combined VOC capture

and VOC control efficienc y of at least 80%. Enclose silage in a we atherproof structure
and vent to a VOC control device with a combined VO C capture and VOC control efficiency of at least 80%.

The majority of dairies store the silage piles underneath a tarp or in an Agbag. The entire pile is covered except fo r the face of the pile. The fa ce of the pile is kept open due to the continual need to extract the silage fo r feed purposes. The silage pile is disturbed 2-3 times per day. Because of the ongoing di sturbance to these p iles, it makes it extremely difficult to design a system to captur e the emissions from these piles. In fact, as far as the District is aware, no system has been designed to successfully extract the gases from the face of the pile to capt ure them, and, as impor tant, no study hasSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-156 assessed the potential impacts on silage quality of a continuous air flow across the silage pile, as would be required by su ch a collection system. Therefore, this technology is not only unproven but the ramifica tions of installing such a system are yet

unknown.

Enclose and vent the milk pa rlor to a VOC control device with an overall VOC capture and VOC control efficiency of at least 80% when an imals are in the parlor.

Currently, there is no dairy as far as the Dis trict is aware of that has a fully enclosed milking parlor system. The milking parlor consists of an attached cow holding area, which temporarily holds the cows as they make their way into the milk parlor. This area is generally fully exposed with a partial cover. In order to capture all of the gases

emitted from the milki ng parlor, and to keep an appropriate negative pressure throughout the system, the holding area would also need to be entirely enclosed. The capital required to enclose this large area w ould also be significant. In addition, the milking parlor has the least amount of emissi ons at the entire dairy. Even if such a system could be fully enclosed, a great deal of energy would be required to circulate the air and vent the gases into a control device.

This technology is still unproven and may pan out to be ineffective due to the minor source of emissions. In addition, fully enc losing animals has the potential of causing a great deal of stress and negative health impacts to the animals, which have yet to be evaluated. Therefore, this technology ma y not only be feasible but may prove to be less superior to other mitigation measures.

House animals in an enclosure vented to a VOC control device with a combined VOC capture and VOC control effi ciency of at least 80%.

Although there are smaller dairy farms that ha ve partially enclosed freestall barns, these barns are not fully enclosed and none of t he barns have been found to vent the exhaust through a collection device. These partia lly enclosed barns are also found in the Midwest where the temperature is much c ooler than the Valley. Freestall barns are large structures and the airflow requirement s through these barns are also extremely high, primarily for herd health purposes (for cooling the cow) . The airflow requirements will be even higher in the S an Joaquin valley, where temper atures reach in excess of 110 degrees in the hot summer. Milk cows have a very low threshold for heat stress, which can occur at temperatur es of greater than 70 degree F. Therefore, one of the

most critical factors in r ealizing a completely enclosed barn will be to provide sufficient amount of cooling so as not to cause a detriment to herd heal th. In addition, collection

and control of the exhaust including the large amounts of airflow have not yet been achieved by any facility. Due to these diffi culties and the lack of any installations of this type of technology, it is difficu lt to say at this time whether this technology is considered

feasible.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-157 Cover the lagoon or storage p ond and vent to a VOC control device with an overall VOC capture and VOC control effi ciency of at least 80%.

The covering of a lagoon in itself has been ac hieved in many facilities; however the control of the biogas poses some air quality c hallenges. There is a negative impact of emissions of other pollutant s resulting from the com bustion of biogas generated by anaerobic digestion. These pollutant s include oxides of nitrogen (NO X ), sulfur oxides (SO X ), particulate matter (PM 10 and PM 2.5 ), and carbon monoxide (CO). Current air quality modeling has dem onstrated that the high levels of biogenic and anthropogenic VOC emissions in the San Joaquin Valley Air Basin cause NO X to be the limiting reactant for ozone production. Therefore, in terms of ozone production, large reductions in VOC emissions can be offset by relatively smaller increases in NO X emissions. This factor must be consider ed when determining if anaerobic digesters will reduce ozone formation in the San Joaquin Va lley Air Basin. Furthermore, several recent studies have demonstrated that parti culate matter, especially fine particulate (PM 2.5 ) such as that produced by combustion, c an pose a significant health risk. Since

VOC emissions from waste stor age lagoons are lower than prev iously thought, it is very likely that emissions of combustion contaminants (NO X , SO X , PM 10 , PM 2.5 , CO), including precursors for the formation ozone and fine particulate, will offset the benefits of any VOC reductions from the lagoons.

In addition, although there are several digesters in operation at agricultural facilities, particularly dairies, only one installation in the District is equipped with advanced

emission controls to reduce NO X . This installation has faced considerable difficulty in meeting the very strict NO X requirements that are needed in order for digesters to have an overall positive affect on air quality. The installation has had a variance for more than six months and will require even more ti me because of the inability to meet the

NO X emission limit in the permi t. Other installations are currently uncontrolled and have some of the highest levels of NO X from stationary equipment in the District resulting in an overall increase in ozone-forming pot ential in the San Joaquin Valley.

In conclusion, anaerobic digesters with no or limited controls for combustion pollutants are not beneficial to the protection of ai r quality in the San Joaquin Valley unless significantly controlled. Although tec hnologies for use of biogas with low NO X emissions (such as fuel cells) are being developed, t hese technologies are rarely used and the expense of such technologies is clearly fa r above the level of RACT including BARCT. These technologies have even yet to be consi dered Achieved in Practice as part of the District’s BACT analysis.

While engineered controls are av ailable and included as options in the rule, not only are

some of them not functional or economica lly feasible, they are beyond BARCT and

RACT.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-158 4.3 RULE 4570 IS LEGALLY AN D PRACTICALLY ENFORCEABLE

Pursuant to Rule 4570 Section 7.1.1.2 , owner s/operators subject to the requirements of Rule 4570 (section 5.0) shall maintain the following:

• Copies of all of the facility's permits

• Copies of all laboratory tests, calcul ations, logs, records, and other information required to demonstrate compliance with a ll applicable requirements of this rule, as determined by the APCO, ARB, EPA.

• Records of the number of animals of each species and production group at the facility on the permit issuance date. Quar terly records of any changes to this information shall also be maintained, (e.g . Dairy Herd Improvement Association records, animal inventories done for financial purposes, etc.)

Sections 7.1.1.2.4 through 7.1. 12.21 require specific record keeping conditions for each mitigation measure.

Section 7.2 requires spec ific monitoring or source test ing conditions for each mitigation

measure.

Because permit rules and prohibitory rules have different purposes, they are not directly comparable in terms of monitoring, testing, and records. Prohibitory rules include these requirements so that the oper ator can demonstrate compliance with the rule’s control requirements. In a permit rule, it is ex pected that required m onitoring, testing, and records would be outlined in a prohibitory rule applicable to the source category.

All rules except District Rule 4570 and SacM etro Rule 459 are permit rules. These rules have one records provision - all CAF o perators must keep records of the number of animals at the facility. By contrast, the SacMetro and District rules, which are prohibitory rules, outline specific records for each type of mitigation measure performed in addition to the number-of-animals provisio n. This means the SacMetro and District rules are more stringent than the other air districts’ rules, but that is to be expected given the difference in the types of rules being compared (permit versus prohibitory).

The monitoring and measurement requirement s of Rule 4570, which include minimum testing frequency, are designed to ensur e that adequate testing is conducted to demonstrate compliance with the appropriate mi tigation measures and such measures are operating in a manner that optimizes the VOC reductions.

It should also be noted that owners may us e documents, such as Regional Water Quality Board Waste Nutrient Management Plans that list the numbers of animals in each production group (e.g. calves, heifers, m ilkers, and dry cows) to comply with this monitoring requirement. The ru le will not require owners/operat ors to maintain a set of records exclusively for the use of the San J oaquin Valley Air District. Other monitoring and testing requirements only apply to facilitie s that choose mitigation measures where such monitoring or testing would a ssist in demonstrating compliance.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-159 4.4 EMISSION REDUCTIONS ACHIEVED BY RULE 4570 MEET DISTRICT
PLANNING REQUIREMENTS

Although some of the individua l mitigation measures in District Rule 4570 were in use before Rule 4570 was adopted, there would be no requirement to keep emissionreducing measures in place if District Rule 4570 did not exist. Rule 4570 requires that large CAF operators put together a suite of mi tigation measures into a mitigation plan which would reduce VOC emissions for every process within the CAF. This provides operators flexibility to reduce emissions in th e most effective way for their facility while assuring that VOC emissions from all processe s within the facility are controlled. Within the confines of Rule 4570, operators can change their mitigation measures through mitigation plan updates. The new mitigation measures could not be put in place until approved by the District. In th is way, the mitigation plan to become a “living document” that allows the operators and t he District to implement the best controls as operations change and scientific knowl edge increases. The following paragraphs review the

absolute emission control effectiveness of Rule 4570 in terms of faci lity mitigation plans rather than individual mitigation plans.

According to USDA records, over 59% of Ca lifornia’s cattle and 80% of the state's swine population are raised in the San Joaquin Valle y Air Basin (SJVAB). Approximately 42%

of these animals are raised in facilities defined as "large CAF". In contrast, the majority of poultry, goats, sheep, and other animals are raised in facilities below the "large CAF"

definition. Therefor e, poultry, goats, sheep and other animals are not subject to the control requirements of the rule and no emission control e ffectiveness was calculated

for these CAFs.

In determining the emission control effectiv eness, District staff as sumed that operators would choose to implement the lowest cost mitigation measures. Also assumed was control effectiveness of 10% for mitigation measures that did not have peer-reviewed

research associated with them. With both of these assumpti ons, District staff calculated the control efficiency for each operation withi n a given type of CAF, then the overall control effectiveness for the given type of CAF was determined. The results of that analysis are shown in the table below.

Estimated Overall Control Ef ficiency by CAF Type (a fter full implementation) Type of CAF Dairy Beef Other Cattle Swine All Others

Percent Control 36% 36% 42% 72% Not affected by

rule

Taken as a whole, there are significant emission reductions associated with District Rule 4570 compared to uncontrolled operat ions, even with conservative control efficiencies assumed for individual mitigati on measures. The calc ulated overall control efficiency range is 36% to 72% with large s wine CAFs having the highest overall VOC control efficiency.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-160 4.4.2 Least Costly Mitigation M easure Requirements are Effective

The number of mitigation meas ure required for each CAF are sufficient and effective in obtaining the required reductions regardless of the mitigation measure selected. In several cases, Rule 4570 only allows one of multiple measures under a category to be selected that go towards the total overa ll number required due to similar control efficiencies or similarity in the type of mitigation. The analysis shown below and also included in Appendix B of Ru le 4570 Staff report, demonstrate s that even if the least costly mitigation measures are selected, the facility would still manage to get the emission reductions needed and be in complianc e with the Rule. The Staff Report also mentions that the least costly controls are also the least ef ficient in reducing emissions amongst all the controls. Since facilities’ wi ll most likely elect to implement measures that are the least costly and since the anal yses in appendix B of Rule 4570 staff report

demonstrates that the emissi on reduction requirements would be met by selecting the least costly measures, then it is reasonable to state that any combination of mitigation measures will achieve the required reducti ons. In addition, since the mitigation measures in Rule 4570 meet BARCT, t hen these measures also meet RACT.

4.4.2.1 EMISSION REDUCTION ANALYSIS

4.4.2.1.1 Background

In performing the analysis, several generalizat ions were made to reflect conservative

emission reduction results. These include:

• All mitigation measures achieve VOC r eductions from facilities that use the mitigation measures. The rule achieves reductions by requiring the mitigation measure or by prohibiting t he owner/operator from ceasing to use the mitigation

measure.

• Facilities will only impl ement the number of mitigat ion measures required by Proposed Rule 4570. Staf f acknowledges that industry may do more than is required. Since the additi onal mitigation measures t hat industry implements that go beyond rule requirements can be ceased at any time, thus staff does not believe these reductions are permanent and the direct result of Rule 4570. Therefore, staff does not believe that it is appropria te to claim such reduction or costs in the Rule 4570 development process.

• Facilities will choose the mitigation m easures that are lo west cost BARCT options. Again, staff acknowledges t hat facilities may choose more costly options. Additionally many existing facilit ies already have installed more costly options, which are more effective at reducing VOC emissions. However, as mentioned in the previous bullet owner/ operators could cease using the more costly option at anytime, thus staff does not believe that it is appropriate to claim

reduction achieved in cases where the mo re costly option achieves greater reductions than the less costly option.

• In some cases, no data could be found in the literature search on which to base a control efficiency factor for these practi ces. The District has conservatively
assumed a minimal 10% control effect iveness. As information becomesSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-161 available, it will be added to this methodol ogy. Additional air quality benefits and control effectiveness for these practi ces would need to be further evaluated through research studies and literature searches.

• Emissions at each source are affected by emission reductions achieved from sources upstream of that source. For example, a mitigation measure for feed that reduces VOC in manure by 10% caus es the emission factor for the lagoon, where the manure is processed, to have 10% less emissions.

• Approximately 29% percent of the dairies have no freestalls, based on California Dairy Farmers Association (CDFA) data provided by Mike Francesconi.

4.4.2.1.2 Excluded Acti vities and Facilities

Based on the assumptions above, staff anal yzed the cost effectiveness of least expensive BARCT options t hat owners/operators would lik ely choose to implement.

4.4.2.1.3 Summary of Emissions and Reductions

Tables 3 through 7 summarize the emission reduction calculations from the control

measures included in the rule. Details of t hose calculations are discussed in Sections D through G.

4.4.2.1.4 Control Efficiency Calculations for Dairies

The calculations for dairies are based on t he following breakdown of the emission factor by source category.

Emissions from Dairy Locations

Emission

Unit Emission

Factors
(Freestall Dairies) Emission Factors
(Dairies without Freestalls) Reference

Manure & Feed in Housing 5.5 lb/hd-yr 4.8 lb/hd-yr 12/14/05 Draft Breakdown for Permitting

Enteric

Emissions in

Housing 7.6 lb/hd-yr 7.6 lb/hd-yr 12/14/05 Draft Breakdown for Permitting

Enteric

Emissions in Milking Center 0.7 lb/hd-yr 0.7 lb/hd-yr 12/14/05 Draft Breakdown for Permitting

Manure

Emissions in Milking Center 0.2 lb/hd-yr 0.2 lb/hd-yr 12/14/05 Draft Breakdown for Permitting

Liquid Manure Handling 2.7 lb/hd-yr 2.3 lb/hd-yr 12/14/05 Draft Breakdown for Permitting

Land Application 5.0 lb/hd-yr 3.7 lb/hd-yr 12/14/05 Draft Breakdown for Permitting

SUBTOTAL 21.7 lb/hd/y 19.3 lb/hd-yr Value used for permitting purposes and emission inventory calculationsSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-162 Solid Bedding Storage Piles 0.2 lb/hd-yr 0.2 lb/hd-yr 1/26/05 Schmidt Flux Chamber Presentation for ARB Meeting

Feed Piles 0.63 lb/hd-yr 0.63 lb/hd-yr Data submitted to DPAG by

Schmidt via ARB. NOTE: this only considered feed in

feedlanes. It did not include

emissions from every feed

emission source.

Please note that the values in the above t able for: manure & feed in housing; enteric emissions in housing; enteric emissions in milking center; manure emissions in milking center; liquid manure handling; and land application subtotal to the current emission factors for permitting purposes. Since these values are used for permitting, these (21.7 lb/hd-yr and 19.3 lb/hd-yr) were used in all calculations which applied to the entire facility to avoid overestimating emissions and emission reductions and maintain consistency.

However, the Dairy Permitting Advisory Committee and APCO reports and the permit department noted that not all emission sources were included in these estimates. Two

sources for which emissions were not count ed are the solid beddi ng storage piles and the feed piles outside of the animal housing. Since there is research documenting emission from and VOC control options for thes e sources, staff estimated the emissions from these sources by using data from Schmidt's research. These emission factors are only used for calculating reductions from mitigation measures that control VOC emissions from solid bedding or feed storage piles.

Based on Table 8 and the CDFA data showing that approximately 29% of dairies have no freestalls, staff calculated the weighted averages for emissions for each area on the dairy and the facilities as a w hole by the following equation:

Weighted average = Emission factor for facilities with freesta lls x 71% + Emission factor

for facilities with no freestalls x 29%

The weighted averages, which staff used to calculate control efficiency of various control measures, are listed below.

Weighted Emissions from Dairy Locations

Emission Unit Emission

Factors
(Freestall Dairies) Emission Factors
(Dairies without Freestalls) Weighted Emission

Factors

Manure & Feed in Housing 5.5 lb/hd-yr 4.8 lb/hd-yr 5.3 lb/hd-yr

Enteric Emissions in Housing 7.6 lb/hd-yr 7.6 lb/hd-yr 7.6 lb/hd-yr

Enteric Emissions in Milking Center 0.7 lb/hd-yr 0.7 lb/hd-yr 0.7 lb/hd-yr

Manure Emissions in Milking Center 0.2 lb/hd-yr 0.2 lb/hd-yr 0.2 lb/hd-yrSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-163 Liquid Manure Handling 2.7 lb/hd-yr 2.3 lb/hd-yr 2.6 lb/hd-yr

Land Application 5.0 lb/hd-yr 3.7 lb/hd-yr 4.6 lb/hd-yr

SUBTOTAL 21.7 lb/hd/y 19.3 lb/hd-yr 21.0 lb/hd-yr

Solid Bedding Storage Piles 0.2 lb/hd-yr 0.2 lb/hd-yr 0.2 lb/hd-yr

Feed 0.63 lb/hd-yr 0.63 lb/hd-yr 0.63 lb/hd-yr

1. FEED PRACTICES CONTROL MEASURES

Option 1: Feeding according to NRC guidelines

This practice is intended to minimize t he excess nutrients fed to the animals. Based on research suggesting that nitrogen conten t in feed is directly proportional to nitrogen content in manure, staff belie ves that feeding according to the NRC guidelines

, which minimizes excess nutrients in the diet, would reduce VOC emissions. Since there is little data quantif ying this reduction, the 10% default is

assumed. Since it reduces the content of VOC precursors being fed to the animal (entering the animal) it will reduce the VOC precursors ex iting the animal and thus being treated in each animal waste system. It will also reduce the emissions from feed in the housing and stockp iles because there will be le ss VOC precursors in the feed, which could eventually decompose. Therefore, the 10% reduction was applied to the facility wide emission factors. This is expected to be used by all facilities since

reductions in excess nutrient s, such as protein, in feed would not increase costs significantly. Any additionally labor empl oyed to determine what feed formulations would meet NRC guidelines w ould likely be offset by lower costs for feed due to

lower nutrient content. The reduction calculations are:

Option 1 Reductions = 10%

Option 2: Store grain in a weatherproof storage structure from October through May

This measure is intended to reduce excess mo isture. Since the microorganisms that degrade organic material to form VOCs require moisture, this is expected to reduce

the VOC emissions from the fe ed storage. Since there is little data quantifying this reduction, the 10% default is assumed. Howe ver, it only affects the emissions from feed and these emissions were already reduced by 10% due to implementing an

NRCS diet. The reduction calculations are:

Option 2 Reductions = 0.63 lb/hd-yr (e missions from feed) x 90% (emissions remaining after implementing Option 1) x 10% (control efficiency from Option 2) = 0.06 lb/hd-yr

This is out of an emission factor of 21.0 lb/hd-yr.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-164 The percent reductions = 0.06 lb/hd-yr ÷ 21.0 lb/hd-yr = 0.3%

Option 3 and 4: Two mitigation measur es for cleaning feed from housing

These measures are intended to minimize mo isture, surface area for VOCs to move

from the feed to the atmo sphere, and anaerobic digestio n due to wet conditions and thick depths of animal waste. Data sugges ts that these practices would minimize VOC emissions, however there are no peer-rev iewed articles that quantify this. Therefore, staff assu med a default reduction of 10% for each measure. However, it only affects the emissions from feed and t hese emissions were already reduced by Option 1 and Option 2.

Option 3 Reductions = 0.63 lb/hd-yr (e missions from feed) x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after implementing Option 2) x 10% (contro l efficiency) = 0.05 lb/hd-yr

Option 4 Reductions = 0.63 lb/hd-yr (e missions from feed) x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after implementing Option 2) x 90% (emissions re maining after implementing Option 3) x 10% (control efficiency) = 0.05 lb/hd-yr

The total reductions from Option 3 and 4= 0. 05 lb/hd-yr (Option 3) + 0.05 lb/hd-yr (Option 4) = 0.10 lb/hd-yr

This is out of an emission factor of 21.0 lb/hd-yr.

The percent reductions = 0.10 lb/hd-yr ÷ 21.0 lb/hd-yr = 0.5%

2. SILAGE PRACTICES

Option 5: S ilage practices

These measures are intended to minimize mo isture, surface area for VOCs to move

from the feed to the atmo sphere, anaerobic digestion due to wet conditions, and excess nutrients in animal waste due to silage practices. Data suggests that these practices would minimize VOC emissi ons, however there are no peer-reviewed articles that quantify this. Therefore, st aff assumed a conservative reduction of 10% for each measure. However, it only a ffects the emissions from feed and these emissions were already reduced by Option 1.

Option 5 Reductions = 0.63 lb/hd-yr (e missions from feed) x 90% (emissions remaining after implementing Option 1) x 10% (control efficiency) = 0.06 lb/hd-yr

This is out of an emission factor of 21.0 lb/hd-yr.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-165 The percent reductions = 0.06 lb/hd-yr ÷ 21.0 lb/hd-yr = 0.3%

3. MILK PARLOR PRACTICES

Option 6: Flush/clean milk parlor after each milking

In the studies used to calcul ate the emission factor this practice was being done. Therefore, the baseline assume s that all facilities implement this practice. Thus, no reduction from the baseline is anticipated. This measure was included to ensure all current and future facilities implement practices accounted for in the baseline

emission estimate.

4. FREESTALL PRACTICES

Options 7 and 8: Vacuum or scrape freesta lls after each milking or flush more frequently than milking and rake, harrow, scr ape, or grade bedding at least once every two weeks

Typically, facilities flush once per m ilking or scrape once a day (once every two milkings). Typically, facilities clean to bedding no more than once a month. By cleaning twice as frequently you cut the time manure is in the freestalls by half. Therefore you reduce the emissions is the fr eestalls by 50%. The freestall emissions are approximately 97% of t he total emissions from manure and feed in the housing (3% of the emissions are in the corrals). The reduction calculations are:

Freestall emission = 5.3 lb/hd-yr x 97% (emissions from freestalls)

= 5.14 lb/hd-yr from freestalls.

Options 7 and 8 Reductions = 5.14 x 90% (e missions remaining after implementing Option 1) x 98% (emissions remaining after implementing Option 3 and 4) x 50% (control efficiency)= 2.3 lb/hd-yr

This is out of an emission factor of 21.7 lb /hd-yr, but only affects 71% of the facilities (facilities with freestalls).

The percent reductions = 2.3 lb/hd-yr ÷ 21.7 lb/hd-yr x 71% = 8%

5. CORRAL PRACTICES

Option 9, 10, 11, 12, 13, and 14: All housing measures to clean corals, manage manure depth, and minimize moisture

These are intended to minimize moistu re and anaerobic digestion due to wet conditions or thick depths of manure that prevents the manure from drying completely and oxygen continuing to come in contact with all animal waste in theSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-166 pens and corrals. Data suggests that this would minimize VOC emissions, however there are no peer-reviewed articles that quant ify this. Therefore, staff assumed a

default reduction of 10% for each measure. The corrals account for approximately

3% of the emissions from the animal housing. The reduction per measure is:

Corral emissions = 5.3 lb/hd-yr x 3% (emissions from corrals) =0.16 lb/hd-yr from corrals

Option 9 Reductions = 0.16 x 90% (emissions remaining after implementing Option 1) x 10% (control efficiency)= 0.01 lb/hd-yr

Option 10 Reductions = 0.16 x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after implementing Option 9) x 10% (control efficiency)= 0.01 lb/hd-yr

Option 11 Reductions = 0.16 x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after im plementing Option 9) x 90% (emissions remaining after implementing Option 10) x 10% (control efficiency)= 0.01 lb/hd-yr

Option 12 Reductions = 0.16 x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after im plementing Option 9) x 90% (emissions remaining after implementing Option 10) x 90% (emissions remaining after implementing Option 11) x 10% (cont rol efficiency)= 0.01 lb/hd-yr

Option 13 Reductions = 0.16 x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after im plementing Option 9) x 90% (emissions remaining after implementing Option 10) x 90% (emissions remaining after implementing Option 11) x 90% (emissions re maining after implementing Option 12) x 10% (control efficiency)= 0.01 lb/hd-yr

Option 14 Reductions= 0.16 x 90% (emissions remaining after implementing Option 1) x 90% (emissions remaining after im plementing Option 9) x 90% (emissions remaining after implementing Option 10) x 90% (emissions remaining after implementing Option 11) x 90% (emissions re maining after implementing Option 12) x 90% (emissions remaining after im plementing Option 13) x 10% (control efficiency)= 0.01 lb/hd-yr

Options 9 through 14 Reduction = 0.01 lb/hd-yr (Option 9) + 0.01 lb /hd-yr (Option 10) + 0.01 lb/hd-yr (Option 11) + 0.01 lb/hd-yr (Opt ion 12) + 0.01 lb/hd- yr (Option 13) + 0.01 lb/hd-yr (Option 14) = 0.06 lb/hd-yr

This is out of an emission factor of 21.0 lb/hd-yr.

The percent reductions = 0.06 lb/hd-yr ÷ 21.0 lb/hd-yr = 0.3%San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-167 6. SOLID MANURE/SEPARATED SOLIDS PRACTICES

Options 15 and 16: Cover piles outside the pens

These measures are intended to minimize moisture and anaerobic digestion due to wet conditions. There is no data regardi ng the amount of emissions from the manure storage piles, therefor e staff conservatively estimated the separated solids and the manure piles emit approx imately the same amount of VOC. Since there is little data regarding reductions staff assu med a default reduction of 10% for each mitigation measure. The reduction per measure is:

Option 16 Reductions = 0.2 lb/hd-yr (p iles) x 90% (emissions remaining after implementing Option 1) x 10% = 0.02 lb/hd-yr reductions.

Option 17 Reductions = 0.2 lb/hd-yr (p iles) x 90% (emissions remaining after implementing Option 1) x 10% = 0.02 lb/hd-yr reductions.

Option 16 and 17 Reductions = 0.02 lb/hd-yr + 0.02 lb/hd-yr = 0.04 lb/hd-yr

This is out of an emission factor of 21.0 lb/hd-yr.

The percent reductions = 0.04 lb/hd-yr ÷ 21.0 lb/hd-yr = 0.2%

7. LIQUID MANURE PRACTICES

Option 17: All of the lagoon control options

AEM, 3/03, Vol 69, pg 1710-1720, indica tes a 80-93% decrease in emissions from swine phototrophic lagoons; ILOC, 1995, pg 80-85, DiSpirito, found the same in swine lagoons; and JFB, 70:39-44, Hiraishi, found the same in sewage wastewater lagoons. The loading rate contributing to a phototrophic are typically found in lagoons utilizing a solid separator, NRCS guidelines for anaerobic lagoon design, and microaerobic nutrient management. Howeve r, these studies were for swine and not cattle. Based on AP42 by E PA, swine emit 63.5% of the volatile solids that cattle do. Therefore, in order to be conservati ve, staff assumed that cattle lagoons are 63.5% as efficient as swine lagoons ( 63.5% x 80% = 50%). The baseline is 2.3 lb/hr/yr, however there are fewer em issions due to the use of the NRC feed guidelines. The reduction per measure is:

Option 17 Reductions = 2.6 lb/hd-yr x 90% (emissions remaining after implementing Option 1) x 50% (control efficiency) = 1.17 lb/hd-yr

This is out of a total emissi on factor of 21.0 lb/hd-yr.

The percent reductions = is 1.17 lb/hd-yr ÷ 21.0 lb/hd-yr = 6%.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-168 8. LAND APPLICATION PRACTICES

Option 18 & 19: All methods for crop application.

These practices are intended to rapidly land incorporate the manure or waste water. The soil is expected to act as a biofilter since it is an organic media with significant microbial populations and airflow. Resear ch suggests biofilters range in efficiency from 10% to 90% depending on how they ar e maintained. Conservatively staff

assumed 50% control. The baseline emissi ons from crop application are 4.6 lb/hdyr. The reduction per measure is:

Options 18 & 19 Reductions = 4.6 lb/ hd/year x 90% (emissions remaining after implementing Option 1) x 50% (contro l efficiency) = 2.07 lb/hd-yr

This is out of a total emissi on factor of 21.0 lb/hd-yr.

The percent reductions = is 2.07 lb/hd-yr ÷ 21.0 lb/hd-yr = 10%.

9. TOTAL REDUCTIONS

The total percent reductions can be calc ulated by summing the percent reductions for each mitigation measure above.

Total Reductions = 36%

As shown in the analysis above, the least cost ly mitigation measures and the most likely to be selected by facilities, achieves a si gnificant amount of emission reductions, far greater than the 25% reductions required by Rule 4570. Since, Rule 4570 meets BARCT, and since BARCT is more stringent t han RACT, then Rule 4570 also meets the

definition of RACT.

5 CONCLUSION AND FUTURE PLANS

In determining whether District Rule 4570 meets RACT, the analysis has considered federal rules that cover large CAFs as well as rules in other Californi a air districts. It

can be concluded that District Rule 4570 exc eeds RACT for the following reasons:

• There are no federal rules that apply to this category; therefore federal rules (CTG, NSPS. NESHAP) do not infer RACT for large CAFs.

• No rule has been approved into the Californ ia SIP for this s ource category, so there is no precedent t hat outlines RACT.

• SB 700 required California air districts with certain non-attain ment status to implement BARCT. District Rule 4570 was designed to satisfy SB 700 and as a consequence, implements BARCT for large CAFs within the Valley. BARCT is a

level of control that is cons idered more stringent than RACT.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-169 • The mitigation measures outlined in Rule 4570 have been required as Best Available Control Technology (BACT) for new and modifying sour ces that trigger

the BACT threshold.

• The Rule achieves a significant level of control even if the least costly measures are selected by the source.

• Rule 4570 requires mitigation measures for all large Confined Animal Facilities and for all major sources of emissions from a facility.

• A comparison of other California air distri ct rules to District Rule 4570 shows that Rule 4570 is as stringent as rules in some air districts and is more stringent than

rules in certain other air dist ricts. No California air di strict rule is overall more stringent than District Rule 4570 for this source category.

Although District Rule 4570 is more stringent than RACT for large CAFs, District staff is pursuing additional emission reductions fr om CAFs in an upcoming rule project. Reducing VOC emissions from CAFs is a st rategic control measure in the District’s ozone attainment plan. The amendments to Rule 4570 will seek to obtain as much reduction of volatile organic compounds (V OCs) from CAFs as expeditiously practicable, technologically feasible, and economically reasonable, as determined by the District’s Governing Board. The District’ s attainment plan anticipates an additional 30% reduction in VOCs by 2014 as a result of the rule amendments. These additional controls will effectively move Rule 4570 even further beyond RACt in terms of applicability and stringency.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-170 

### Rule 4601 – Architectural Coatings

Emissions Inventory Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 0.0 0.0 0.0 0. 0 0.0 0.0 0.0 0.0

VOC 9.1 9.4 9.6 9.7 10.2 10.5 10.9 11.2
(Source: District 2007 Ozone Plan)

District Rule 4601 Description

This rule is applicable to any person who supp lies, sells, offers for sale, applies, or solicits the application of any architectural coating, or who manufactures any architectural coating for use within the Distric t. District Rule 4601 specifies VOC coating

limits from the state’s (ARB’s) 2000 Suggested Control Measure (SCM).

How does District Rule 4601 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

There is no CTG for this source category.

B. EPA – Alternative Control Technology (ACT)

There is no ACT for this source category.

C. Standards of Performance fo r New Stationary Sources (NSPS)

There is no NSPS for this source category.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

There is no NESHAP or MACT for this source category.

How does District Rule 4601 compare to rules in other air districts?

District staff compared VOC lim its, optional control require ments, and work practice standards in District Rule 4601 to comparable requirements in rule s from the following

California nonattainment areas:

• South Coast AQMD Rule 1113, as amended July 2007San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-171 • Bay Area AQMD Regulation 8 Rule 3, as amended November 2001

• Ventura County APCD Rule 74.2 , as amended November 2001

• Sacramento Metro AQMD Rule 442, as amended May 2001

A. South Coast AQMD Rule 1113

SCAQMD has introduced new coating limits t hat are more stringent than the state’s 2000 SCM. As a result, coatings that m eet these new limits have been introduced in the South Coast area beginning in 2005. T he new limits were phased-in over three years, with the final phase effective in July 2008.

District Rule 4601 is undergoing rule developm ent process to incorporate South Coast limits for architectural coatings. Amendments are expected to be adopt ed in the fourth quarter of 2009.

B. Bay Area AQMD Regulat ion 8 Rule 3; Ventura County APCD Rule 74.2, Sacramento Metropolitan AQMD Rule 442

These air districts adopted ARB’s 2000 SCM for architectural coatings. Rule 4601 used the same SCM as a template and , therefore, is curr ently at the same level of stringency

as these air district rules. District Ru le 4601 is undergoing rule development process to incorporate South Coast’s limits for this source category. Rule 4601 amendments are expected to be adopted in the fourth quarter of 2009.

Conclusion

After careful evaluation of prohibitory ru les in other California nonattainment areas,

District staff concludes that District Rule 4601 satisfies RACT for architectural coatings.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-172 

### Rule 4603 – Surface Coating of Metal Parts and Products

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 0 0 0 0 0 0 0 0

VOC 0.57 0.60 0.66 0. 68 0.76 0.81 0.86 0.88
(Source: District 2007 Ozone Plan)

District Rule 4603 Description

District Rule 4603, recently amended on Oct ober 16, 2008, controls VOC emissions from miscellaneous metal part and products , including large appliances and metal

furniture. The rule also controls em issions organic solvent cleaning, storage and disposal of solvents, and waste solvent materials associated with such coating operations. Rule 4603 establishes VOC c ontent limits for coatings used in the manufacture and fabrication of metal parts and products as well as separate VOC limits for coatings used in large appliances and metal fu rniture. Except for large appliances or metal furniture, the general VOC limits for baked coatings and for air-dried coatings is 275 grams per liter and 340 grams/liter, respectively. Ex cept for large appliances or metal furniture coating operations, the VOC limits for specialty coatings (except for) ranging from 360 grams/liter to 880 grams/liter for baked coatings and 420 to 880 for air-dried coatings, depending on the category of coating. Specialty coating category includes camouflage, extreme perform ance, heat resistant, high gloss, high performance architectural, hi gh temperature, metallic topc oat, pretreatment primer, silicone release, solar absorbent, and solid film lubricant. For large appliances or metal furniture coating operations the coating VO C limits range from 275 grams/liter to 420 grams/liter depending on the type of coating and whether baked or air-dried. The VOC content limit for organic solvent cl eaning materials is 25 grams/liter.

In lieu of using compliant coatings and solvents, District Rule 4603 allows the use of an APCO-approved VOC emission control system with an overall capture and control efficiency of at least 90 percent by weight. Also, the rule includes coating application methods, work practice standards, recordkeeping, and test methods.

District Rule 4603 exempts some source operat ions from certain requirements of the rule. It exempts facilities use a total of 55 ga llons or less of non-compliant coatings per rolling consecutive 365-day period. Also ex empt are sources that are regulated by other District’s coating rules such as Ru le 4661 (Organic Solvents), Rule 4602 (Motor vehicle and Mobile Equipm ent Coating Operations), Rule 4612 (Motor Vehicle and Mobile Equipment Operations Phase II), and Rule 4605 (Aerospace Assembly and Component Manufacturing Operations) Rule 4604 (Can and Coil Coating Operations). Touch-up and repair, polyester resin operations and the applicat ion of polyester resin to metal parts and products are exempt from District 4603. Some solvent cleaningSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-173 operations are also exempt (e .g., cleaning solar cells, lase rs, high precision optics, laboratory tests, analyses or bench scale/res earch projects, paper-based gasket, etc.).

How does District Rule 4603 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

1. CTG for Large Appliance Coatin gs (EPA 453/R-07-004), September 2007

The 2007 CTG for large appliance coatings mentioned that EPA pub lished in December 1977 a CTG for this same category, entitled C ontrol of Volatile Organic Emissions from Existing Stationary Sources, Volume V: Surface Coatin g of Large Appliances OC Emissions (EPA-450/2-77-034). The 1977 CTG c oating VOC limit is 2.8 lb/gallon for prime, single or topcoat app lication area, flashoff area a nd oven. The 2007 CTG limits for general, one component coating of 2.3 lb/gall on (air-dried or baked) is more stringent

than the 1977 CTG VOC limit of 2.8 lb/gal. Also, the 1977 CTG specified only three coating categories whereas 2007 CTG has eight different categories. For this reason, District staff placed more emphasis in eval uating the more current emission standards

of the 2007 CTG as RACT instead of the 1977 CTG.

The 2007 CTG applies to large appliance part s and products coating operations whose VOC emissions, before considerat ion of controls, are equal to or greater than 15 lb/day. The CTG allows an alternative applicability tr igger level of 3 tons of VOC per 12-month rolling period. The CTG coatings VOC cont ent limits range from 2 75 grams/liter (2.3 pounds/gallon) to 420 grams/liter (3.5 pounds/gallon) of coat ing, less water and exempt compounds, as applied, dependi ng on the type of coating and whether air-dried or baked. In lieu of complying with the VOC c oatings limits, an operator may install and operate a VOC emission contro l system that has an overall capture and control efficiency of at least 90 percent, by weight.

The CTG establish work practice standards to reduce VOC emissions. The standards include: storing all VOC coat ings, thinners, and cleaning ma terials in closed containers, minimizing spills of VOC-containing coati ngs, thinners, cleaning spills immediately, conveying VOC-containing materials in cl osed containers or pipes, closing mixing

vessels which contain VOC c oatings and other materials ex cept when specifically in use, and minimizing emissions of VOC during cleaning of st orage, mixing, and conveying equipment.

The CTG exempts stencil coatings, safety-indi cating coatings, solid-film lubricants, electric-insulating and thermal-conducting co atings, touch-up and repair coatings, and coating application utiliz ing hand-held aerosols.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-174 2. CTG for Metal Furnitur e Coatings (EPA 453/R-07-005)

The CTG applies to metal furniture coating operations. The applicability VOC emission threshold, coating VOC limits, VOC emission control system control efficiency, and work practice standards, and exemptions are iden tical to the requirements discussed above for the CTG on large parts and products. Therefore, the CTG does not apply to these refinishing facilities. Based on the above disc ussion, District staf f deems that District Rule 4606 satisfies Reasonably Avail able Control Technology (RACT).

3. CTG for Surface Coating of Miscellaneous Metal Parts and Products (EPA450/2-78-015)

The CTG applies to surface coating of misce llaneous metal parts and products. The coating VOC limits is 3.5 lb/ gallon for air or fo rced air-dried and 4.3 lb/gallon for clear coat. Nothing is mentioned about the VOC limit for baked coatings as well for specialty coatings. The CTG allows the use of a VO C control system with an efficiency of 90% in lieu of using compliant coatings. In additi on, the CTG included discussions on different coating application equi pment spray, electrodeposition, elec trostatic, dip coating, etc. However, unlike the CTGs for large appli ance and metal furniture coating operations, the miscellaneous parts and products CTG d oes not specify any applicability VOC emission threshold and any work practice standards.

The coatings VOC limit s in CTG EPA-450/2-78-015 for miscellaneous parts and products of 3.5 lb/gallon for air or forced air-dried and 4.3 lb/gallon for clear coat are less stringent than District Rule 4603 VOC limit of 2.8 for general co ating, air-dried. Rule 4603 prohibits the use of organic solven ts for cleaning operations that exceed 25 grams per liter of material, but the CT G does not have any VOC limits for solvent cleaning operations.

4. CTG for Miscellaneous Metal and Plasti c Parts Coatings (EPA-453/R-08-003)

The CTG applies to each miscellaneous metal products and miscellaneous plastic parts coating units at a facility where the total actual VOC emissions from all miscellaneous metal product and plastic parts surface coati ng operations, including related cleaning activities, at that facility are equal to or ex ceed 6.8 kg/day (15 lb/day), or an equivalent level of 2.7 tons per 12-month rolling peri od, before considerati on of controls. EPA does not recommend the CTG’s control approaches for facilities that emit below this level because of the very low emissi ons reductions that can be achieved.

For comparison with Rule 4603 (Surface Coat ing of Metal Parts and Products), only the CTG requirements that pertains to coat ing operations associated with miscellaneous metal parts and products will be discussed in th is RACT analysis. For miscellaneous metal parts and products coating operations , the CTG coatings VOC content limits range from 2.3 pounds/gallon to 6.2 pounds/gallon) of coating, excluding water and exempt compounds, as applied, depending on the type of coating and whether air-dried or baked. As an option, the CTG allows the coatings VO C limits to be expressed inSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-175 terms of mass of VOC per volume of coating solids, as applied, for facilities that use a combination of low-VOC coatings and add- on control equipment on a coating unit. Using an assumed VOC density of 7.36 pounds per gallon, the e quivalent limits in terms of mass of VOC per volume of solids, as applied, ranged from 3.35 pounds per gallon solids to 38 pounds per gallon solids, dependi ng on the type of coating and whether airdried or baked.

The CTG also allows a facility to use add- on control equipment wit h an overall control efficiency of 90 percent install and operate a VOC emission control system that has an overall capture and control efficiency of at least 90 percent in lieu of using low-VOC coatings and specifi ed application methods.

The CTG VOC limits and application methods do not apply to aerosol coating products or powder coatings. Except for work pr actice standards, CTG VOC limits do not apply to stencil coatings, safety-indicating coat ings, solid-film lubricants; and electricinsulating and thermal-conducting coatings.

The CTG included discussions on different c oating application equipment such as air spray system (conventional, airless, air-assist ed airless, electrostatic, HVLP, and zincarc), dip coating, powder coatings, flow c oating, roll coating, electrocoating, and autophoretic.

The CTG establish work practice standards for coating-related activities to reduce VOC

emissions. The standards include: store all VOC-containing coat ings, thinners, and coating-related waste materials in closed containers; ensure t hat mixing and storage containers used for VOC-containing coatin gs, thinners, and coating-related waste materials are kept closed at all times except when depositing or removing these materials; minimizing spills of VOC-containing coatings , thinners, and coating-related waste materials; convey VOC-containing coat ings, thinners, and coating-related waste

materials from one location to another in closed containers or pipes.

The CTG does not specify any VOC limits for solvent cleaning operations other than work practice standards. The work practice standards for cleaning materials tor educe

VOC emissions. The standards include: store all VOC-containing cleaning materials and used shop towels in closed containers; (2) ensure storage containers used for VOC-containing cleaning materials are kept closed at all times except when depositing or removing these materials; minimizing spills of VOC-c ontaining cleaning materials; convey VOC-containing cleaning materials from one location to another in closed containers or pipes; and minimize VOC emi ssions from cleaning application, storage, mixing, and conveying equi pment by ensuring that equipment cleaning performed without atomizing the cleaning solvent and all spent solvent is captured in closed

containers.

Rule 4603 general coating limit s are: Air-dried - 275 grams per liter (2.3 pounds per gallon) of coating, less water and exempt compounds, as applied. Baked – 340 grams per liter (2.8 pounds per gallon) of coat ing, less water and exempt compounds, asSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-176 applied. The specialty coating limits fo r baked range from 880 grams per liter (7.3 pounds per gallon) to 360 grams per liter (3.0 pounds per gallon) of coating, less water and exempt compound, as applied, depending on t he type of specialty coating; and for air-dried the limits range from 880 grams per liter (7.3 pounds per gallon) to 420 grams per liter (3.5 pounds per gallon) of coat ing less water and exempt compound, as applied, depending on the type of specialty coating. Coatings that are not specified in the table of VOC limits for specialty coat ings are defaulted to the general coating category as specified above.

In comparison with the Rule 4603, the CT G limits are less stringent than Rule 4603 general coating limits (baked – 2.8 pounds per ga llon; air-dried – 2.3 pounds per gallon) for the following coating types: electric-insul ating varnish - 3.5 pounds per gallon (baked or air dried) ; etching filler - 3.5 pounds per gallon (baked and air dried); mold seal - 3.5 pounds per gallon (baked or air dried); pan backing - 3.5 pounds per gallon (baked or air dried) ; prefabricated ar chitectural multi-component – 3.5 pounds per gallon (airdried); prefabricated architectural one-co mponent – 3.5 pounds per gallon (air-dried); pretreatment coating – 3.5 pounds per gall on (baked and air dried); vacuum-metalizing – 3.5 pounds per gallon (baked or air-dried) . In addition, the CTG limits for baked camouflage coating and for metallic coating of 3.5 pounds per gallon is less stringent than Rule 4603 limit of 3.0 pounds per ga llon. The CTG limit for baked extreme performance coating of 3.0 pounds per gallon is slightly st ringent than Rule 4603 limit of 3.5 pounds per gallon. Repair and touch-up coating is exempt in Rule 4603 but the CTG has a VOC limit of 3.5 pounds per ga llon (air-dried) and 3.0 pounds per gallon (baked).

In response to April 1, 2009 EPA comments t hat the 2008 CTG for Miscellaneous Metal and Plastic Coatings is more stringent than Rule 4603 (VOC limits for baked extreme performance, repair and touch-up coatings, and work practices for miscellaneous parts and products), District staff belie ves that Rule 4603, overall, is as stringent as the CTG for the following reasons:

• Rule 4603 only exempts touch-up and r epair coating, but the CTG has more exempt coatings (i.e., stencil coatings, safety-indicating coatings, solid film lubricants, electric-insulating and the rmal-conducting coatings, powder coatings, magnetic data storage disk coatings, plasti c extruded onto metal parts to form a coating, and aerosol coatings. Except for powder coatings and aerosol coating exemption, the CTG provides no expl anation why such coatings have been exempted. District staff believes that the potential VOC em issions from the CTG’s numerous exempt coating cat egories as menti oned above would be greater than the emissions from just one exempt touch-up and repair coating category. It is important to mention that District Compliance staff’s field inspections show that, for touch and repair, operators genera lly use the same VOC-compliant coatings t hat are being applied during the fabrication process because of ease of color matching and for economic reason that they do not have to buy a separate coating ex clusively for touch-up and repair.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-177 • Although the CTG limit of 3. 0 lb/gal is slightly lowe r than Rule 4603 limit of 3.5 lb/gal for baked extreme performance coating, it is important to mention that the CTG has higher limits for 10 coating cat egories compared to a higher limit for only one coating in Rule 4603 as discussed above. District staff believes that the potential emissions fr om the CTG higher limits for 10 coatings would be greater than the emissions from Rule 4603 higher limit for only one coating category.

• Rule 4603 has work practice standards only for large appliances and metal furniture coating operations similar to the CTG but none for miscellaneous metal parts and products. The CTG only reco mmends work practice standards for cleaning materials but no specific VOC lim it because EPA stated that they have no information available regarding current VOC content to determine RACT for cleaning materials. Although Rule 4603 does not have work practice standards for miscellaneous metal parts and products c oatings, District staff believes that Rule 4603, overall, is equivalent in st ringency because the rule prohibits the use organic solvent cleaning materials that contain more than 25 grams VOC per liter, as well as compliance with certain work practice standards for which the CTG have specific no requirements.

5. EPA 453/R-07-004 and EPA 453/R-07-005

District Rule 4603 coatings VOC limits for la rge appliances and metal furniture coatings VOC limits, which range from 275 grams/liter to 420 gram s/liter depending on the type of coating and whether baked or air-dried, are exactly the same as the limits specified by the CTGs . Unlike the CTGs for large appliances or metal furniture coating operations, District Rule 4603 does not exem pt stencil coatings, safety-indicating coatings, solid-film lubricants, electric-i nsulating and thermal-conducting coatings. The work practice standards for large appliances or metal furniture coating operations are

identical to the CTGs. Unlike the CTG wh ich does not have any VOC limits for solvent cleaning operations, Rule 4603 prohibits the use of organic solvents for cleaning operations that exceed 25 gram s per liter of material. As an alternative to complying with the solvent cleaning VOC limit, Rule 4603 allows the use of add-on emission control system that an overall capture and control efficiency of 90 percent, by weight.

Based on the discussion above, District staff deems District Rule 4603 overall is as stringent as the CTGs and satisfies RACT.

B. EPA – Alternative Control Techniques (ACT) Document

ACT for Industrial Cleaning Solv ents (EPA-453-94-015), February 1994

This ACT contained detailed discussion on solv ent cleaning activities (i.e., dipping, flushing, purging, spraying, and wiping) and fact ors that affect emissi ons. However, the ACT does not specify any solvent VOC limit or emission st andards. Therefore, it doesSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-178 not serve any meaningful purpose for RACT determination of organic solvent cleaning

activities.

In comparison, District Rule 4603 require s the use of cleaning solvents with a VOC content of no more than 25 gram s/liter. As an alternative to using compliant cleaning solvents, an operator may operate an APCO-approved VOC emission control system that has an overall capture and control effici ency of 90%. In addition , District Rule 4603 also specifies allowable cleaning methods such as wipe cleaning, non-atomized solvent flow, and solvent flushing. The rule prohibits atomization of solvent into open air unless it is vented to an APCO-approved VOC emissi on control system, and also prohibits use of VOC containing materials to clean spra y equipment unless an enclosed system is used. A spray equipment cleaning method other than an enclosed system may be used provided it is proven to be equally as an enclos ed effective in controlling emissions. Based on the discussion above, District staff deems District Rule 4603 satisfies RACT.

C. Standards of Performance fo r New Stationary Sources (NSPS)

1. 40 CFR 60 Subpart EE (Surface Coating of Metal Furniture)

This NSPS applies to metal furniture c oating operation facility that commences construction, modification, or reconstruction after November 28, 1980. Facilities using less than 3,842 liters of coating, as applied, per year are ex empt. The NSPS prohibits the discharge into the atmospher e of VOC emissions from c oating operations in excess of 0.90 kg/liter (900 grams/lit er) of coating solids applied. In lieu of using compliant coatings, a VOC capture and control system may be used provided the performance monitoring requirements specified in the NSPS are met. The NSPS specifies coating application methods and corresponding transfer ef ficiencies (air atomized spray - 0.25; airless spray – 0.25; manual electrostati c spray – 0.60; nonrot ational automatic electrostatic spray – 0.70; rotating head el ectrostatic spray manual and automatic – 0.80%; dip and flow coating – 0.90; electr odeposition – 0.95). The NSPS details the methodology and mathematical equations for calculating the VOC emissions using the

information VOC content of the coatings and the app lication method (with the corresponding transfer efficiency) to determi ne compliance with the 0.90 kg/liter limit.

2. 40 CFR 60 Subpart SS (Industrial Surf ace Coating of Large Appliances)

This NSPS applies to large appliance surf ace coating facility that commences construction, modification, or reconstruc tion after December 24, 1980. The NSPS prohibits the discharge into the atmosphere of VOC emissions from coating operations in excess of 0.90 kg/liter of c oating solids applied. In lieu of using compliant coatings, a VOC capture and control system may be used provided the performance monitoring requirements specified in the NSPS are met. The NSPS specifies coating application methods and corresponding transfer efficienci es (air atomized spray – 0.40; airless spray – 0.45; manual electrostatic spray – 0.60; nonrotational automatic electrostatic spray – 0.85; rotating head automatic electros tatic spray – 0.90; dip and flow coating – 0.85; electrodeposition – 0.95). The NSPS details the methodology and mathematicalSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-179 equations for calculating the VOC emissions using the info rmation VOC content of the coatings and the applicati on method (with the corresponding transfer efficiency) to determine compliance with the 0.90 kg/liter limit.

District Rule 4603 coatings VOC limits for la rge appliances and metal furniture coatings VOC limits, which range from 275 grams/liter (2.3 lb/gall on) to 420 grams/liter (3.5 lb/gallon) of coating, appl ied, depending on the type of coating and whether baked or air-dried, are more stringent than the NSPS VOC emission limit of 0.90 kg/liter of coating solids applied (equivalent to 3.7 lb /gallon of coating, assuming an average solvent solids density of 10 lb/gallon and an average solids solv ent density of 7.34 lb/gallon).

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

NESHAPs and MACTs are requirements contai ned in 40 Code of Federal Regulations (CFR) Part 61 and 40 CFR Part 63. Since EPA has delegated the authority to implement NESHAP requirements to the Dis trict, NESHAPs and MACTs promulgated by EPA are usually incorporated by reference into District Rule 4002 (National Emission

Standards for Hazardous Air Pollu tants). It is impor tant to mention that the District implements NESHAPs and MACTs by inco rporating the emission standards as

conditions of the Permits to Operate that are issued to affected sources. The three NESHAPs that apply to miscellaneous meta l parts and products, large appliances, and metal furniture coating operations are briefly discussed below.

1. 40 CFR Part 63 Subpart MMMM (NESHAP for Surface Coating of Miscellaneous Metal Parts and Products)

This NESHAP applies to new, reconstructed, or existing affected so urce that uses 946 liters (250 gallons) per year or more of c oatings that contain hazardous air pollutants (HAPs) in surface coating of miscellaneous metal parts and products defined in the NESHAP, and that is a major source, located at a major source, or a part of a major source. A major source of HAP emissions is a stationary source that emits or has the potential to emit any single HAP at a rate of 9.07 megagrams (10 tons) or more per year, or any combination of HAP at a rate of 22.68 megagrams (25 tons) or more per year. The NESHAP include provisions for co mplying with the applicable emission limits, work practice standards, recordkeeping and reporting requirements. The NESHAP also contains exemptions for certain types of surface coating operations. Work practice standards are also specified by the NESHAP. The standards include storing all organic containing materials in closed containers, minimizing spills of all HAP materials, conveying HAP materials from one location to another in closed containers or pipes, closing mixing vessels except when adding , removing, or mixing the contents; and minimizing emissions during cleaning of storage, mixing, and conveying equipment.

It is important to mention that the NESHAP HAP emission limits which are expressed in terms of mass (kg) of HAP per volume ( liter) of coating solids are not directlySan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-180 comparable to the coatings VO C limits which are expressed in terms of grams (or lb) of VOC per liter (or gallons) of coatings, less water and exempt compounds, as applied. In addition, some HAPs may be exempt VOCs, and some VOCs may be HAPs; therefore,

there is no direct correlati on between the NESHAP limit ve rsus District Rule 4606 VOC

limits.

2. 40 CFR Part 63 Subpart NNNN (NESH AP for Surface Coating of Large Appliances)

This NESHAP applies to each new, reconstr ucted, and existing large appliance parts and products coating facility that is a majo r source of hazardous air pollutants (HAPs)

that emits or has t he potential to emit a single HA P of 9.07 megagrams (10 tons) per year, or any combination of HAPs of 22.68 megagrams (25 tons) per year. It applies to

a new affected source that commences construction after July 23, 2002 and the construction is of a completely new lar ge appliance surface coating facility where previously no large appliance surface coat ing facility had existed. The NESHAP include provisions for complying with the applicable emission limits, work practice standards, and recordkeeping and reporting requi rements. The NESHAP also contains exemptions for certain types of surface coating operations. Work practice standards are also specified by the NESHAP. The standar ds include storing all organic containing materials in closed containers, minimizing spills of all HAP materials, conveying HAP

materials from one location to another in cl osed containers or pipes, closing mixing vessels except when adding, removing, or mixing the content s; and minimizing emissions during cleaning of storage, mixing, and conveying equipment.

It is important to mention that the NESHAP HAP emission limits which are expressed in terms of mass (kg) of HAP per volume ( liter) of coating solids are not directly comparable to the coatings VO C limits which are expressed in terms of grams (or lb) of VOC per liter (or gallons) of coatings, less water and exempt compounds, as applied. In addition, some HAPs may be exempt VOCs, and some VOCs may be HAPs; therefore,

there is no direct correlati on between the NESHAP limit ve rsus District Rule 4606 VOC

limits.

3. 40 CFR Part 63 Subpart RRRR (NESHAP for Surface Coating of Metal Furniture)

This NESHAP applies to each new, reconstruc ted, and existing metal furniture coating facility that is a major source, is located at a major source, or is a part of a major source of emissions of HAPs. A major source of HAP emissions is any stationary source or group of stationary source located withi n a contiguous area and under common control

that emits or has t he potential to emit a single HAP of 9.07 megagrams (10 tons) per year, or any combination of HAPs of 22.68 megagrams (25 tons) per year. An affected

source is a new affected source if it co mmenced its construction after April 24, 2002, and the construction is of a completely ne w metal furniture coating operation facility where previously no metal furniture surface coating facility existed.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-181 The NESHAP include provisions for complyin g with the applicable emission limits, work practice standards, and recordkeeping and r eporting requirements. The NESHAP also contains exemptions for certain types of surface coating operations. Work practice standards are also specified by the NESHAP. The standards include storing all organic containing materials in closed containers, minimizing spills of all HAP materials, conveying HAP materials from one location to another in closed containers or pipes, closing mixing vessels except when adding , removing, or mixing the contents; and minimizing emissions duri ng cleaning of storage, mixi ng, and conveying equipment.

It is important to mention that the NESHAP HAP emission limits which are expressed in terms of mass (kg) of HAP per volume ( liter) of coating solids are not directly comparable to the coatings VO C limits which are expressed in terms of grams (or lb) of VOC per liter (or gallons) of coatings, less water and exempt compounds, as applied. In addition, some HAPs may be exempt VOCs, and some VOCs may be HAPs; therefore,

there is no direct correlati on between the NESHAP limit ve rsus District Rule 4606 VOC

limits.

How does District Rule 4603 compare to rules in other air districts?

District staff compared VOC lim its, optional control require ments, and work practice standards in District Rule 4601 to comparable requirements in rules from the following

California nonattainment areas:

• South Coast AQMD Rule 1136

• South Coast AQMD Rule 1107 (Coating of Metal Parts and Products) amended January 6, 2006

• BAAQMD Regulation 8 Rule 19 (Surface Preparation and Coating of Miscellaneous Metal Parts and Products) amended October 16, 2002

• BAAQMD Regulation 8, Rule 14 (Surfa ce Preparation and Coating of Large Appliances and Metal Furnit ure) amended October 16, 2002

• Sacramento Metropolitan Air Quality M anagement District (SMQMD) Rule 451 (Surface Coating of Miscellaneous Me tal Parts and Products) amended October 10, 1997

• Ventura County Air Polluti on Control District (VCPCD) Rule 74.12 (Surface Coating of Metal Parts and Products) amended April 8, 2008

A. SCAQMD Rule 1136

SCAQMD Rule 1136 applies to all metal c oating coatings operations except those performed on aerospace assembly , magnet wire, marine craft, vehicle, metal container, and coil coating operations. It also does not apply to the coating of architectural components at the structure si te or at a temporary uni mproved location designated exclusively for coating of structural com ponents. SCAQMD Rule 1136 specifies the VOC limits for 22 categories of coatings . The VOC limits range from 275 to 420 grams/liter for coatings dependi ng on the coating type and whether air-dried or baked.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-182 The VOC limit for stripping any coating is 200 grams/liter or less. As an alternate compliance option to using compliant coat ings, the rule allows operators to use approved air pollution control equipment wit h a collection efficiency of 90% and a control efficiency of 95% (or the output of the control device is no more than 5 ppmv VOC calculated as carbon without dilution) . The rule includes coating application equipment requirements and a VO C limit for solvent cleaning and surface preparation pursuant to SCAQMD Rule 1171 (S olvent Cleaning Operations).

B. SCAQMD Rule 1107 (Coating of Metal Parts and Products)

SCAQMD Rule 1107 exempts the followi ng coatings or coating operations:

• Stencil, safety indicating, magnetic data storage disk, solid film lubricants, and electric-insulating and t hermal-conducting coatings

• Coatings and cleaning solvents used in performance tests on coatings at paint manufacturing facilities.

• High performance architectural, vacuum-meta lizing, or pretreatment coatings used at a facility which has a potent ial to emit a total of 10 to ns or less per year, before

consideration of controls.

• Aerosol coating products.

• Use of aggregate 55 gallons or less of essent ial public service coatings per year per facility.

• Use of aggregate 10 gallons or less of optical anti-reflective coatings per year per facility.

• Use of 66 gallons of electrocoatings per month per facility provided the VOC content does not exceed 450 grams/liter, less water and less exempt compounds as applied.

• Photoresist operations applying liquid phot oresist coating used for photofabrication

of metal substrates with a thickness not exceeding 0.060 inch provided the usgae does not exceed 10 gallons per year per facility.

District Rule 4603 coatings VOC limits are su bdivided into two major categories (i.e., general coatings and specialty coatings). For general coati ngs, the VOC limits are 340 grams/liter for air-dried and 275 for baked. T he specialty coatings are subdivided into eight types of coatings. In addition, Dis trict Rule 4603 has s eparate VOC limits for coatings used in metal furniture and large ap pliance coating operations versus coatings used for other metal parts and products coati ng operations. In contrast, SCAQMD Rule 1107 does not have a general coating VOC limits, but the rule specifies VOC limits for 22 coating types. All the specialty coatings VOC limits of District Rule 4603 for metal parts and products are as stringent as SCAQ MD Rule 1107, except for extreme high gloss, extreme performance, metallic, and ca mouflage coatings. SCAQMD Rule 1107 VOC limits for extreme high gloss air-dried of 340 grams/liter is stringent than 420 grams/liter limit of District Rule 4603. However, SCAQMD Rule 1107 VOC limit for metallic coating and camouflage coating of 420 grams/liter baked is less stringent than District Rule 4603 limit of 360 grams/liter ai r dried. SCAQMD Rule 1107 coatings VOC limit for etching filler, vacuum-metalizing, mold seal, electric-insulating varnish, and pan backing coatings is 420 gram s/liter is less stringent than District Rule 4603 coatingsSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-183 limits of 275 grams/liter bak ed and 340 grams/liter air-dri ed (comparison is made using the general coatings limits since Distr ict Rule 4603 has no corresponding coating types). For large appliances and metal furn iture coating operations, District Rule 4603

VOC limits are the as stringent as SCAQMD Rule 1 175. SCAQMD Rule 1107 has a VOC limit of 420 grams/liter air-dried and 360 grams/liter baked for touch-up coatings and repair coatings. District Rule 4603, how ever, does not have a VOC limit because touch and repair are exempt from t he rule requirements.

The solvents cleaning VOC limit of 25 grams/liter in District Rule 4603 is the same as the SCAQMD solvent cleaning limit for this source category wh ich regulated under SCAQMD Rule 1171 (Solvent Cleaning Operations).

Although SCAQMD Rule 1107 has slight mo re stringent VOC limits for extreme high gloss and extreme performance coatings t han District Rule 4603, there are some coating types where SCAQMD Rule 1107 has less stringent limits as discussed above. It important to mention SCAQMD Rule 1107 has more exemptions than District Rule

4603. Based on the above discussion District st aff deems that overall District Rule 4603 is as stringent as SCAQMD Rule 1107.

C. BAAQMD Regulation 8 Rule 19 (Sur face Preparation and Coating of Miscellaneous Metal Parts and Products)

BAAQMD Regulation 8 Rule 19 applies to surface preparation and coating of miscellaneous parts and products. The VO C limits for general coatings are 340 grams/liter for air-dried and 275 for baked. Fo r specialty coatings, the VOC limits range from 360 grams/liter to 420 grams/liter depending on the c oating type and whether baked or air-dried. In lieu of using compli ant coatings, BAAQMD Regulation 8 Rule 19 allows the use of an air pollution abatement equipment with an efficiency of at least 85% provided the emissions are reduced to a level that is at least equivalent to the emissions generated by using compliant coatings.

BAAQMD Regulation 8 Rule 19 specifies th e requirements for spray application equipment such as HVLP, electrostatic spray, detailing gun, or other spray application equipment that achieves equiva lent transfer efficiency. The solvent evaporative loss minimization provisions require closed cont ainers for storage or disposal of materials used for solvent surface preparation and cleanup; prohibits use of organic solvents that have a VOC content in excess of 50 grams/liter for cleanup of spray equipment and paint lines unless a spray gun washer that co mplies with Regulation 8, Rule 16 as well is used, or the solvent is pressurized th rough spray equipment with atomizing air off or disposed from a small non-atomizing cont ainer, and collected and stored in a closed container until recycled or properly disposed. The surface preparation solvent limit is 50 grams/liter or the use of an approved emission control syst em with an overall abatement efficiency of at least 85%.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-184 BAAQMD Regulation 8 Rule 19 exempts the following:

• Usage of any coating that does not meet the applicable coating VOC limits if such usage is less than 75.7 liters (20 gallons) in any one cal endar year and provided the total amount of all noncompliant coatings used does not exceed 100 gallons in any calendar year.

• Application of adhesives; touch-up oper ations; metal containers and closures (drums, cans, lid, etc.) and metal coil; magne t wire for use in electrical machinery; metal furniture and large appliances (subject to Regulation 8, Rule 14); aircraft or aerospace vehicles; motor vehicles and mobile equipment; marine vessels and component parts; stationary structur es and appurtenances which require architectural coatings exce pt where bake coatings are required; stencil coatings, powder coatings provided the VOC emissions do not exceed t hat which is equivalent to the use of compliant coatings, solid film lubricants, chemical milling maskant, and coatings applied to printed board circuits, and other exemptions.

• Specialty coatings (high performance; pr etreatment wash prim er; silicon release, extreme performance, and high temperature) provided t hey meet the VOC limits which range from 550 to 780 grams/liter depending on the type of coating and provided the usage of such coatings does not exceed 3,785 liters (100 gallons) in any calendar year.

• Source operations using less than 20 gallons of coating in any calendar year is exempt from record keeping requirements.

• Certain spray application equipment are exempt but with specific conditions of use.

The coatings VOC limits of District Rule 4603 for metal parts and products are as stringent as the limits of BAAQ MD Regulation 8, Rule 19. District Rule 4603 has VOC limit of 880 grams/liter for solid film lubricant, but BAAQMD Regulation 8, Rule 19 exempts such coating. In lieu of using comp liant coatings District Rule 4603 allows the use of a VOC emission control system with an overall capture and control efficiency of 90%, which is more stringent than BAAQMD R egulation 8, Rule 19 requirement of 85% abatement efficiency.

BAAQMD Regulation 8, Rule 19 requirement s on spray application equipment and work practice standards (solvent evaporative loss mi nimization) are as stringent as District Rule 4603. However, the surface prepar ation and solvent clean-up VOC limit of 25 grams/liter of District Rule 4603 is more stringent than the BAAQMD Regulation 8, Rule 19 limit of 50 grams/liter. With regard to exempt operations, District Rule 4603 has lesser exempt operations than BAAQMD regulat ion 8, Rule 19. Based on the above discussions, District staff deem s that overall District Rule 4603 is more stringent than BAAQMD Regulation 8, Rule 19.

D. BAAQMD Regulation 8, Rule 14 (Sur face Preparation and Coating of Large Appliances and Metal Furniture)

BAAQMD Regulation 8, Rule 14 applies to su rface preparation and coating of large appliances and metal furniture. The VOC limits for general coatings (high gloss, heat resistant, metallic topcoat, pretreatment wa sh primer, and solar adsorbant) are 340San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-185 grams/liter for air-dried and 275 for baked. Fo r specialty coatings, the VOC limits range from 360 grams/liter to 420 grams/liter depending on the c oating type and whether baked or air-dried. In lieu of using comp liant coatings, BAAQMD Regulation 8 Rule 19 allows the use of an air pollution abatement equipment with an efficiency of at least 85% provided the emissions are reduced to a level that is at least equivalent to the emissions generated by using compliant coatings.

BAAQMD Regulation 8 Rule14 specifies the requirements for spray application equipment such as HVLP, electrostatic sp ray, flow coat, roller coat, dip coat, electrodeposition, and brush coat. The solv ent evaporative loss minimization provisions require closed containers for storage or disp osal of materials used for solvent surface preparation and cleanup; prohibits use of organi c solvents that have a VOC content in excess of 50 grams/liter for cleanup of sp ray equipment and paint lines unless a spray gun washer that complies with Re gulation 8, Rule 16 as well is used, or the solvent is pressurized through spray equipment with atom izing air off or di sposed from a small non-atomizing container, and collected and stor ed in a closed container until recycled or properly disposed. The surfac e preparation solvent limit is 50 grams/liter or the use of an approved emission control system with an ov erall abatement efficiency of at least

85%.

BAAQMD Regulation 8 Rule 19 exempts the following:

• Use of any coating that does not meet the applicable coating VOC limits if such usage is less than 75.7 liters (20 gallons) in any one cal endar year and provided the total amount of all noncompliant coati ngs used does not exceed 208.1 liters (55 gallons) in any calendar year.

• Touch coating operation; adhesives applic ation; aerosol cans, powder coatings provided the VOC emissions do not exceed t hat which is equivalent to the use of compliant coatings.

• Surface preparation of electrical and el ectronic components; stripping of cured coatings, inks, and adhesives; research and development surf ace preparation; performance testing of adhesives, inks, and coatings; quality control and quality assurance testing.

The coatings VOC limits of District Rule 4603 for metal parts and products are as stringent as the limits of BAAQ MD Regulation 8, Rule 14, except the baked metallic topcoat VOC limit of 420 grams/ liter is slight more stringent than District Rule 4603 limit of 420 grams/liter. Howeve r, BAAQMD Regulation 8, Ru le 14 general coating VOC limit for air dried coatings of 340 grams/liter is less stri ngent than District Rule 4603 VOC limit 275 grams/liter for ai r dried one component coating. In lieu of using compliant coatings District Rule 4603 allows the us e of a VOC emission control system with an overall capture and control efficiency of 90%, which is more stringent than BAAQMD Regulation 8, Rule 14 requirement of 85% abatement efficiency.

BAAQMD Regulation 8, Rule 14 requirement s on spray application equipment and work practice standards (solvent evaporative loss minimization) are as stringent as District Rule 4603. However, the surface prepar ation and solvent clean-up VOC limit of 25San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-186 grams/liter of District Rule 4603 is more stringent than the BAAQMD Regulation 8, Rule 19 limit of 50 grams/liter. With regard to exempt operations, District Rule 4603 has lesser exempt operations than BAAQMD Regulat ion 8, Rule 14. Based on the above discussions, District staff deem s that overall District Rule 4603 is more stringent than BAAQMD Regulation 8, Rule 14.

E. Sacramento Metropolitan Air Qualit y Management District (SMQMD) Rule 451 (Surface Coating of Miscellaneous Metal Parts and Products)

SMAQMD Rule 451 applies to the coat ing of miscellaneous parts and products including removal (stripping), surface prepar ation and cleanup operations. The coatings VOC limits range from 340 to 420 grams/liter for air dried c oatings and from 275 to 420 grams/liter for baked coatings, depending on the type of coatings . As an alternative to using compliant coatings, an APCO-approved air pollution c ontrol equipment which has an overall system efficiency of 85% may be us ed to comply with the rule. The VOC limit for strippers is 200 grams/liter. The rule includes requirem ents for coating application equipment (roll coater, dip coat, electrosta tic spray, flow c oat, HVPL, LVLP, hand application such as brush or roller, or any other method approved by the APCO and EPA. Surface preparation, cleanup, and storage requirements include using closed containers for disposal of cloth, paper, or sponges used for surfac e preparation cleanup and coating removal; closed containers for st oring VOC-containing materials except when in use; use enclosed gun cleaner or us e cleanup solvent with a VOC content that does not exceed 72 grams/liter; spray guns only may be soaked in solvent-based materials in a container not exceeding 5 gallons is tightly covered at all times except when accessing the container.

SMAQMD Rule 451 ex empts the following:

• Use of any coating that does not meet the applicable coating VOC limits if such usage is less than 55 gallons per calendar year, per stationary source, except for complying with recordkeeping requirements.

• Use of any aluminum coating for window and door frames exceeding the specified VOC limit if the usage is less than 200 ga llons per calendar year, per stationary source, except for complying with the recordkeeping requirements.

• Use of pretreatment wash pr imer that exceeds the specif ied VOC limit if the usage is less than 200 gallons per calendar year, per stationary source, ex cept for complying with the recordkeeping requirements.

• Coating of prefabricated architectural com ponents or structures not coated in a shop which are regulated by Rule 442 (Architectural Coatings).

• Coating of motor vehicles, excluding radiat ors, drive trains, differentials, and engine components which by Rule 459 (Autom otive, Truck and heavy Equipment Refinishing Operations).

• Coating of aircraft or aerospace vehicles ; cans, coils or magnetic wire; adhesives; magnetic data storage disc; safety indicati ng coatings; stencil coatings; conformal coatings (e.g., coating of electronic circuit boards or assembled components); and hand lettering.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-187 The coatings VOC limits of SMAQMD Rule 451 are as stringent as District Rule 4603, except SMAQMD Rule 451 aluminum coating limit of 420 grams per liter for baked and air-dried coating, 420 grams/ liter for baked metallic/irridescent, and baked non-skid 360 grams/liter are less stringent than District Rule 4603 gen eral coatings limits of 275 grams/liter for baked and 340 gr ams/liter for air dried c oatings and baked metallic coating limit of 360 grams/liter . In lieu of using compliant coatings, SCAQMD Rule 451 allows the use of an APCO-approved air pol lution control equipment with an overall system efficiency of 85% compared to Distric t Rule 4603 more stringent overall capture and control efficiency of 90%. SCAQMD Rule 551 solvent cleaning and surface preparation VOC limit of 72 gr ams/liter is less stringent than District Rule 4603 VOC limit of 25 gr ams/liter.

Unlike the exemptions in SMAQMD Rule 451, District Rule 4603 does not exempt aluminum coating for window and door frames exceeding the specified VOC limit if the usage is less than 200 gallons per calendar year; coatings used on magnetic data storage disc; safety indicating coatings; st encil coatings; conformal coatings (e.g., coating of electronic circuit boards or assembled components); and hand lettering. Based on the above discussion, District staff deem s that District Rule 4603 overall is more stringent than SCAQMD Rule 451.

F. Ventura County APCD Rule 74.12 (S urface Coating of Metal Parts and Products)

VCPCD Rule 74.12 applies to surface c oating of metal parts and products. The coatings VOC limits range fr om 275 to 420 grams/ liter depending on the type of coating and whether the coating is air-dried or baked. As an alternative to using compliant coatings, an APCO-approved air pollution control equipment which has an overall system efficiency of 90% may be used to comply with the rule. VCPCD Rule 74.12 contains coating applicati on equipment and solvent clea nup and surface preparation requirements, but the rule does not include an y work practice standards. The VOC limit for substrate surface cleaning and sp ray equipment cleaning or cleanup is 25 grams/liter.

VCPCD Rule 74.12 exem pts the following:

• If no complying coatings are available, total usage of non-complying coatings has not exceeded 55 gallons in any calendar year.

• Aircraft or aerospace vehicle coating oper ations; marine vessel exteriors; motor vehicle and mobile equipment; and aerosol coating products.

• Stationary source that em its less than 200 lb ROC (VOC) in every rolling period of 12 consecutive months from metal parts and products coating operations (emissions from aerosol products, cold cleaners and vapor degreasers should not be included in this determination).

• Surface preparation and cleanup require ments do not apply to metal parts and products coating operations if the total usage of non-complying substrate surface cleaners does not exceed 5 gallons per rolling 12-month period.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-188 VCPACD Rule 74.12 coatings VOC limits of 275 grams per liter for air-dried for “all coatings” category, 360 grams/liter for baked extreme performance coating, and 420 grams/liter for air-dried and 275 grams/liter for baked pretre atment wash primer are slightly more stringent than District Rule 4603 limits of 340 gram s/liter for air-dried general coatings, 420 grams/liter for baked extreme performance, and 420 grams/liter for both air-dried and baked pret reatment coating. However, District Rule 4603 coatings VOC limits of 340 grams/liter air-dried and 275 grams/liter baked for general coatings are more stringent than VCPACD Rule 74.12 limits of 420 grams/lit er for air-dried or baked mold seal coating, 420 grams/liter fo r air-dried or baked pan backing coating, and 420 grams/liter for air-dried and baked vacuum metalizing coating. It is important to

mention that since District Rule 4603 does include mold seal, pan backing, and vacuum metalizing coating categories, such coatings are subject to the “g eneral coatings” VOC

limits of District Rule 4603. District Rule 460 3 includes work practice standards while VCPACD Rule 74.12 has none specified. In addition, District Rule 4603 has VOC limits for metal parts and products coating operati ons and separate limits for large appliances and metal furniture coating operations. Unli ke District Rule 4603, VCAPCD Rule 74.12 exempts sources that emit less than 200 lb ROC (VOC ) in every rolling period of 12 consecutive months from metal parts and pr oducts coating operations (emissions from aerosol products, cold cleaners and vapor degreasers should not be included in this determination). Based on the above discussion, District staff deems that overall District Rule 4603 is as stringent as VCAPCD Rule 74.12.

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, Distric t staff concludes that District Rule 4603 satisfies RACT for metal parts and produc ts, large appliance parts and products, and metal furniture coating operations. However, in order to incorporate the recent CTG requirements, as outlined in Table 4-3, the rule is on a schedule for amendment.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-189 

### Rule 4604 - Can and Coil Coating Operations

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 0 0 0 0 0 0 0 0

VOC 1.0 1.0 1.1 1. 1 1.2 1.3 1.3 1.4
(Source: District Ozone Plan)

District Rule 4604 Description

District Rule 4604, recently amended on Septem ber 20, 2007, controls VOC emissions

from can and coil coating operations, and from organic solvent cleaning, storage and disposal associated with can coating and coil coating operations.

The rule limits the VOC content of different coatings and allows an emission control device for those companies who use non-comp liant coatings. Alternative emission control plans are also allowed under certain conditions. The emission control system or alternative emission control pl an must reduce emissions to no more than the amount of

VOCs that would have been emit ted had rule-compliant coatings been used. The rule contains provisions for organic solvent cleaning, storage and disposal requirements, monitoring provisions, and recordkeeping.

There are a limited number of sources subject to Rule 4604 (less than ten). There are neither two-piece can manufacturers nor coil coating operations in the SJVAB. Except for the closed manufacturing site, the compan ies subject to this rule have year-round operations, although some of the equipment under permit is operated only during peak periods.

How does District Rule 4604 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

EPA-450/2-77-008 1977/05

The CTG applies t o surface coating of cans, coils, pape r, fabrics, automobiles, and light-duty trucks operations located in marg inal, moderate, serious or severe ozone nonattainment areas that has the potential to emit greater than or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of VOC for extreme ozone

nonattainment areas.

The table below identifies the CTG requirem ents and how Rule 4604 compares to those requirements.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-190 Coating Type CTG (lb/gal) Rule 4604 (lb/gal)

Can Sheet basecoat 2.8 2.1 Can Interior Body 4.2 3.5

Can Side Seam 5.5 5.5

Can End Seal 3.7 0.2 Coil Prime and Topcoat 2.6 1.7

As shown in the table above, District Rule 4604 is as stringent or more stringent than all

CTG limits.

B. EPA - Alternative Control Technology (ACT)

There is no EPA ACT guidance document for can and coil coating operations.

C. Standards of Performance fo r New Stationary Sources (NSPS )

1. 40 CFR 60 Subpart TT (Standards of Performance for Metal Coil Surface Coating)

The table below identifies the NSPS require ments and how Rule 4604 compares to those requirements.

Coating Type NSPS (kg/l) 4604 (kg/l)

Coil Surface – No

Control Device 0.28 (monthly average) 0.20

Coil Surface –

W/Control Device 0.14 (monthly average) or

90% VOC reduction 90% VOC reduction

As shown in the table above, District Rule 4604 is as stringent or more stringent than all

NSPS limits.

2. 40 CFR 60 Subpart WW (Standards of Pe rformance for Beverage Can Surface Coating Industry)

The table below identifies the NSPS requi rements and how Rule 4604 compares to those requirements.

Coating Type NSPS (kg/l) 4604 (kg/l)

2-Piece can exterior base

coat 0.29 0.25

2-Piece can clear base

coat 0.46 0.25

2-Piece can overvarnish 0.46 0.25

2-Piece can inside spray 0.89 0.36San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-191 As shown in the table above, District Rule 4604 is as stringent or more stringent than all

NSPS limits.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

NESHAPs and MACTs are requirements contai ned in 40 Code of Federal Regulations (CFR) Part 61 and 40 CFR Part 63. Since EPA has delegated the authority to implement NESHAP requirements to the Dis trict, NESHAPs and MACTs promulgated by EPA are usually incorporated by reference into District Rule 4002 (National Emission

Standards for Hazardous Air Pollu tants). It is impor tant to mention that the District implements NESHAPs and MACTs by inco rporating the emission standards as

conditions of the Permits to Operate issued to affe cted sources.

1. 40 CFR 63 Subpart KKKK (National Em ission Standards for HAPs: Surface Coating of Metal Cans)

Per Section 63.3481, this Subpart does not apply since 40 CFR 63 Subpart SSSS (National Emission Standards for HAPs: Surfac e Coating of Metal Co il) applies to this emission source category.

2. 40 CFR 63 Subpart SSSS (National Em ission Standards for HAPs: Surface Coating of Metal Coil)

The requirements in this subpart are not dire ctly comparable to the District Rule 4604 limit of 200 g/L of coil coating. The NESH AP HAP emission limits which are expressed in terms of % HAP, HAP emission concent ration, and mass (kg) of HAP per mass (kg) of solids are not directly comparable to the coatings VOC limit which is expressed in terms of grams (or lb) of VOC per liter (o r gallons) of coatings, less water and exempt compounds, as applied. In addition, some HAPs may be exempt VOCs, and some VOCs may be HAPs; therefore, there is no direct correlat ion between the NESHAP limit

versus District Rule 4604 VOC limits.

How does District Rule 4604 compare to rules in other air districts?

District staff compared VOC lim its, optional control require ments, and work practice standards in District Rule 4604 to comparable requirements in rule s from the following

California nonattainment areas:

• South Coast AQMD Rule 1125 - Metal Container, Closure, and Coil Coating Operations, amended March 7, 2008

• BAAQMD Regulation 8 Rule 11 - Metal C ontainer, Closure and Coil Coating, as amended November 19, 1997San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-192 • Sacramento Metropolitan Air Quality Manage ment District (SMQMD) Rule 452 (Can Coating), as amended September 25, 2008

• Ventura County Air Polluti on Control District (VCPCD) - No rule for can or coil coating facilities.

A. South Coast Air Quality Management Dist rict (SCAQMD) Rule 1125 - Metal Container, Closure, and Coil Coating Operations

SCAQMD Rule 1125 applies to can and coil coating operations. The table below

identifies where the rules diffe r in VOC requirements. Ca tegories not discussed, such as solvents, means the two rules have the same requirement.

Category South Coast (g/l) SJ Valley (g/l) More Stringent for Category

Exemption Throughput 1 gal/day 55 gal/year SJ Valley

Necker Lubricants 100 Exempt South Coast

Stripping of Cured Materials 25 Exempt South Coast

Cleaning Solvents Lab/Research 25 Exempt South Coast

2-Piece can interior spray 440 420 SJ Valley
End Seal Compound (Food/Beverage) 440 20 SJ Valley

End Seal Compound (NonFood/Beverage) 0 20 South Coast

Inks 250 - 800 See Rule 4607 RACT Analysis See Rule 4607 RACT Analysis

Due the central locality of the agriculture industry, the SJ Valley’s can/coil coating facilities overwhelmingly manufacture food/beverage products compared to nonfood/beverage products. As such, the SJ Valley’ s stringent rule limit of 20 g/l (versus the South Coast limit of 440 g/ l) has a greater affect on VO C emissions compared to the insignificant categories where the South Coast is more stringent, such as the small/exempt operations and end seal compound for non-food/beverage. Overall

SJVAPCD Rule 4604 is at least as stringent as SCAQMD Rule 1125.

B. Bay Area Air Quality Ma nagement District (BAAQMD ) Regulation 8 Rule 11 – (Metal Container, Closure and Coil Coating )

BAAQMD Reg 8 Rule 11 applies to can and coil coating operations. The table below

identifies where the rules di ffer in VOC requirements. Categories not discussed means the two rules have the same requirement.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-193 Category Bay Area (g/l) SJ Valley (g/l) More Stringent for Category

Exemptions

Facilities Using < 55 gal/year Not Exempt Exempt Bay Area

Two Piece Can Coating

Exterior Sheet Base Coating 225 250 Bay Area

End Coating (Interior or Exterior) 250 420 Bay Area

Repair Coating No Limit 750 SJ Valley

Three Piece Can Coating

Overvarnish (Exterior or Interior) 250 225 SJ Valley

End Coating (Exterior or Interior) 250 225 SJ Valley

Repair Coating No Limit 750 SJ Valley

Drum Pails, Pails, and Lids

Sheet Base Coating No Limit 225 SJ Valley

Overvarnish (Exterior or Interior) No Limit 225 SJ Valley

Interior End Coating (New) No Limit 420 SJ Valley
Interior End Coating (Reconditioned) No Limit 510 SJ Valley

Exterior End Coating (New) No Limit 340 SJ Valley Exterior End Coating (Reconditioned) No Limit 420 SJ Valley

Side Seam Coating No Limit 660 SJ Valley

Inks 300 See Rule 4607 RACT Analysis See Rule 4607 RACT Analysis

Solvents

Surface Preparation No Limit 25 SJ Valley

Repair and maintenance No Limit 25 SJ Valley
Cleaning of Coating Application Equipment (except 3-piece can sheet coater) No Limit 25 SJ Valley

Cleaning of 3-piece can sheet

coater No Limit 550 SJ Valley

As shown in the table above, the SJVAPCD ru le contains an overwhelmingly amount of requirements that are more st ringent than the Bay Area Rule. Also, potential reductions from two-piece can coating are non-existent since there are no two-piece can coating operations in the SJVAPCD. Overall SJVAPCD Rule 4604 is at least as stringent as BAAQMD Regulation 8 Rule 11.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-194 C. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 452 (Can Coating)

SMAQMD Rule 452 applies to can coating oper ations. The table be low identifies where the rules differ in VOC requirements. Ca tegories not discussed means the two rules have the same requirement.

Category Sac Metro (g/l) SJ Valley (g/l) More Stringent for Category

Exemptions

Facilities Using < 55 gal/year Not Exempt Exempt Sac Metro

Two Piece Can Coating

Exterior Body Spray No Limit 420 SJ Valley

End Coating (Interior or Exterior) 250 420 Sac Metro

End Seal Compound (Non-Food) 0 20 Sac Metro

Repair Coating No Limit 750 SJ Valley

Three Piece Can Coating

Exterior Body Spray No Limit 420 SJ Valley

End Coating (Exterior or Interior) No Limit 250 SJ Valley

End Seal Compound (Non-Food) 0 20 Sac Metro

Repair Coating No Limit 750 SJ Valley

Coil

Prime and topcoat or singl e coat 225 200 SJ Valley

Solvents

Surface Preparation 25 (starting 9/25/09) 25 SJ Valley

Repair and maintenance 25 (starting 9/25/09) 25 SJ Valley

Cleaning of Coating Application Equipment (except 3-piece can sheet coater) 25 (starting 9/25/09) 25 SJ Valley

Cleaning of 3-piece can sheet

coater 25 (after 9/25/09) 550 (until 9/30/11)

250 (after

9/25/09 Sac Metro

Cleaning side seam spray applicators No Limits 25 SJ Valley

Not shown in the table above is a comparison for drum, pail, and lid coating categories.

The SJVAPCD rule contains limits for dr um, pail, and lid coating, whereas the
SMAQMD rule does not. The SJVAPCD will a ssume that since SMAQMD rule has noSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-195 limits for this category, there are no facilitie s of this nature in t he SMAQMD. As such,

the two District rules will be c onsidered equivalent for the drum, pail, and lid coating categories.

As shown in the table above, the SJVAPCD rule contains se veral requirements that are more stringent than the SMAQMD Rule. Also , potential reductions from two-piece can coating are non-existent sinc e there are no two-piece can coating operations in the

SJVAPCD. Overall SJVAPCD Rule 4604 is at least as stringent as SMAQMD Rule 452.

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, Distric t staff concludes that District Rule 4604 satisfies RACT for can and coil coating operations.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-196 

### Rule 4605 – Aerospace Assembly a nd Component Coating Operations

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

VOC 0.02 0.02 0.02 0. 02 0.02 0.02 0.02 0.02
(Source: District 2007 Ozone Plan)

District Rule 4605 Description

District Rule 4605, recently amended on Sept ember 20, 2007, sets VOC content limits for coatings, adhesives, and other related VOC-containing materials for coating operations related to aerospace assemblies and components.

The flushing of jet or rocke t engines using any solvent other than trichloroethylene is exempt. Aerospace assembly and component coating operations using less than four gallons per day of VOC-containing products are exempt as are other coatings or

adhesives. Materials used in laboratories associated with research and development, quality control, or production te sting are exempt from VOC cont ent limits. There is also a limited exemption from app lication equipment standards. VOC emissions are 50% controlled compared to uncontrolled emissions.

How does District Rule 4605 compare wi th federal rules and regulations?

A. EPA-Control Technique Guidelines (CTG)

1. The CTG EPA-453/R-97-004 1997/12 applies to Surface Coating Operations at Aerospace Manufacturing and Rework Operations located in marginal, moderate,

serious or severe ozone nonattainment ar eas that has the potential to emit greater than or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of VOC for extrem e ozone nonattainment areas.

The table below identifies the CTG r equirements and how Rule 4605 compares to those requirements.

Coating Type CTG (g/L) 4605 (g/L)

Ablative 600 - Adhesion Promoter 890 850 Adhesive Bonding Primers 850 805 Adhesive (Non-Structural) 360 250 Adhesive (Structural Autoclavable) 60 50 Adhesive (Structural Non-Autoclavable) 850 850

Antichafe 660 600 Bearing Coating 620 --San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-197 Coating Type CTG (g/L) 4605 (g/L)
Caulking and Smoothing Compounds 850 -- Chemical Agent Resistant Coating 550 -- Conformal Coating -- 750 Dry Lubricative Material 880 675 Electric/Radiation Effect Coating 800 800 Electromagnetic Interference Coating 800 -- Fire-Resistant Coatings 800 650 Flight Test Coatings (Missiles or Single Use Target Craft) 420 420 Flight Test Coatings (Other) 840 600 Fuel Tank Coatings 720 420 High Temperature Coating 850 850 Impact Resistant Coating -- 420 Intermediate Release Coating 750 -- Lacquer 830 -- Maskants 1,020 250 Metalized Epoxy Coating 740 -- Mold Release 780 -- Optical Anti-Reflective Coating 750 700 Part Marking Coating 850 -- Pretreatment Coatings 780 780 Primer (Commercial Exterior Aerodynamic Structure) 650 350 Primer (General) -- 350 Primer (Compatible Substrate) 780 350 Primer (Cryogenic Flexible) 645 350 Primer (Flexible) 640 350 Primer (Elevated Temperature Skydrol Resistant Commercial) 740 350

Rain Erosion Resistant Coating 850 800 Rocket Motor Nozzle Coating 660 -- Scale Inhibitor 880 880

Screen Print Ink 840 -- Sealant (Extrudable/ Rollable/Brushable) 280 600 Sealant (Fastener) 600 675 Sealant (Sprayable) 600 600

Silicone Insulation Material 850 -- Solid Film Lubricant (Fastener Mfr) 880 250 Solid Film Lubricant (Fastener Installation) 880 880 Solid Film Lubricant (Non-Fastener Mfr) 880 880 Space Vehicle Coatings (Electrostatic Discharge Protection) -- 800

Space Vehicle Coatings (Adhesives) -- 800 Space Vehicle Coatings (Other) -- 1,000 Specialized Function Coating 890 -- Temporary Protective Coating 320 250 Thermal Control Coating 800 -- Topcoat (General) -- 420 Topcoat (Barrier) -- 420 Topcoat (Clear) 720 520 Topcoat (Epoxy Polyamide) 660 -- Topcoat (Self Priming - Unicoat) -- 420 Wet Fastener Installation Coating 675 -- Wing Coating 850 750San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-198 Coating Type CTG (g/L) 4605 (g/L)
Wire Coating (Electronic) -- 420 Wire Coating (Anti-Wicking) -- 420 Wire Coating (Pre-Bonding Etching) -- 420 Wire Coating (Phosphate Ester Resistant Ink) -- 925

As shown in the table above, District Rule 4605 is more stringent than the CTG limits for 34 categories, while the CTG is more stringent than District Rule 4605 in 19 categories. As such, District staff concludes that District Rule 4605 is at least as stringent overall than the CTG.

2. The CTG EPA-450/2-77-034 1977/12 applies to Surface Coating of Large Appliances operations located in marginal, m oderate, serious or severe ozone nonattainment areas that have the potential to emit greater than or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of VOC for extreme

ozone nonattainment areas.

Since this CTG applies to large applianc e coating; therefor e, it will not be compared to SJVAPCD Rule 4605 which covers aerospace coating.

3. The CTG EPA-450/2-77-022 1977/11 applies to VOC Emissions from Solvent Metal Cleaning operations located in margi nal, moderate, serious or

severe ozone nonattainment areas that have the potential to emit greater than or equal to 25 tons/year of VO C, and equal to greater than 10 tons/year of VOC for

extreme ozone nonattainment areas.

This CTG applies to the use of th e following degreasing equipment: cold cleaners, open top vapor degreasers, and conv eyorized degreasers. Identified in the CTG are design and work practice standards for cold cleaners, open top vapor degreasers, and conveyorized degrease rs, for example: cover the solvent tank, have a facility for waste solvent and draining cleaned parts, permanent labels on operating parts, close degreaser when not in use, drain parts until dripping ceases, no excessive splashing if solvent is sprayed. The CTG also

identifies add-on controls such as re frigeration chillers and carbon control.

SJVACPD Rule 4605 i dentifies solvent VOC content limits or a control system with efficiencies of at least 90% capt ure and 95% control, and that would not allow more emissions than if compliant materials were utilized. The general solvent limit is 200 g/L; the coating stri pper solvent limit is currently 300 g/L.

Since the CTG does not identify control requirements any more stringent than SJVACPD Rule 4605, District staff consi ders Rule 4605 at least as stringent as

the CTG.

B. EPA - Alternative Control Technology (ACT)

There is no EPA ACT guidance document for aerospace coating operations.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-199 C. Standards of Performance for New Stationary Sources (NSPS)

There is no NSPS guidance document for aerospace coating operations.

D. National Emission Standards for Ha zardous Air Pollutants (NESHAPs) and Maximum Achievable Control Technologies (MACTs)

NESHAPs and MACTs are requirements contained in 40 Code of Federal Regulations (CFR) Part 61 and 40 CFR Part 63. Since EPA has delegated the authority to implement N ESHAP requirements to the District, NESHAPs and MACTs promulgated by EPA are usually inco rporated by reference into District Rule 4002 (National Emission Standards fo r Hazardous Air Pollutants). It is important to mention that the Distr ict implements NESHAPs and MACTs by incorporating the emission standards as conditions of the Permits to Operate

issued to affected sources.

1. 40 CFR 63 Subpart GG (National Emission Standards for HAPs: Aerospace Manufacturing and Rework Facilities)

The requirements in this subpart are not directly comparable to the District

Rule 4605 VOC limits. The NESH AP HAP emission limits which are expressed in terms of % HAP, HAP emission concentration, and mass (kg) of HAP per mass (kg) of solids are not dire ctly comparable to the coatings VOC limit which is expressed in terms of gr ams (or lb) of VOC per liter (or gallons) of coatings, less water and exempt com pounds, as applied. In addition, some HAPs may be exempt VOCs, and some VO Cs may be HAPs; therefore, there

is no direct correlation between the NESH AP limit versus District Rule 4605

VOC limits.

How does District Rule 4605 compare to rules in other air districts?

District staff compared District Rule 4605 with the rules of ot her California ozone nonattainment air districts’ rules (listed bel ow) for aerospace operations. The results of the analysis are discussed below.

A. South Coast Air Quality Management Dis trict (SCAQMD) Rule 1124 - Aerospace Assembly and Component Manufacturing O perations (Amended September 21, 2001) B. Bay Area Air Quality Management Distr ict (BAAQMD) Regulation 8 Rule 29 -

Adhesive and Sealant Products (Amended December 20, 1995) C. Sacramento Metropolitan Air Quality M anagement District (SMAQMD) Rule 456 - Aerospace Assembly and Component Coat ing Operations (Amended October 23, 2008)San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-200 D. Ventura County Air Pollut ion Control District (VCPCD) Rule 74.13 - Aerospace Assembly and Component Manufacturing Operations (Amended November 11, 2003)

The table below compares requi rements for each of the rules. All coating and solvent limits are in g/L.

Exemptions Bay Area (Rule 8-29) South Coast (Rule 1124) Sac Metro (Rule 456) Ventura (Rule 74.13) SJV (Rule 4605)
Airbrushing X

Fabrication of Electronic Components X

Assembled Circuit Boards X

Low Use Facility 3 gal/day 200 lbVOC/yr 4 gal/day

Military Corrosion Repair Coating 5 gal/day

Clear/Translucent Coatings on Clear/Transparent Surfaces X

Paper Fabric Film X

Tank-Type Stripper X

Adhesives X X 10 gal/yr

Aerosol Cans X X X X X

Non-Compliant Coatings 200 gal/yr 200 gal/yr 55 gal/yr 200 gal/yr 20 gal/yr

Stencil Coatings X X

Touch Up Coatings X
Recoating of Assembled Aircraft with Original Coating

Formulations X

Materials Marking Coatings X

R&D Laboratories X X

Solid Film Lubricant (Antichafe) X

Test Panels X

Temporary Marking Coatings X

Solvents (Space Vehicle) X X

Solvents (Rocket Motor Lining) X
Solvents (Jet Engine or Rocket Engine Flushing) X

Solvents (Prior to Adhesive Bonding) X

Solvents (Solar Cells, Fluid Systems, Avionic Equipment, Laser Optics) X

Solvents (Surfaces exposed to strong oxidizers or reducers) X

Satellite Coatings X
Primer (High Temp Curing Adhesive Bonding) XSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-201 Exemptions Bay Area (Rule 8-29) South Coast (Rule 1124) Sac Metro (Rule 456) Ventura (Rule 74.13) SJV (Rule 4605) Spray Application Equipment (360 Degree Spray Gun Nozzle) X

Spray Application Equipment (Waterborne Extreme Performance Interior Topcoat) X

Spray Application Equipment (Adhesive Bonding/Pretreatment Wash Primers) X

Spray Application Equipment (Textured Finish Coat) X

Application Equipment (Touch Up and Repair) X

Coatings that contain fillers to

decrease atomization with HVLP guns X

Hand Held Spray Containers w/non-refillable propellant X

Coatings added via Template, Stencil, Stamp, Hand Lettering X

Coating Type Bay Area (Rule 8-29) South Coast (Rule 1124) Sac Metro (Rule 456) Ventura (Rule 74.13) SJV (Rule 4605)

Ablative 600

Adhesion Promoter 850 850 850

Adhesion Promoter (Sealant) 750

Adhesive (Bonding Agent) 780

Adhesive (General) 600

Adhesive (Fuel Tank) 620 620 620

Adhesive (Non-Structural) 250 250 250
Adhesive (Structural Autoclavable) 50 50 50

Adhesive (Structural NonAutoclavable) 850 850 850

Antichafe 420 600 600

Conformal Coating 750 600 750 750

Dry Lubricative Material 675

Electric/Radiation Effect Coating 800 800 800 800

Electrostatic Discharge 612

Extreme Performance 750
Fire-Resistant Coatings (Commercial) 600 650 600 650 650

Fire-Resistant Coatings (Military) 800

Flight Test Coatings (Missiles 420 420 420 420San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-202 Coating Type Bay Area (Rule 8-29) South Coast (Rule 1124) Sac Metro (Rule 456) Ventura (Rule 74.13) SJV (Rule 4605) or Single Use Target Craft)

Flight Test Coatings (Other) 840 600 600

Fuel Tank Coatings 720 420 650 420 420

High Temperature Coating 850 420 850 850

Impact Resistant Coating 420 420 420
Lubricant (Solid Film - Fastener Mfr) 250 250 250

Lubricant (Dry Lubricative - Fastener Mfr) 120 250 120

Lubricant (Barrier - Fastener Mfr) 420

Lubricant (Solid Film - Fastener Installation) 880 880 880 880

Lubricant (Dry Lubricative - Fastener Installation) 675

Lubricant (Solid Film NonFastener Mfr) 880 880 880 880

Lubricant (Dry Lubricative NonFastener Mfr) 675 880 675

Maskants (General) 850 250
Maskants (Chemical Processing) 250

Maskants (Chemical Milling Type I) 250 622 250 250

Maskants (Chemical Milling Type II) 160 160 250 250

Maskants (Photolithographic) 850
Maskants (Touch-up, Line Sealer) 750

Metalized Epoxy Coating 700

Mold Release Coatings 780 762

Optical Anti-Reflective Coating 700 700 700

Part Marking Coating 850

Pretreatment Coatings 780 780
Primer (Commercial Exterior Aerodynamic Structure) 350

Primer (Adhesive Bonding) 850 780 805
Primer (Adhesive Bonding - New Commercial Aircraft) 250 250

Primer (Adhesive Bonding - Military Aircraft) 805 805

Primer (Adhesive Bonding -

Remanufactured Commercial Aircraft Parts) 805 805

Primer (Adhesive Bonding -

Sonic and Accoustic Applications) 805 805

Primer (Adhesive Bonding - 250 250San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-203 Coating Type Bay Area (Rule 8-29) South Coast (Rule 1124) Sac Metro (Rule 456) Ventura (Rule 74.13) SJV (Rule 4605) Long Term)

Primer (Adhesive Bonding - Short Term) 250 250

Primer (General) 350 350 350 350 350

Primer (Compatible Substrate) 350

Primer (Cryogenic Flexible) 350

Primer (Flexible) 350
Primer (Elevated Temperature Skydrol Resistant Commercial) 350

Primer (Low-Solids Corrosion Resistant Primer) 350

Primer (Pretreatment) 780

Primer (Pretreatment Wash) 420 780 350

Primer (Rain Erosion Resistant) 850

Primer (Sealant Bonding) 720 350

Radiation Effect 600

Rain Erosion Resistant Coating 800 600 420 800
Rain Erosion Resistant Coating (Fluoroelastomer) 800

Scale Inhibitor 880 880 880

Sealant (Extrudable/Rollable/Brushable) 600 280 600

Sealant (Fastener) 600 675 675 675

Sealant (Other) 600 600 600 600

Sealant (Sprayable) 600 600
Space Vehicle Coatings (Electrostatic Discharge Protection) 800 880 800 800

Space Vehicle Coatings (Adhesives) 800 800 800

Space Vehicle Coatings (O ther) 1,000 1,000 1,000 1,000

Temporary Protective Coating 250 250 250 250 250

Thermal Control Coating 600

Thermal Expansion Release 762
Topcoat (Acrylic Lacquer for F111) 780

Topcoat (General) 420 420 420 420 420

Topcoat (Barrier) 420 420

Topcoat (Clear) 520 520 520

Topcoat (Interior) 340 420
Topcoat (Interior - Extreme Performance) 420 420

Topcoat (Epoxy Polyamide) 420
Topcoat (Self Priming - Unicoat) 420 420 420 420 420San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-204 Coating Type Bay Area (Rule 8-29) South Coast (Rule 1124) Sac Metro (Rule 456) Ventura (Rule 74.13) SJV (Rule 4605)

Wet Fastener Installation Coating 620

Wing Coating 750 420 750

Wire Coating (Electronic) 420 420

Wire Coating (Anti-Wicking) 420 420

Wire Coating (Other) 420
Wire Coating (Pre-Bonding Etching) 420 420

Wire Coating (Phosphate Ester Resistant Ink) 925 925 925

Application Methods Bay Area (Rule 8-29) South Coast (Rule 1124) Sac Metro (Rule 456) Ventura (Rule 74.13) SJV (Rule 4605)

Brush or Roll Coat X X X X X

Dip Coat X X X X X

Detailing Gun X X X X X

Electro deposition X X X X X

Electrostatic Spray X X X X X

Flow Coat X X X X X

Hand Application X X X X X
HVLP Spray X X X X X

LVLP Spray X

Other, Transfer Efficiency

Minimum X X X X X

Add-on Control Efficiency Bay Area (Rule 8-29) South Coast (Rule 1124) Sac Metro (Rule 456) Ventura (Rule 74.13) SJV (Rule 4605)
Capture 90% 90%

Control 85% 95% 95%

Overall Control 86% 85% 85% 86%

Solvents Bay Area (Rule 8-29) South Coast (Rule 1171)* Sac Metro (Rule 456) Ventura (Rule 74.13) SJV (Rule 4605)
Cleaning (General) No Limit Exempt 200 200 200

Coating Strippers 400 Exempt 300 300 300

Cleaning (Application Equipment) Enclosed system (or

Equiv) Enclosed system (or

Equiv) Enclosed system (or

Equiv) Enclosed system (or

Equiv) Enclosed system (or Equiv)
*Per Rule 1171 (Solvent Cleaning)San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-205 As shown in the table above, SJVAPCD Ru le 4605 varies in stringency when compared to other Districts’ adhesive requirements. Howe ver, for the majority of categories, Rule 4605 is as stringent as or more stri ngent than the other District Rules.

Conclusion

District staff concludes that District Rule 4605 satisfies RACT for 

### aerospace assembly and component c oating operations

.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-206 

### Rule 4606 – Wood Products and Flat Wood Products Coating Operations

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 0 0 0 0 0 0 0 0

VOC 1.2 1.3 1.4 1. 5 1.6 1.7 1.8 1.9
(Source: District 2007 Ozone Plan)

District Rule 4606 Description

District Rule 4606, recently amended on Oct ober 16, 2008, controls VOC emissions from wood products coating operations and flat wood paneling products coating operations, and from the organic solvent cleaning, storage and di sposal of solvents, and

waste solvent materials associated with su ch coating operations. District Rule 4606 rule specifies the VOC content limits of coatings used on wood products which range from 125 grams/liter to 750 grams/liter (excluding wate r and exempt compounds, as applied) depending on the type of coating. For flat wood paneling products, the VOC content limit is 250 grams/lit er (excluding water and exempt compounds, as applied).

The VOC content limit for solvents used in cl eaning operations is 25 grams/liter of material. In lieu of complying with the s pecified VOC content lim its of coatings and solvents, operators may use a VOC emission control system with s pecified capture and control efficiency of at least 85 percent for wood coating operation, and at least 90 percent for flat wood paneling pr oducts coating operations.

District Rule 4606 exempts aerosol coatings for touch up and repair; wood products coating operations that use a total of less than 20 gallons per year in a stationary source; coatings application by template to add letters, designs or numbers to wood products; coating application to wooden musical instruments; residential noncommercial coating operation; architectu ral coating application; refinishing, replacement, and custom replica furniture o perations; and specific finishes coatings.

How does District Rule 4606 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

1. EPA-453/R-96-007 CTG for Wood Furn iture Manufacturi ng Operations

The CTG applies to wood furniture manufac turing facilities located in marginal, moderate, serious or severe ozone nonattainment areas that has the potential to emit greater than or equal to 25 tons/year of VO C, and equal to greater than 10 tons/year of

VOC for extreme ozone nonattainment areas. The CTG specifies VOC limits only forSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-207 topcoats and sealers, but not fo r any other coating types whic h range from 0.8 to 2.3 lb VOC/lb solid (equivalent to 460 to 660 grams/liter of coati ng). District Rule 4606 VOC limits 275 grams/liter for topcoats and sealers are more stringent than the CTG limits. The CTG does not exempt refinishing, replac ement and custom replic a furniture coating operations, but District Rule 4606 exempts such operations from meeting the VOC limits. However, a review of the Distric t’s Permit to Operate (PTO) database indicates that there are only two permitted refinishing c oating application facili ties operating in the San Joaquin Valley. The annual VOC emission of one facility is 0.2 tons/year and is using a coating with a VOC limit of 2.14 lb/gal which is less than 2.3 lb/gal VOC limit of

District Rule 4606. The annual VOC emissions of the other facility is 0.8 tons/year and

uses low VOC stains with a VOC content of 0.58 lb/gal, sealers with a VOC content of 0.51 lb/gal, topcoats with a VO C content of 0.58 lb/gal, pi gmented coatings with a VOC content of 2.3 lb/gal which are within the specified VOC limits of District Rule 4606.

In response to April 1, 2009 EPA comments recommending more detailed discussion regarding the exemption Rule 4606 exemption for refinishi ng, replacement and custom replica coating operations, District staff has included the following justifications:

• The only two permitted facilities in the San Joaquin Valley are using compliant coatings that meet t he VOC limits of Rule 4606 as discussed above.

• The total VOC emissions of 0.28 tons/year (0.00077 tons/day) from refinishing, replacement and custom replica furniture coating operations in the District is only 0.05% of 474.5 tons/year (1.3 tons/day) 2008 baseline emissions inventory.

• The annual VOC emissions of each exempted facility (0.2 tons/year and 8 tons/year) are much less than the CTG appl icability threshold of 10 tons/year of VOC per facility. Theref ore, the CTG does not apply to these refinishing

facilities.

2. EPA 453-06-004 CTG for Flat Wood Paneling Coatings

District Rule 4606 VOC limit of 250 grams/liter for coatings , inks, or adhesives applied to flat wood paneling products are the same as the limit in the CTG. Based on the discussion above, District staff deems District Rule 4606 satisfies RACT.

B. EPA – Alternative Control Technology (ACT)

There is no EPA ACT guidance docum ent for wood coating operations.

C. Standards of Performance fo r New Stationary Sources (NSPS)

There is no NSPS for wood products coati ng operations or flat wood paneling products coating operations.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-208 D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

NESHAPs and MACTs are requirements contai ned in 40 Code of Federal Regulations (CFR) Part 61 and 40 CFR Part 63. Since EPA has delegated the authority to implement NESHAP requirements to the Dis trict, NESHAPs and MACTs promulgated by EPA are usually incorporated by reference into District Rule 4002 (National Emission

Standards for Hazardous Air Pollu tants). It is impor tant to mention that the District implements NESHAPs and MACTs by inco rporating the emission standards as

conditions of the Permits to Operate issued to affe cted sources.

1. 40 CFR 63 Subpart JJ (National Em ission Standards for Wood Furniture Manufacturing)

This NESHAP applies to wood furniture manufacturing sour ces that are not exempt under the following conditions: (1 ) a source that uses no more than 250 gallons per month, for every month, of coating, gluing, cleaning, and wash off materials at the source; (2) a source that uses no more than 3,000 gallons per ro lling 12-month period, for every 12-month period, of coating, glui ng, cleaning, and wash off materials at the source, including materials used for sour ce categories other than wood furniture (surface coating); or (3) a s ource that emits no more than 4.5 Mg (5 tons) of any one HAP per rolling 12-month period and no more than 11.4 Mg (12.5 tons) of any combination of HAP per rolling 12-month peri od, and at least 90 percent of the plant wide emissions per rolling 12-month period are associated with the manufacture of

wood furniture or wood furnitur e components. Exempt source s are required to maintain monthly records of the amount of VOC-c ontaining materials used and such records have to be kept for a period of five years.

It is important to mention that the NESHAP HAP emission limit which is expressed in terms of mass (kg) of HAP per mass (kg) of solids is not directly comparable to the coatings VOC limit which is expressed in te rms of grams (or lb) of VOC per liter (or gallons) of coatings, less wa ter and exempt compounds, as app lied. In addition, some HAPs may be exempt VOCs, and some VOCs may be HAPs; therefore, there is no

direct correlation between the NESHAP limit versus District Rule 4606 VOC limits.

2. 40 CFR 63 Subpart DDDD—National Emission Standards for Hazardous Air Pollutants: Plyw ood and Composite Wood Products

This NESHAP applies source s that manufacture plyw ood and/or composite wood products by bonding wood material (fibers, particles, strands, veneers, etc.) or agricultural fiber, generally with resin under heat and pressure, to form a structural panel or engineered wood product, and that emit or hav e the potential to emit any single HAP at a rate of 9.07 megagram s (10 tons) or more per year or any combination of HAP at a rate of 22.68 megagrams (25 tons) or more per y ear. Plywood and composite wood products manufacturing facilities also include facilities that manufacture dry veneer and lumber kilns located at any facility.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-209 It is important to mention that the NESHAP HAP emission limit which is expressed in terms of mass (kg) of HAP per mass (kg) of solids is not directly comparable to the coatings VOC limit which is expressed in te rms of grams (or lb) of VOC per liter (or gallons) of coatings, less wa ter and exempt compounds, as app lied. In addition, some HAPs may be exempt VOCs, and some VOCs may be HAPs; therefore, there is no

direct correlation between the NESHAP limit versus District Rule 4606 VOC limits.

Currently, there is no plywood or composit e wood products manufacturing companies operating within the San Joaquin Valley.

3. 40 CFR 63 Subpart QQQQ (National Emis sion Standards for Surface Coating of Wood Building Products)

This NESHAP applies to source s that perform surface coat ing operations involving wood building products that use at least 4,170 liters (1,100 gal lons) of coating per year, and is a major source, is locat ed at a major source, or is a part of a major source of HAP emissions. A major source is a sour ce that has the pot ential to emit 9.0 megagrams/yr (10 tons/yr) of any single HAP or 22.68 megagram s/yr (25 tons/yr) of any

combination of HAP. This NESHAP applies to new, reconstruc ted, and existing source (a new affected source is one on which construction commenced after 6/21/02). The NESHAP specifies work practice st andards, monitoring and recordkeeping.

It is important to mention that the NESHAP HAP emission limit which is expressed in terms of mass (kg) of HAP per mass (kg) of solids is not directly comparable to the coatings VOC limit which is expressed in te rms of grams (or lb) of VOC per liter (or gallons) of coatings, less wa ter and exempt compounds, as app lied. In addition, some HAPs may be exempt VOCs, and some VOCs may be HAPs; theref ore, there is no

direct correlation between the NESHAP limit versus District Rule 4606 VOC limits.

How does District Rule 4606 compare to rules in other air districts?

District staff compared VOC lim its, optional control require ments, and work practice standards in District Rule 4604 to comparable requirements in rule s from the following

California nonattainment areas:

• South Coast AQMD Rule 1136 (Wood Products Coatings) amended June 14, 1996

• SCAQMD Rule 1104 (Wood Flat Stock C oating Operations) amended August 13,

1999

• BAAQMD Regulation 8 Rule 23 (Coating of Flat Wood Paneling and Wood Flat Stock) amended December 20, 1995

• BAAQMD Regulation 8 Rule 32 (Wood Products Coatings) amended June 19, 1996

• Sacramento Metropolitan Air Quality M anagement District (SMQMD) Rule 463 (Wood Products Coating) amended July 23, 1998

• Ventura County Air Polluti on Control District (VCPCD) Rule 74.30 (Wood Products Coatings) amended June 6, 2006.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-210 A. SCAQMD Rule 1136 (Wood Products Coatings)

SCAQMD Rule 1136 applies to coating oper ations on any wood products. The VOC limits range from 120 to 750 gr ams/liter for coatings dependi ng on the coating type and 500 grams/liter for inks. As an alternate co mpliance option to using compliant coatings, the rule allows operators to use emissions av eraging for all or a portion of the coatings at a facility in provided t he actual emissions from the coatings being averaged do not exceed the emissions generated by complying wit h the specified coating limits. The rule includes coating applicati on equipment requirements and a VOC limit for solvent cleaning and surface preparati on pursuant to SCAQMD Rule 1171 (Solvent Cleaning Operations). The rule exempts facilities that use one gallon/day or less of coating. In addition, the rule exem pts japans provided the VOC content is 700 gram s/liter or less. The rule also allows the addition of 10% by volume to topcoat, primer, sealer or undercoat to avoid blushing during high humidit y provided the coating contains no more than 550 grams/liter of VOC and t he coating is not applied from April 1 to October 31 of any year. The rule does not exempt refi nishing, replacement, and custom replica furniture coating operations.

District Rule 4606 has the same VOC content limits as SCAQMD Rule 1136, except

that District Rule 4606 VOC lim it of 240 grams/liter is lower than SCAQMD Rule 1136 limit of 350 grams/liter. Dis trict Rule 4606 does not allo w operators to use emissions averaging, but SCAQMD Rule 1136 allows it as a complia nce option instead of using compliant materials. District Rule 4606 allo ws an operator to install and operate a VOC emission control system with a specified capt ure and control efficiency in lieu of using compliant coatings. The coating application methods specified in District Rule 4606 are
identical to SCAQMD Rule 1136. The solven ts cleaning VOC limit of 25 grams/liter in
District Rule 4606 is the same as the SCAQ MD solvent cleaning limit for this source category which regulated under SCAQMD Rule 1171.

SCAQMD Rule 1136 exemption from the VOC limit s and coating application method for facilities that use less than one gallon per day or less of coating is less stringent than District Rule 4606 exemption for facilities t hat use 20 gallons per year of coating. District Rule 4606 exempts refinishing, r eplacement, and custom replica furniture coating operations but SCAQ MD Rule 1136 does not exempt such coating operations. As discussed in Section III.A above, there are only two permitted facilities that performs refinishing coating operat ions and their total comb ined annual VOC emissions are insignificant (1 ton/year or 5 lb/day of VOC) which is in significant. SCAQMD Rule 1136 allows the use of japans wit h a high VOC limit of 700 grams/ liter, but District Rule 4606 considers japans as pigmented coating subject to 275 grams/ liter VOC limit. District
SCAQMD Rule 1136 allows the addition of 10% by volume to topcoat, primer, sealer or undercoat, but District Rule 4606 does not allo w it. The coating application equipment and solvent cleaning requirements of Distric t Rule 4606 are as stringent as SCAQMD Rule 1136. Based on the above discussion, in spite of exempt ion for refinishing operations, District staff deems that overa ll District Rule 4606 is as stringent as
SCAQMD Rule 1136.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-211 B. SCAQMD Rule 1104 (Wood Flat Stock Coating Operations)

SCAQMD Rule 1104 applies to manufacturing of finished wood panel. The VOC limit is 250 grams/liter for coatings, inks, and adhesiv es. In lieu of complying with the VOC limit, an operator may use a VO C control equipment that reduc es the emissions by at least 95 percent or the output of the control device is less than 50 ppm and provided the efficiency of the collection system is at l east 90 percent. District Rule 4606 has the same coating VOC limits but the VOC emission system’s capt ure and control efficiency is more stringent by an additional 5 percent [i.e., 90 percent overall capture and control efficiency for flat wood paneling products c oating operations versus SCAQMD Rule 1104 control efficiency of 85.5 percent (95 per cent control x 90 percent capture)].

The coating application met hods specified in District Rule 4606 are identical to SCAQMD Rule 1104. The solvents cleaning VOC limit of 25 grams/ liter in Rule 4606 is the same as the SCAQMD solvent cleaning limit for this source category which regulated under a separate rule SCAQMD Rule 1171 (Solvent Cleaning Operations). Based on the above discussion, District Rule 4606 is more stringent than SCAQMD

Rule 1104 based on the VOC emission cont rol system overall capture and control efficiency.

C. BAAQMD Regulation 8 Rule 23 (Coa ting of Flat Wood Paneling and Wood Flat Stock)

BAAQMD Regulation 8 Rule 23 applies to the application of coatings and adhesives to flat wood and wood flat stock products. The VOC limit for coatings, adhesives, and inks is 250 grams/liter. The rule allows operators to use an air pollution abatement device with an efficiency of at least 90 percent. Overall, the emission limits and control device efficiency requirements of BAAQMD Regulation 8 Rule 23 is as stringent as District Rule 4606 for this source category.

D. BAAQMD Regulation 8 Rule 32 (Wood Products Coatings)

BAAQMD Regulation 8 Rule 32 applies to wood products coating operations. The rule has separate coating VOC lim its depending on the type of wood products. The VOC limits for general wood product range from 2 75 to 700 grams/liter depending on the type of coating. The VOC limits for furniture, custom cabinet ry, and custom architectural millwork range from 480 to 700 gr ams/liter. For custom and c ontract furniture, the VOC limits range from 480 to 700 gram s/liter. The rule does not hav e a VOC limit for stripper. In lieu of using compliant coatings, the rule allows an operator to use an air pollution abatement equipment has an abatem ent efficiency of at lest 85 percent. In addition, operators may demonstrate compliance with t he VOC limits by averaging (multiple day periods on a rolling basis for a period no greater than 30 days) any or all coatings and solvent usage directly to the coating of wood products. The rule contains several exemptions such as facilities that use a to tal of less than 20 gallons of coatings per year; refinishing, replacemen t, and custom replica furnitur e; stencil coatings; musicalSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-212 instruments; and other types of exemptions. In addition the rule also exempts facilities that use low VOC coatings t hat at are high solid coatin gs with a VOC content of no more than 275 grams/liter and lo w solids coatings with a VOC content of no more than 120 grams/liter. The rule includes solvent evaporative loss minimization as well as coating application equipment requirement s.

In comparison, District Rule 4606 VOC lim its range from 120 to 500 grams/liter for coatings and 750 grams/liter for inks for all types of wood products. The stripper VOC limit is 350 grams/liter. District Rule 4606 al so exempts refinishing, replacement, and custom replica furniture coating operations and facilities that us e less than 20 gallons per year of coatings, but does not exempt facilities that use low VOC coatings as provided by BAAQMD Regulation 8 Rule 32. Based on the above discussion staff deems that, overall, District Rule 4606 is more stringent than BAAQMD Regulation 8

Rule 32.

E. Sacramento Metropolitan Air Qualit y Management District (SMQMD) Rule 463 (Wood Products Coating)

SCAQMD Rule 463 applies to coatings, stri ppers, used in wood products wood products coating operations and solvents used in su rface preparation and cleanup. The coatings VOC limits for new wood products range from 120 to 750 grams/liter of coating depending on the type coating. The coatings VOC limits fo r refinishing, repairing, preserving, or restoring wood products r ange from 480 to 700 grams/ liter depending on the type of coating. The VO C limit for stripper is 350 gram s/liter or a VOC composite partial vapor pressure of 2 mm Hg (0.04 psia) or less at 68 0 F. In lieu of complying with the VOC limits, an oper ator may use an air pollution co ntrol device which reduces the emissions by an equivalent or greater amount than t he emissions resulting from the use of compliant coatings and strippers. The rule also allows operators to use an approved emission averaging method which demonstrates t hat the emissions from all the coatings being averaged are less than the a llowable emissions from usi ng compliant materials. The rule contains coating applicati on equipment and solvent cleanup and surface preparation requirements. T he VOC limit for solvent cl eanup and surface preparation is 200 grams/liter. The rule contains several ex emptions such as sources using less than 55 gallons/year, coating operat ions for the purpose of m anufacturing finished wood panels, non-refillable aerosol coati ngs, and stencil coatings.

In comparison, District Rule 4606 coatings VOC limits are the same as SMAQMD Rule 463 limits for new wood products. However, District Rule 4606 exempts refinishing, replacement, and custom replica furniture coat ings operations. As discussed in Section III.A above, there are only two permitted fa cilities that performs refinishing coating operations and their total combined annual VOC emissions are insignificant (1 ton/year or 5.5 lb/day of VOC). District Rule 4606 only allows the use of strippers with a VOC limit of 350 grams/liter, but SMAQMD Rule 463 allows the use of a stripper with either a composite partial vapor of 2 mm Hg (0.04 psia) or less at 68 0 F or with a VO C limit of 350 grams/liter. In addition, District Rule 4606 solvent cleanup an d surface preparation VOC limit is 25 grams/ liter which is more stringent than SMAQMD Rule 462 limit of 200San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-213 grams/liter. Based on the abov e discussion, District staff d eems that overall District Rule 4606 is as stringent as SCAQMD Rule 463.

F. Ventura County Air Pollution Contro l District (VCPCD) Rule 74.30 (Wood Products Coatings)

VCPCD Rule 74.30 applies to coatings used in wood products. The VOC limits for new wood product or new simula ted wood products range from 120 to 500 grams/liter for coatings, 240 grams/liter for sealers, and 750 grams/liter for inks. For refinishing operation, the VOC limit s range from 480 to 680 grams for coatings and 750 grams/liter for inks. The VOC limit for stripper is 350 gr ams/liter or a VOC co mposite partial vapor pressure of 2 mm Hg (0.04 psia) or less at 68 0 F. The rule allows the use of an emission control system that achieves a combined capt ure and control efficiency of at least 90 percent. The rule contains coating application equipment and solvent cleanup and surface preparation requirement s. The VOC limit for solvent cleaning is 25 grams/liter. The rule exempts facilities that emit less than 200 pounds in every rolling 12 consecutive calendar months. Also exempt is coating of wooden musical instruments.

In comparison, District Rule 4606 coatings VOC limits are the sa me as VCAPCD Rule 74.30 limits for new wood products, except the VOC limit of 275 gram s/liter for sealers is slightly higher than Vent ura’s 240 grams/liter limit. Unlike VCAPCD Rule 74.30, District Rule 4606 exempts sources that perfo rm refinishing coating operations. As discussed in Section III.A above, there are onl y two permitted facilities that perform refinishing coating operati ons and their total combined annual VOC emissions are not significant (1 ton/year or 5.5 lb/day of VOC). District Ru le 4606 only allows the use of strippers with a VOC limit of 350 grams/liter, but VC PCD Rule 74.30 allows the use of a stripper with either a composit e partial vapor of 2 mm Hg (0.04 psia) or less at 68 0 F or with a VOC limit of 350 gram s/liter. District Rule 4606 emission control system efficiency of 85 percent for wood products coating operations is less stringent than VCPACD Rule 74.30 control efficiency of 90 perc ent. However, a review of the District’s Permit to Operate database indicates that ther e are no wood coating facilities in the San Joaquin Valley that operate a VO C emission control system as a compliance option in lieu of using compliant coatings required by District Rule 4606. Therefore, increasing the capture and control efficiency of the VOC control system from 85 percent to 90 percent would not result in any emissions reductions from current level.

VCPCD Rule 74.30 exemption for facilities t hat emit 200 lb/year of VOC or less is slightly less stringent than District Rule 4606 exemption of 20 gallons/year per facility (assume a VOC limit of 6.7 lb/ gal, 20 gallons of coating/year exemption would only emit 134 lb/year of VOC). Based on the above discu ssion staff deems that, overall, District Rule 4606 as stringent as VCPACD Rule 74.30.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-214 Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, Distric t staff concludes that District Rule 4606 satisfies RACT for wood products and flat wood products coating operations.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-215 

### Rule 4607 – Graphic Arts

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 0.0 0.0 0.0 0. 0 0.0 0.0 0.0 0.0

VOC 1.7 1.7 1.9 1. 9 2.1 2.2 2.3 2.3
(Source: District 2007 Ozone Plan)

District Rule 4607 Description

This source category in cludes any graphic arts pr inting operation, to any paper, fabric film, or foil coating operation, to the organic solvent cleaning, and to the storage and disposal

of solvents and waste solvent materi als associated with these operations.

How does District Rule 4607 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

1. EPA 450/2-77-008 –Control Technique Guide lines for Control of VOCs from Existing Stationary Sources – Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks

Out of the six surface coati ng operations covered by the CTG, two are part of District Rule 4607 (Graphic Arts) – paper coating and fabric coat ing. The CTG-recommended

VOC content limits for coatings within these source ca tegories ranges from 290 grams per liter to 380 grams per liter depending on coating type. The CTG also allows operators to use higher VOC content mate rials if the operator uses an add-on VOC emission control system with ov erall capture and control efficiency of at least 81%.

The coating VOC content limit s in the CTG are higher than the VOC content limit of 265 grams per liter for the same categories in District Rule 4607. The required overall capture and control efficiency for paper and fabr ic coating operations in District Rule 4607 is 90%, which is higher than the 81% overall capture and control efficiency

recommended in the CTG.

2. EPA 450/2-78-033 – Control Techniques Gui delines for Control of VOCs from Existing Stationary Sources – Volume VIII: Graphic Arts - Rotogravure and Flexography

This CTG applies to printing and coating oper ations using rotogravure (gravure) and flexography (flexo). The CTG acknowledges that these operations tend to use highSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-216 VOC inks and coatings for technical reasons. Because of this, the CTG first discusses add-on controls for these operations, follo wed by ink VOC content limits.

Recommended overall capture and cont rol efficiencies depend on the printing technology and the product. For publicat ion gravure and publication flexo, recommended the overall capture and control is broken into its components - 75% capture and 90 to 95% control, meaning that the overall c apture and control would be the capture multiplied by the c ontrol, which is minimally 67.5%. For packaging gravure, overall capture and control efficiency is recommended at 65% and all non-publication flexo at 60% overall capture and control.

The CTG recommends that 25% of the volatile portion of t he ink as solvent for waterborne gravure and water-borne flexo inks an d a 70% reduction in solvent usage compared to all-solvent inks as being co mparable to an add-on VO C control system. The CTG also recommends an exemption for inks with more than 60% non-volatiles.

The CTG recommendations for inks cannot be directly compared to the VOC content

limits for inks in District Rule 4607. The Distr ict rule limits inks and other materials to a specific VOC content in grams VOC per liter material, minus water and exempt compounds. The CTG does not have VOC cont ent expressed in these units; therefore

it is difficult to determine whether the CT G and the District rule are equivalent. Any comparison for water-borne inks would have to be done on a case-by-case basis for

individual inks because the ratio of water to solvent could be different for each waterborne ink and the water/solvent ratio is not di rectly tied to the VO C content as evaluated by the District rule. Evaluating solvent-bas ed ink reductions would also be problematic since the volume of solids per volume of ma terial could greatly a ffect the overall VOC content when the content is expressed per liter of material, minus water and exempt compounds.

Current District Rule 4607 specifies overall control for add-on control devices used in graphic arts operations into three groups. T he VOC emission control system is required to have an overall capture and control efficien cy of at least 80% for flexible packaging printing (regardless of printing technology us ed), 85% for publication gravure, and 75% for other types of graphic arts printing operations.

3. EPA 453/R-06-002 – Control Techniques Guide lines for Offset Lithographic Printing and Letterpress Printing

This CTG, promulgated by EPA September 2006, provides control recommendations for reducing VOC emissions stemming from the use of fountai n solutions, cleaning materials, inks in offset lithographic prin ting and cleaning materials, and inks in letterpress printing. The CTG contains th ree mechanisms to reduce VOC emissions from offset lithographic prin ting and letterpress printing. These options are add-on controls, process modifications or work practices, and material reformulation or

substitution. The recommended level of contro l for VOC emissions from dryers for heatset operations is either 90% or 95% contro l efficiency depending on the control device’sSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-217 installation date. The CTG recommends applyi ng controls to offset lithographic printing operation where emissions asso ciated with all aspects of t hat operation equal or exceed 6.8 kg per day (15 pounds per day) actual em issions of VOC or an equivalent level,

before consideration of cont rols. The allowable VOC content depends on the specific ink (heat-set or cold-set) and feed type (w eb-fed or sheet-fed). The allowable VOC content is further modified through how much alc ohol is allowed in the fountain solution.

The CTG recommends that the control for fountain solution not be applied to sheet-fed presses with maximum sheet size of 11X17 inches or smaller, or to any press with total fountain solution reservoir of less than 1 gal lon. District Rule 4607 has been recently amended to incorporate the recommendations of this CTG.

The CTG recommends the use of cleaning materials with a VOC composite vapor pressure less than 10mm Hg at 20 o C or cleaning material s containing less than 70 weight percent VOC for blanket washing, roll er washing, plate cleaners, metering roller cleaners, impression cylinder cleaners, rubber rejuvenators, and other cleaners used for cleaning a press, press parts, or to remove dried ink fr om areas around a press. Additionally, cleaning materials and used s hop towels should be kept in closed

containers. Current District Rule 4607 has a specific allowable VOC content limit for different cleaning operations, which is not direct ly comparable to a vapor pressure limit. The solvent cleaning VOC content limit for solvent cleaning related to flexo and gravure printing are less than the recommended VOC content recommended in the CTG. The District rule incorporates work practices similar to the CTG.

4. EPA 453/R-06-003 – Control Techniques Guidelines for Flexible Package Printing

This CTG, promulgated by EPA September 2006, provides control recommendations for reducing VOC emissions from inks, coati ngs, adhesives and cleaning materials used by the rotogravure and flexographic printing industries for flexib le packaging printing. The two approaches to reducing VOC emissions from inks, coatings, and adhesives used in the flexible package printing industry are adding or improvi ng add-on emission controls,

and material reformulation or substitution.

The primary thrust of the CTG is control of emissions through add-on emission controls. As such, the CTG outlines overall control efficiency for presses, depending on the date the press was first installed and the date an add-on control was first installed. The range of overall control is 65% to 80%. As an alternative to the overall control requirements, the CTG also recommends tw o equivalent VOC content limits for inks which can be met by use of low VOC content materials or a combination of materials

and controls. These VOC content limits ar e consistent with an 80 percent overall

emission reduction level and reflect similar c ontrol levels as the capture and control option. The CTG does not recommend a specif ic VOC content limit for materials used during cleaning, but does recommend certain wo rk practices to limit emissions during cleaning. Current District Rule 4607 has a specific allowable VOC content limit for different cleaning operations and incorporates work practices similar to the CTG.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-218 District Rule 4607 has recently been amended to incorporate those CTG recommendations that were less stringent.

5. EPA 453/R-07-003 – Control Techniques Guidelines for Paper, Film, and Foil Coatings

This CTG provides control recommendatio ns for reducing VOC emissions stemming from the use of coatings in paper, film, and foil surface c oating operations. Coating performed on or in-lin e with any offset lithographic, scr een, letterpress, flexographic, rotogravure, or digital printi ng press is part of a printing process and is not part of the paper, film, and foil coating category. Comm on control techniques for reducing VOC emissions from paper, film, and foil surface coatings include pollution prevention measures and the operation of emissi on capture and add-on control systems.

Overall VOC control efficiency of 90 perc ent is recommended for each paper, film, and foil surface coating line. As an alternative to an overall 90 percent control efficiency, the

CTG recommends VOC content-based emission lim its that are equival ent to 90 percent overall control, which can be met by use of low-VOC content materi als or combinations

of materials and controls. EPA recommends the limit of 0.20 kg VOC/kg (0.20 lb VOC/lb) solids applied and an addit ional equivalent limit of 0. 067 kg VOC/kg (0.067 lb VOC/lb) of coatings as RACT for pressure sensitive tape and label surface coating lines. District Rule 4607 has been recently amended to include the recommendations of

this CTG.

The CTG does not recommend a specific VOC content limit for materials used during cleaning, but does recommend certain work practi ces to limit emissions during cleaning. Current District Rule 4607 has a specific a llowable VOC content limit for different cleaning operations and includes the CTG-recommended work practices.

B. EPA – Alternative Control Technology (ACT)

There is no ACT for this source category.

C. Standards of Performance fo r New Stationary Sources (NSPS)

1. 40 CFR 60 Subpart QQ – Standards of Perfor mance for the Graphic Arts Industry: Publication Rotogravure Printing

This NSPS applies to each publication rotogr avure printing press at a facility that commenced construction, modification, or re construction after October 28, 1980. The NSPS does not apply to proof presses.

The NSPS requires that emitted VOC be no mo re than 16 percent of the total mass of

VOC solvent and water used at that facilit y during any 30-consecutive calendar day averaging period. The water used includes onl y that water contained in the waterborneSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-219 raw inks and related coatings and the wa ter added for dilution with waterborne ink systems.

The NSPS provision cannot be directly comp ared to the VOC content limits for inks or compared to the control efficiency limits in District Rule 4607. The NSPS is based on the volatile (water plus solvent) emissions from the operation as a whole and, therefore,

it is difficult to determine whether the N SPS and the District rule are equivalent. The

District rule limits inks and other materials to a specific VOC content in grams VOC per liter material, minus water and minus exempt compounds. Further, the District rule has a minimum overall capture and control requirement for add-on emission control systems. Any comparison for would have to be done on a case-by-case basis for

individual facilities because the ratio of wa ter to solvent could be different for each facility and the solvent-to-water ratio is not directly tied to the VOC content or the emission control system control efficiency.

2. 40 CFR 60 Subpart RR – Standards of Perf ormance for Pressure Sensitive Tape and Label Surface Coating Operations

This NSPS applies to coatings for pressure sensitive tape and labe ls where the coating operations are located at a facility whic h began construction, modification, or reconstruction after December 30, 1980. T here are two ways to control emissions – through VOC content limit and by specifying the overall capt ure and control of the addon control device. The VOC content limit is listed in pounds of VOC per pound of coatings solids. The alternative over all capture and control required is 90%.

District Rule 4607 incorporates the VOC content limits as a specific requirement in the rule as well as having an overall capture and control efficiency of at least 90% for these operations.

3. 40 CFR 60 Subpart FFF – Standards of Pe rformance for Flexible Vinyl and Urethane Coating and Printing

The affected facility is a facility which began c onstruction, modification, or reconstruction after January 18, 1983. The operation subject to the NSPS is rotogravure printers used to print or coat flex ible vinyl or urethane products. T he NSPS requires that the operator use inks with a weighted average VOC content less than 1.0 kilogram VOC per kilogram ink solids at each affected facility, or, equivalently, to reduce VOC emissions by 85 percent from the facility.

District Rule 4607 does not address this source category as a specific sub-category of the graphic arts. Grav ure printers/coaters are held to an ink VOC content of 300 grams per liter of material, minus water and ex empt compounds. This is not directly comparable to the NSPS VOC content. In lieu of meeting the VOC content limits, operators could choose to use a VOC contro l system to reduce their emissions from printing, however, use of the system c annot have emission more than would have occurred if the operator used co mpliant materials. In Dis trict Rule 4607, the minimumSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-220 overall capture and control efficiency is 75% for VOC emission control systems for gravure printing/coating other than flexible pa ckaging and publication. It is difficult to

determine whether the NSPS and the current District rule are equivalent – such comparisons would need to be done on a coating-by-coating basis.

4. 40 CFR 60 Subpart SSS – Standards of Performance for Magnetic Tape Coating

Facilities

Subpart SSS applies to coating operations and coating mix preparation operations located at a magnetic tape manufacturing facilit y for which construction, modification, or reconstruction began after January 22, 1986. Of the two operations, only the coating operations correspond to District Rule 4607 sources. The prov isions of this subpart that apply to coating operations will be used for this analysis.

Control of coating VOCs is through a VOC emission control device with overall capture and control ranging from 90% to 95%, depending on whether a the oper ation is new or

modified/reconstructed and whether the VOC em ission control system is control device

is new or has been modified/reconstructed.

Because magnetic tape is a special coating on film, magnetic tape manufacturers would

be considered film coaters for District Rule 4607. As such, they would be subject to an overall capture and control efficiency of at least 90%. However, the District has no sources that manufacture magnet ic tape. Any new source t hat would begin operations would be subjet to the Distr ict New and Modified Source Review Rule, which would require that the new operation meet this NSPS as a minimum standard.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

There are no NESHAPs in 40 CFR 61 directly applicable to sources subject to District

Rule 4607. There are three MACTs in 40 CF R 63 that apply to sources subject to

District Rule 4607.

1. 40 CFR 63 Subpart KK – National Em ission Standards for the Printing and Publishing Industry

This MACT applies to major sources of hazardous air pollutants (HAPs) that perform rotogravure printing for the publication, product, or packaging markets. It also applies to wide-web flexographic printing that is a major source of HAPs.

For publication rotogravure, emissions of HA Ps are limited to no more than 8% of the total volatile matter used each month. Operat ors may comply with this limit with an addon emission control system having overall capt ure and control efficiency of at least 92%, by substitution of non-HAP materials for orga nic HAP, or by a combination of both.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-221 In the case of product rotogravure, pack aging rotogravure, and wide-web flexographic printing operations, the emission of HAPs has th ree numeric limits. The first limit is that

emissions are limited to no more than 5% of the organic HAP appli ed for the month.

The second limits is that the HAPs emission s are no more than 4% of the total mass of inks, coatings, varnishes, adhesives, primers, solvents, reducers, thinners, and other materials applied during the mont h. The third limit is that HAPs emissions are no more
than 20% of the mass of so lids applied during the mont h. Operators may use an

emission control device with ov erall HAP control efficiency of at least 95% and that

limits the emissions to no more than w ould have been emitted had they complied with

all three numeric limits.

HAPs and VOCs are not directly comparable. The VOC contents in District Rule 4607 are given in units of pounds of VOC per liter of material, minus water and minus exempt compounds. Subpart KK has different units of measure for HAPs . Not only are the units of measure different, a given H AP compound may not be photo-chemically reactive, meaning that the HAP is an exem pt compound and not counted as a VOC. Thus, the NESHAP does not define app licable RACT for these sources.

2. 40 CFR 63 Subpart JJJJ – National Em ission Standards for Hazardous Air Pollutants: Paper and Other Web Coating

This subpart of the CFR applies to facilities t hat perform web coating and the facility is a major source of HAPs. Exemptions in clude web coating done with lithography, screen printing, letterpress, and na rrow-web flexographic printing as well as any web coating subject to a different subpart of 40 CFR 63. Research and laboratory equipment is also exempt.

The subpart limits the emission of HAPs relati ve to the amount of HAPs. Because the particular HAPs emitted may not be an exem pt compound and not, t herefore, a VOC,

the emission limits in this MACT are not di rectly comparable to VOC content limits. HAPs and VOCs are not directly comparable. The VOC cont ent limits in District Rule 4607 are given in units of pounds of VOC per liter of material, minus water and minus exempt compounds. Thus, t he NESHAP does not define app licable RACT for these

sources.

3. 40 CFR 63 Subpart OOOO – National Em ission Standards for Hazardous Air Pollutants: Printing, C oating, and Dyeing of F abrics and Other Textiles

40 CFR 63 Subpart OOOO applies to facilities t hat are major HAPs sources that coat, print, dye, slash, or finish f abrics and other textiles. There are five exemptions: if the particular operation does not use materials wit h organic HAPs, if the operations occur at a research or laboratory, if the materials are used internally (not for commerce), if the operations are conducted at am bient temperatures (no heat ers or dryers), and if the facility is located on a US Armed Forces installation.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-222 HAPs and VOCs are not direct ly comparable. The VOC contents in District Rule 4607 are given in units of pounds of VOC per liter of material, minus water and minus exempt compounds. Subpart KK has different units of measure for HAPs . Not only are the units of measure different, a given H AP compound may not be photo-chemically reactive, meaning that the HAP is an ex empt compound and not counted as a VOC. Thus, the NESHAP does not define app licable RACT for these sources.

How does District Rule 4607 compare to rules in other air districts?

District staff compared VOC content limits, optional cont rol requirements, and work practice standards in District Rule 4607 to comparable requirements in rules from the following California nonattainment areas:

• South Coast AQMD Rule 1128, as amended March 1996

• South Coast AQMD Rule 1130, as amended October 1999

• South Coast AQMD Rule 1130.1, as amended December 1996

• South Coast AQMD Rule 1171, as amended February 2008

• Bay Area AQMD Regulation 8 Rule 4, as amended October 2002

• Bay Area AQMD Regulation 8 Ru le 12, as amended December 1995

• Bay Area AQMD Regulation 8 Ru le 20, as amended November 2008

• Sacramento Metropolitan AQMD Ru le 450, as amended March 2000

• Sacramento Metropolitan does not have a pr ohibitory rule for paper, film, foil or fabric coating.

• Ventura County APCD Rule 74. 19, as amended November 2003

• Ventura County APCD Rule 74. 19-1, as amended November 2003

• Ventura County APCD Rule 74. 3, as amended December 1991

A. South Coast AQMD Rule 1128 (Paper, Fabric and Film Coating Operations)

South Coast AQMD Rule 1128 applies to all persons applying coatings or wash primers to paper, fabric, or film substrates. Coat ing VOC content is lim ited to 265 grams VOC per liter of coating less water and less exem pt compounds, as applied. Plastisol is limited to 20 grams VOC per liter of materi al less water and less exempt compounds, as applied. Wash primer is limit ed to 365 grams VOC per liter of material used. In lieu of using compliant materials, an operator may install and operate an approved VOC emission control system. The co llection portion of the system must collect at least 90% of the VOC vapors and the control portion of the system must destro y at least 95% of the collected vapors or the control device emit no more than 50 parts per million without

dilution.

District Rule 4607 VOC content limits for mate rials used for paper, fabric, and film are

similar to South Coast Rule 1128 for c oatings. The overall capture and control efficiency for these operations in at least 90% which is higher than the overall capture

and control of the South Coast ru le (90% times 95% or 85.5%).San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-223 B. South Coast AQMD Rule 1130 (Graphic Arts)

South Coast Rule 1130 applies to persons performing graphic arts operations or who solicit, specify, offer for sale, sell, or distribute graphic arts materials for use in the South
Coast AQMD.

If an operation is subject to the control requi rements of the rule, there are VOC content limits. Coatings and inks have a VOC content limit of 300 gr ams VOC per liter material, minus water and exempt compounds, as applied; except certain flexographic inks. The VOC content limit for flexographic ink applie d on a non-porous substrate is the same as for other inks and coatings – 300 grams per liter minus water and exempt compounds. The VOC content limit for flexographic ink on a porous substrate is 225 grams per liter minus water and exempt compounds, as app lied. Adhesives and web-splicing adhesives have a limit of 150 grams per liter minus water and exempt compounds. The

VOC content of fountai n solution is limited to no great er than 80 grams per liter of material, or if a refrigerat ed chiller is used, no greater than 100 grams per liter of

material. Matte finish and metallic inks have VOC content limits, however, the limits apply only at facilities with potential to emit and actual emissions not more than ten tons per year of VOCs. In addition to specific VOC content limit s, the operator has a limit on the total quantity of matte finish and metallic c oating used each day and each year. If a source does not meet the daily/annual c oatings usage or total facility emission requirements for matte finish and metallic coatings, the general coating VOC content limit of 300 gram per liter (less water and ex empt compounds) applies to these coatings.

In place of using compliant materials, an operator may utilize a VOC control system. The overall (capture and) control efficiency mu st be at least 85% for publication gravure and 75% for all other graphic arts operations . An approved emission control system must reduce emissions to a level equal to or lower than that which would have been achieved through use of compliant or meet s the applicable overall control efficiency limits, whichever results in lower emissions.

Except as noted in the exempt ion section, a person is not allowed to sell or specify a graphic arts material with VOC content greater than the VOC content in the rule within
the South Coast AQMD boundaries.

District Rule 4607 mirrors the VOC content lim its in South Coast AQMD Rule 1130 with a few exceptions – the use metallic inks/matte finish inks in flexo printing. The VOC

content limits for matte finish and metallic inks in Rule 4607 apply regardless of the size of the facility. In contras t, the South Coast rule applies onl y to facilities that are not major sources for VOC. In bot h rules, use of these specialt y inks is limited on a per-day and per-year basis. District Rule 4607 also has an even lower VOC content for flexo

metallic ink and matte finish inks for facilities that emit at least ten tons per year of

VOCs.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-224 C. South Coast AQMD Rule 1130.1 (Screen Printing)

This rule applies to persons performing screen printing operati ons or who sell, distribute, or require the use of screen pr inting materials in the South Coast AQMD. South Coast AQMD Rule 1130.1 divides screen-pr inting operations into several special groups as well as dividing by substrate. The VOC content lim its range between 400 and 850 grams VOC per liter, less water and le ss exempt compounds, as applied. The total usage of high-VOC serigraph inks cannot exceed 10 percent of the total usage of screen printing materials applied on all serigr aphs at a facility, on a monthly basis, unless an approved emission control system is used to reduce emissions from highVOC serigraph inks by an equivalent or great er level to that which would have been achieved by the use of an ink containi ng 400 grams VOC per liter (less water and exempt compounds).

In lieu of complying with the VOC content limits for graphic arts material, an operator may install and operate a VOC emission control system. If an operator chooses to

utilize a VOC emission control system, the control device must destroy at least 95% of the collected vapors and the total emissions from the operation must not exceed the

amount of VOC that woul d have been emitted if the operator had used compliant material. Except as noted in the exempt ions, a person cannot s pecify that an operator

use of a material that has a higher VOC content than in the rule nor can a person sell or distribute high-VOC material within the South Coast AQMD.

District Rule 4607 VOC content limits for screen printing operations are equal to or less

than the VOC content limits in South Coast AQMD Rule 1130.1. District Rule 4607

limits the VOC content of a ll screen printing inks and coatings to 400 grams per liter. Adhesives have a limit of 150 grams per liter and resists have a limit of 600 grams per

liter. The limits are for the material as applied, less water and exempt compounds. The South Coast rule allows higher VOC content for coatings used in certain specialty markets. District Rule 4607 has a specific overall capture and control efficiency for VOC emission control systems as well as limiti ng total emissions. If an operator must meet both conditions, it is possible that the emissions fr om the process would be less than if the operator had used comp liant coatings to meet t he rule requirements. The South Coast AQMD rule does not have a spec ific minimum overall capture and control efficiency, although the rule does require 95% destruction of the vapors collected.

D. South Coast AQMD Rule 1171 (Solvent Cleaning Operations)

South Coast AQMD has a separate rule for all so lvent cleaning. This rule applies to all persons who use solvent materials in solv ent cleaning operations during the production, repair, maintenance, or servicing of parts, products, tools, machinery, equipment, or general work areas; all persons who store and dispose of these materials used in solvent cleaning operations; and all solvent suppliers who supply, sell, or offer for sale solvent cleaning materials for use in solvent cleaning operations. For this analysis, the focus will be on those cleaning operations performed by South Coast sources that would be subject to District Rule 4607 if they were located within the District’s

boundaries.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-225 In South Coast Rule 1171, the VOC content limits applicable to sources similar to District Rule 4607 depend on the equipment to be cleaned and range from 25 grams per liter to 100 grams per liter. In lieu of complyin g with the VOC content limits, operators may utilize an approved VOC emission control system in association with the solvent-cleaning operation. For graphic arts and screen printi ng, the collection portion of the control system must collect at least 70% of the emissions generated and the control portion of the system must reduce em issions fro the emission collection system by at least 95%. Solvents and cleaning cl oths and paper towels should be stored in closed, non-absorbent, non- leaking containers.

South Coast AQMD Rule 1171 does allow cert ain flexographic operations a slightly higher VOC content for cleaning materials co mpared to District Rule 4607. The VOC content limits, the control r equirements, and the work practices in South Coast Rule 1171 are essentially identical to District Rule 4607 for graphic arts operations because the solvent cleaning portion of Rule 4607 wa s recently amended to upgrade the rule to reflect best available control technology.

E. Bay Area AQMD Regulati on 8 Rule 4 (General So lvent and Surface Coating Operations)

The purpose of this Rule is to limit emissi ons of VOCs from the use of solvents and surface coatings in any operatio n other than those specified by other rules of Regulation 8. The provisions of this Rule apply to operations like model ma king, printed circuit board manufacturing and assembly, electrical and electronic component manufacturing, surface coating of test panels, training facili ties where the application of coating is for training purposes, stencil coatings, low usage coating activities exempt from other Regulation 8 Rules, coatings specifically exempt from other Regulation 8 Rules or solvent usage not specified by other Regulation 8 Rule s. Operations that are subject to the requirements of other rules in Regul ation 8 are exempt from this rule.

If an operation is subject to Regulation 8 Rule 4, the operator c an comply by meeting

one of the followin g requirements:

o Emit no more than 5 tons VO C per year from any source;

o Control emissions with an approved emi ssion control device with an overall capture and control efficiency of 85%. If the control device is an incinerator, the VOC destruction efficiency mu st be at least 90%; or

o The coating operation uses coating with VOC content of 420 gr ams per liter, as applied.

To minimize solvent evaporative losses, the Bay Area rule requires work practices in

addition to VOC content limit s. Solvents used in the cleanup of spray equipment is

limited to VOC content of 50 grams per liter unless the at omizing air for the equipment is turned off or a spray gun washer is used. Solvents used for surface preparation are

limited to a VOC content of 50 grams per liter. An operator may forego the work practices or use higher VOC-content materi al if the emissions from the cleaningSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-226 operations are controlled by an approved emission control system with overall capture and control efficiency of 85%.

Bay Area AQMD Regulation 8 Rule 4 is a rule fo r “other” coating sources. As such, it is difficult to compare the Bay Area AQMD rule directly with District Rule 4607. The Bay Area AQMD coating VOC content limit is higher than all coatings in District Rule 4607 except metallic inks, matte finish inks, and screen-printing re sists. The Bay Area AQMD rule’s overall capture and control efficiency is generally higher than sources are required

to meet in current District Rule 4607. Howe ver, the sources that would be subject to Bay Area AQMD’s rule would be small source s and most likely meet the requirements of the rule through total emissions from the facility. District Rule 4607 does not exempt small facilities from the control requirements of the rule, therefore, District Rule 4607 may be more stringent than Bay Area Regula tion 8 Rule 4 for certain sources.

F. Bay Area AQMD Regulati on 8 Rule 12 (Paper, Fabric, and Film Coating)

Bay Area AQMD Regulation 8 Rule 12 limits VOC emissions from the application of coatings and adhesives to paper, fabric or fi lms. The rule does not apply to operations subject to Bay Area AQMD Regulation 8 Rule 20. The rule doesn’t apply to any coating line which emits less than 6.5 kg (14.3 pounds ) per day. Coatings and adhesive are

limited to a VOC content of less than 265 grams per liter of coating applied, excluding water. In lieu of meeting the VOC cont ent limit, the operator may use an approved emission control system that reduces VOC emi ssions to less than 120 grams per liter of coating applied, excluding water. This equates to approximately 55% overall capture and control efficiency for operators choosing to utilize a VOC emission control system. The Bay Area rule does not have a specific VOC content limit for cleaning materials used for surface preparation and cleanup. Inst ead, there are work practices that limit VOC emissions in the storage and mixing of VO C-containing materials as well as during solvent cleaning operations.

District Rule 4607 has the same VOC content limits for the coating and adhesive as the Bay Area rule. Compared to the Bay Area AQMD’s 55% overall control efficiency, current District Rule 4607 has a higher overall control efficiency of 90%. District Rule 4607 also incorporates the same work practi ce as the Bay Area AQMD rule, as well as a few additional work practices related to cleaning with solvents. For example, the District rule includes allowing only certai n application techniques for applying the cleaning solvent to minimize evaporations – the Bay Area AQMD does not. In addition to work practices, District Rule 4607 has specific VOC content limits for cleaning materials. An operator can choose to use hi gh-VOC content material for cleaning if the operator has a VOC emission control system t hat controls emissions from the cleaning operation by at least 90%.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-227 G. Bay Area AQMD Regulation 8 Rule 20 (Graphic Arts Printing and Coating Operations)

The purpose of this Rule is to limit the VO C emissions from graphic arts operations and graphic arts lines. Any facility which emit s less than 34 kilograms (175 pounds) of VOC in any month from graphic arts operations is exempt from the rule , except for recordkeeping. Laboratory and experimental operat ions are also exempt from control requirements.

For flexography (flexo), lithography, gravur e, and letterpress, the VOC content of coatings and web-splicing adhesive is limit ed to 300 grams per liter less water as applied. Other adhesives are limited to a VOC content limit of 150 gr ams per liter, less water as applied. For inks other than flexo ink on a porous substrate, the VOC content limit is 300 grams per liter less water and ex empt solvents, as applied. Flexo ink applied to a porous substrate has a VOC content limit of 225 grams per liter (less water and exempt solvents). Fountain solution is lim ited to 8% VOC. Screen printing inks and coatings are limited to 400 gram s per liter less water, as applied. Adhesives used in screen printing operations are lim ited to 150 grams per liter, less water, as applied.

Solvents used for claning are limited to a VOC content of 25 grams per liter to 100 grams per liter, depending on the printing tec hnology and process. In addition to the cleaning product requirements, this rule also has work practices to minimize VOC

emissions.

In lieu of complying with the VOC content limits for materials, an operator may install and operate a VOC emission cont rol system. The minimum overall capture and control efficiency is 75% on a mass basis.

For most printing/coating operations, Bay Area AQMD Regulation 8 Rule 20 has VOC

content limits that are identical to District Rule 4607. For one screen printing material – screen resists - the Bay Area AQMD rule is silent. District Rule 4607 has a VOC content limit of 600 grams per liter, less wa ter and exempt compounds, as applied. For emission control systems, the Bay Area rule has a lower required control efficiency for certain printing technologies.

The Bay Area AQMD rule and District Rule 4607 incorporate the same VOC content limits for cleaning solvents. District Rule 4607 also incorporates the same work practice as the Bay Area AQMD rule, as well as a few additional work pr actices related to cleaning with solvents. For example, the District rule includes allowing only certain application techniques for applying the cleaning solvent to minimize evaporations – the Bay Area AQMD does not.

H. Sacramento Metropolitan AQMD Rule 450 (Graphic Arts Operations)

Sac Metro AQMD Rule 450 applies to graphic ar ts operations and to any screen printing operation at any stationary sour ce regardless of the substrat e. The requirement of thisSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-228 rule, including the VOC limits in Section 301.1 for adhesives, shall also apply to adhesives used by graphic arts operations unless exempt. The cleaning and storage requirements in Section 302 shall apply to a ll graphic arts operations at any stationary source including those exempt pursuant to Section 110 of th is rule. The requirements of Sac Metro Rule 440 (Organic Solvents), does not apply to operations subject to this

rule.

The VOC content requirements for inks, coat ings, and adhesives does not apply to any graphic arts operation at a stationary source which either has actual VOC emissions of less than or equal to 60 pounds per month from all graphic arts operations and cleaning materials; or receives a pe rmit that limits the potential to emit, to not more than 175 pounds of VOC per month from all graphic ar ts operations and cleaning materials.

Sac Metro AQMD Rule 450 has the following exemptions:

o Gravure printing operations.

o Business and personal printers.

o Prepress operations, including film photo processors and plate photo processors.

o Aerosol adhesives used by screen printe rs if the adhesives comply with Sac Metro Rule 460 (Adhesives and Sealants)

o Aerosol adhesives used in graphic arts operations provided that the total VOC emissions from the facility ar e less than 660 pounds per month

VOC content limits fo r graphic arts operations that are not screen printing operations are 300 grams VOC per liter for coati ngs and inks and 150 gr ams per liter for

adhesives. The VOC content limits are less water and less exempt compounds. The

VOC content of fountai n solution is limited to no great er than 80 grams per liter of material, or if a refrigerat ed chiller is used, no greater than 100 grams per liter of

material. If the fountain solution has a dens ity of 1,000 grams per liter, the 80 grams per liter limit represents about 8% by volume and the 100 grams per liter limit represents about 10% by volume. This rule also mandates a specific temperature for

the chilled fountain solution.

For solvent cleaning, Sac Metro AQMD limits composite partial pressure in addition to VOC content for certain cleaning activities and in lieu of VOC content for other cleaning activities. The range of VOC content is 72 to 810 grams per liter. Composite partial pressure ranges from 3 to 33 millimeters mercury at 20 degrees centigrade. To minimize solvent evaporation, operators are required to cove r containers of VOCcontaining material and to place material in covered containers. Additionally, the total amount of solvent used for lithographic and le tter press printing – other cleaning cannot
exceed 15% of the total m onthly usage of blanket wash cleaning and roller wash cleaning.

In lieu of complying with the VOC content limits for printing materials or for cleaning operations, an operator may use an approved emission control system with capture efficiency of at least 70% and a control device efficiency of at least 95%. This translates to an overall capture and control efficiency of 67%.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-229 A person cannot supply, sell, solicit, or offer for sale, any noncompliant material for use in graphic arts operations. The prohibition applies to any graphi c arts material which will be applied at any physical location within the District.

District Rule 4607 mirrors Sac Metro Rule 450 for the VOC content of non-screen printing inks, coatings, and adhesives. Thes e VOC content limits apply to gravure printing operation, which the Sac Metro rule exempts. Dis trict rule limits all fountain

solutions to a VOC content of 8%. The Sa c Metro rule allows a higher VOC content limit for refrigerated/chilled f ountain solution. Screen printi ng inks and coatings in the Sac Metro AQMD rule range from 300 to 800 grams per liter, as applied less water and exempt compounds. District Rule 4607 has a VOC content limit of 400 grams per liter for inks and coatings and 150 grams per liter for adhesives. Sac Metro rule has one screen printing coating that is lower than District Rule 4607 – web -ed wallpaper. District staff is not aware that such operations exist within the District’s boundaries. For one screen printing material – screen resists - the Sac Metro AQMD rule is silent –

District Rule 4607 has a VOC content limit of 600 grams per liter, less water and exempt compounds, as applied for this material.

Since the Sac Metro AQMD rule allows compos ite partial pressure as an alternative to VOC content for certain cleaning solvents, it is not possible to compare the solvent cleaning material limits directly. Low vaporpressure material may or may not be highVOC content. In general, however, District Rule 4607 has lower numeric limits for VOC content – composite vapor pressure is not us ed. For solvent cleaning, current District

Rule 4607 has a VOC content limit range of 25 to 100 gram s VOC per liter material beginning in January 2010. This range is lower than the numeric limits in the Sac Metro AQMD rule. District Rule 4607 also incorpor ates the same work practices as the Sac
Metro AQMD rule to minimize solvent evaporation during cl eaning operations.

I. Ventura County APCD 74.3 (Paper, Fa bric, and Film Coating Operations)

The provisions of this rule apply to any application process involving the coating of paper, fabric or film. O perators have three ways to comply with the rule:

o Use coating material, as applied, with less than 265 grams ROC per liter coating less water and exempt compounds.

o Emissions from the operation are less than 120 grams per liter coating applied, less water and exempt compounds, on a 24-hour average basis.

o Install and utilize an emission control system that reduces emissions by a combined capture and destruction efficiency of at least 90%.

If the coating applied contains more than 1200 grams of ROC per liter of coating applied, less water and less exempt solvent, then, in addition to the emission control system, emissions are limited to 120 grams of ROC per liter of coating applied, less water and exempt solvent, using a rolling 24 hour average.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-230 Solvent evaporation is minimized through requi ring covered, non-leaking containers for solvent-containing materials – a work practice . Solvents used in clean-up are limited to 200 grams ROC per liter materi al or the operator Install and utilize an emission control system that reduces emissions by a combi ned capture and destruction efficiency of at

least 90%.

Current District Rule 4607 VOC content limits for inks and coatings in paper and fabric are identical to the Ventura County APCD VOC content limits. Operators do not have the option of averaging over a 24-hour period to comply with Rule 4607. If an operator uses a VOC emission control system to comply with the rule limits, there is a specific overall capture and control efficiency of at least 86%. Since District Rule 4607 is undergoing amendment, the proposed efficien cy will be increased to 90%, which matches the Ventura County APCD combined capture and destruction efficiency.

For solvent cleaning, current District Rule 4607 has a VOC content limit range of 25 to 100 grams VOC per liter materi al beginning in January 2010. This range is significantly lower than the 200 gram per liter limit in t he Ventura County APCD rule. As with the Ventura County APCD rule, operators can use higher VOC content material for cleaning if the operation is within an approved VOC emission contro l system with an overall capture and control efficiency of at least 86% . This control efficiency will be increased to 90% as part of a rule am endment project. District Rule 4607 also incorporates the same work practice as the Ventura County APCD rule, as well as a few additional work practices related to cleaning with solvents designed to minimize solvent evaporation during cleaning. The public hearing to adopt the amendments to Rule 4607 is expected

in December 2008.

J. Ventura County APCD Rule 74.19 (Graphic Arts)

Ventura County APCD rule applies to any person who applies any ink, coating, adhesive, fountain solution, or solvent c ontaining Reactive Organic Compounds (ROC) as part of a graphic arts operation. The ru le also applies to any person in Ventura County who manufactures any ink, coating, adhesive, fountain solution, or solvent containing VOC sold for use in a graphic ar ts operation in Ventura County. The ROC

content limits of Ventura C ounty APCD Rule 74.19 do not apply to any stationary source that emits less than 200 pounds of ROC per year from gr aphic arts operations.

For sources subject to the Ventura County APCD rule requirements, inks and coatings

are limited to a ROC content of 300 grams per liter and adhes ives to 150 grams per liter – both limits are less water and exempt compounds. Flexographic inks on porous

substrates have a ROC cont ent limit of 225 grams per liter less water and exempt compounds. If the material contains less t han 120 grams of solids per liter of material, the ink/coating/adhesive limits are the same, but determined as grams of ROC per liter of material – water and exempt compounds are not subtracted.

The ROC content of fountain solution is limited to no greater than 80 grams per liter of material, or if a refrigerat ed chiller is used, no greater than 100 grams per liter ofSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-231 material. If the fountain solution has a dens ity of 1,000 grams per liter, the 80 grams per liter limit represents about 8% by volume and the 100 grams per liter limit represents about 10% by volume.

For solvent cleaning, Ventura County APCD limits composite partial pressure in addition to ROC content for certain cleaning activiti es and in lieu of ROC content for other cleaning activities. The range of ROC content is 50 to 950 grams per liter. Composite partial pressure ranges from 3 to 33 millim eters mercury at 20 degrees centigrade. Operators are prohibited fr om using methylene chloride for cleaning purposes. Methylene chloride is usually considered an exempt compound.

District Rule 4607 mirrors the Ventura C ounty APCD rule for inks, coatings, and adhesives for graphic arts operations. Sinc e the Ventura County APCD rule allows composite partial pressure as an alter native to VOC content for certain cleaning solvents, it is not possible to compare the solvent cleaning ma terial limits directly. Low vapor pressure material may or may not be have high-VOC content. In general, however, District Rule 4607 has lower numer ic limits for VOC content – composite vapor pressure is not used. For solvent cl eaning, current Distric t Rule 4607 has a VOC content limit range of 25 to 100 grams VOC per liter material beginning in January 2010. This range is lower than the numeric limits in the Ventura County APCD rule. As with the Ventura County APCD rule, operators can use higher VOC content material for cleaning if the operation is within an approved VOC emissi on control system with an overall capture and control efficiency of at least 86%. This control efficiency will be increased to 90% as part of a rule amendm ent project. Distr ict Rule 4607 also incorporates the same work practice as the Ventura County APCD rule, as well as a few additional work practices related to cleaning with solvents designed to minimize solvent evaporation during cleaning. The public hear ing to adopt the amendments to Rule 4607 is expected in December 2008.

K. Ventura County APCD Rule 74.19-1 (Screen Printing Operations)

Ventura County APCD Rule 74.19-1 applies to any person who uses any ink, coating, adhesive, resist, or solvent containing RO C (Reactive Organic Compounds) in a screen printing operation. The rule also applies to any person in the District who manufactures, specifies the use of, sells, or offers for sale any ink, coating, adhesive, resist, or solvent containing ROC for use in a screen printing operation in the Ventura County APCD.

The ROC content limits of Ventura Count y AQCD Rule 74.19-1 do not apply to any stationary source that emits less than 200 pounds of ROC per year from screen printing operations. Emissions from aerosol products, cold cleaners, vapor degreasers, graphic arts operations used exclusively for res earch, classroom instruction in schools, laboratory analysis, or determination of product quality and commercial acceptance are

not included in the exem ption determination.

In addition to the above exemption, screen pr inting operations used exclusively for research, classroom instruction in schools, laboratory analysis, or determination ofSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-232 product quality and commercial acceptance ar e exempt, provided that total ROC emissions are less than 200 pounds per year. The production of electronic circuits is specifically exempt from t he ROC limits of the rule. The adhesive ROC limit does not apply to aerosol platen adhesive if the aeros ol platen adhesive usage is 150 ounces per

month or less.

Screen printing inks, coatings and adhesives are limited to a ROC content of 400 grams per liter; metallic inks and resists are lim ited to 600 grams per liter; and extreme performance inks and coatings are limited to 800 grams per liter; water slide decals and ceramic decals are limited to 800 grams per liter. These limits are less water and exempt compounds. In lieu of meeting the ROC limits, an operator may install and operate an emission control system with an ov erall efficiency of at least 75%. Additionally, all drying ovens must be vented to the control system and the incinerator must be continuously monitored.

No one is allowed to sell distribute, or require any other person to use any ROCcontaining material subject to the provisions of this rule which, when thinned or reduced according to the manufacturer's recommendati on for application and use, does not meet the applicable ROC limits required by this rule for the specific applic ation, except if the person operates an approved emission control syst em or the facility emissions are less than 200 pounds of ROC per year.

For solvent cleaning, Ventura County APCD limits composite partial pressure in addition to ROC content for certain cleaning activiti es and in lieu of ROC content for other cleaning activities. The range of ROC content is 200 to 1070 grams per liter. Composite partial pressure ranges from 5 to 25 millimeters me rcury at 20 degrees centigrade.

District Rule 4607 limits the VO C content of screen printing inks and coatings to 400 grams per liter. Adhesives have a limit of 150 grams per liter and re sists have a limit of 600 grams per liter. T he limits are for the material as applied, less water and exempt compounds. The Ventura County rule allows higher VOC content for coatings used in certain specialty markets. As with the Ventura County APCD ru le, operators can use higher VOC content material for coating, of printing if the oper ation is within an approved VOC emission control system with an ov erall capture and control efficiency of at least 67%. This control efficiency wil l be increased to 75% as part of a rule amendment project.

Since the Ventura County APCD rule allo ws composite partial pressure as an

alternative to VOC content for certain cleani ng solvents, it is not possible to compare the solvent cleaning material limits directly. Low vapor pressure material may or may not be high-VOC content. In general, howev er, District Rule 4607 has lower numeric limits for VOC content – composite vapor pre ssure is not used. For solvent cleaning,

current District Rule 4607 has a VOC content limit range of 25 to 100 grams VOC per liter material beginning in January 2010. This range is lower than the numeric limits in the Ventura County APCD rule. District Rule 4607 also incorporates the same workSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-233 practices as the Ventura County APCD rule to minimize solvent evaporation during cleaning. Operators ar e also allowed to use high-VOC c ontent material if the cleaning operation is controlled with a VOC emission control system. Th is allows operators operational flexibilit y without increasing VOC emissi ons. The Ventura County APCD rule is silent as to whether operators have this option. The public hearing to adopt the

amendments to Rule 4607 is expected in December 2008.

Conclusion

After careful evaluation of federal rules or regulations covering emissions from this source category as well as prohibitory rule s in other California nonattainment areas,

District staff concludes that District Rule 4607 satisfies RACT for graphic arts operations as well as for paper, film, foil and fabric.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-234 

### Rule 4610 – Glass Coating Operations

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

VOC 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01
(Source: District 2007 Ozone Plan)

District Rule 4610 Description

The purpose of this rule is to limit the em issions of volatile organic compounds (VOCs) from the coating of glass products.

The following categories of operations are exem pt from the rule requirements: (a) touchup and repair coatings; (b) stencil coatings applied on clear or tr ansparent substrates; (c) manufacturer performance testing of c oatings; (d) aerosol coating products.

The rule requires that the VO C contents of coati ngs applied to glass shall not exceed the following limits: (a) single-component gen eral coating - 2.3 lb/gallon; (b) dualcomponent general coating - 3.5 lb/gallon; (c ) mirror backing applied by curtain coating - 4.2 lb/gallon; (d) mirror backing applied by roll coating - 3.6 lb/gallon; (e) optical coatings - 6.7 lb/gallon; (f) electricity-dissi pating and shock-free coatin gs - 3.0 lb/gallon; and (g) metallic coatings - 3.5 lb/gallon.

The rule restricts coating application methods to electrostatic application, curtain/flow coater, roll coater, dip coat er, hand application methods, and high-volume, low-pressure (HVLP) spray.

The rule also provides an option to use an emissions control device in lieu of complying

with VOC content limits and c oating application methods. Control devices used must have a capture efficiency of at least 90% and a destruction efficiency of at least 95%.

Records of coating operations must be mainta ined and retained for at least five years. Operators opting to use an emissions cont rol device must maintain records of parameters needed to demonstrate proper operation of the control device.

How does District Rule 4610 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

There is no CTG for this category.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-235 B. EPA – Alternative Control Technology (ACT)

There is no ACT for this category.

C. Standards of Performance fo r New Stationary Sources (NSPS)

There is no NSPS for this category.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

There is no NESHAP or MACT for this category.

How does District Rule 4610 compare to rules in other air districts?

District staff compared emission limits, opti onal control requirements, and work practice standards in District Rule 4610 to comparable requirements in rules from the following

California nonattainment areas:

• South Coast AQMD Rule 1145 (amended 12/3/2004)

• Bay Area AQMD Regulation 8 Rule 4 (adopted 10/16/2002)

• Sacramento Metro AQMD (no applicable rule)

• Ventura County APCD (no applicable rule)

A. South Coast AQMD Rule 1145

The purpose of South Coast AQMD rule 1145, Plastic, Rubber, Leather, and Glass Coatings , is to reduce volatile organic compounds (VOC) emissions from the application of coatings to any plastic, rubber, leather, or glass products.

The rule exempts the follo wing categories of operations: (a) touch-up and repair coatings; (b) stencil coatings applied on clear or transparent substrates; (c) manufacturer performance testing of coatings; (d) aerosol coating products, (e) clear or translucent coatings, (f) any individual c oating category used in volumes less than 50 gallons in any one year, provided that the total usage of all such coatings does not exceed 200 gallons per year per facility, (g ) mask coatings less than 0.5 millimeter thick (dried) if the area coated is less than 25 squa re inches, (h) mask coatings that are less than 0.5 millimeter thick (dried) and/or the area coated is more than 25 square inches, provided that a written petition that demonstrates compliant c oatings are not available is submitted to and written approval is grant ed by the Executive Officer, (i) EMI/RFI shielding coatings, (j) Heparin-benzalkon ium chloride (HBAC)-containing coatings applied to medical devices, pr ovided that the total usage of all such coatings does not exceed 100 gallons per year, per facility, and (k) airbrush operations using 5 gallons or less per year are exempt from application method restrictions.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-236 The rule stipulates that the VOC contents of coatings appli ed to glass shall not exceed the following limits: (a) single-component gen eral coating – 1.0 lb/gallon; (b) dualcomponent general coating – 1.0 lb/gallon; (c) mirror backing applied by curtain coating - 4.2 lb/gallon; (d) mirror backing applied by roll coating - 2.6 lb/gallon; (e) optical coatings - 0.4 lb/gallon; (f) electricity-dissi pating and shock-free coatin gs - 3.0 lb/gallon; and (g) metallic coatings - 3.5 lb/gallon.

The rule restricts coating application methods to electrostatic application, curtain/flow coater, roll coater, dip coat er, hand application methods, and high-volume, low-pressure (HVLP) spray.

The rule also provides an option to use an emissions control device in lieu of complying

with VOC content limits and c oating application methods. Control devices used must have a capture efficiency of at least 90% and a destruction efficiency of at least 95%.

The rule requires maintenance of daily or m onthly coatings usage activities. Records must be retained for at least two years.

South Coast AQMD Rule 1145 is more st ringent than District Rule 4610 in the requirements for VOC contents of glass coat ings. Whereas the two rules have similar

VOC content limits for three ca tegories of coatings (flow/ curtain-coated mirror backing, electricity dissipating and metallic), South Coast AQMD Rule 1145 has more stringent

VOC content limits for four categories (one- and two-component general coatings, rolled-on mirror backing, and optical).

There is no significant difference betw een the two rules under the exemptions; application methods and alternative emissi ons control methods. South Coast AQMD Rule 1145 includes a longer list of exemptio ns, but this is probably only because it covers coatings for plastic, rubber, leather and glass while District Rule 4610 addresses only glass coatings.

District Rule 4610 is more stringent in t he record keeping requirement because it requires records to be reta ined for five years, while South Coast AQMD Rule 1145 requires only a two-year retention period.

With the exception of the VOC content limits, the two rules ar e only slightly different or similar in all comparison categories. Sout h Coast AQMD Rule 1145 has more stringent VOC content limits, and is therefore more stringent than District Rule 4610 overall.

B. Bay Area AQMD Re gulation 8 Rule 4

The purpose of Bay Area AQMD Regulation 8 Rule 4, General Solvent and Surface Coating Operations , is to limit emissions of volatile organic compounds from the use of solvents and surface coatings in operations other than thos e covered by other rules ofSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-237 Regulation 8. Since it is not covered by any other rule under Regulation 8, glass coating

falls under rule 4.

Exemptions are provided for aerosol can coat ings. No other exemptions pertinent to glass coating are s pecifically listed.

The rule provides three options for compliance: (a) limit total facility VOC emissions to 5 tons per years; or (b) use a control device with a VOC destruction efficiency of at least 90%, or (c): use coatings with a VOC limit of 3.5 lb/gallon.

The rule requires records of coating activiti es to be maintained and retained for at least two years.

As far as glass coating is concerned, Bay Area AQMD Regulation 8 Rule 4 provides two avenues of compliance that are less stringent than District Rule 4610: (a) facilities are provided an option to use any coatings, r egardless of VOC content, as long as total

annual VOC emissions are limited to 5 tons. Facilities of comparable size under District Rule 4610 would still have to comply with VOC content limits or use control devices. (b) facilities opting to use a control device onl y need to achieve a 90% control efficiency, compared to 95% required by District Rule 4610.

The VOC content limit of 3.5 lb /gallon, which is the third compliance option provided by Bay Area AQMD Regulation 8 Rule 4, is an av erage value that is fairly comparable to the category-specific VOC limit s of District Rule 4610. It is as stringent as two of the Rule 4610 categories, less st ringent than another two, and more stringent than a further three categories.

In addition, District Rule 4610 has a more stringent record keeping requirement because it requires records to be retained fo r five years, compar ed to the two-year retention period required by Bay Ar ea AQMD Regulation 8 Rule 4.

District Rule 4610 is therefore more stri ngent than Bay Area AQMD Regulation 8 Rule

4.

Conclusion

After evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, District staf f concludes that District Rule 4610 meets RACT for Glass Coating Operations.

The rule is more stringent overall than the equivalent Bay Area AQMD rule, but not as stringent overall as the equivalent South Coast AQMD rule. However, since South Coast AQMD rules generally exceed RACT r equirements, District Rule 4610 still meets RACT even though it is not as stringent as the corresponding South Coast AQMD rule.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-238



### Rule 4612 - Motor Vehicle and Mobile Equipment Coating Operations

Emissions Inventory: Tons per day - summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 0 0 0 0 0 0 0 0

VOC 2.05 2.10 1.54 1. 55 1.57 3.04 1.61 1.63
(Source: District 2007 Ozone Plan)

District Rule 4612 Description

District Rule 4612, recently amended on Septem ber 20, 2007, controls VOC emissions

from motor vehicle and mob ile equipment coating operati ons, and from organic solvent cleaning, storage and disposal associ ated with the coating operations.

This source category in cludes operations that apply, supply, sell, offers for sa le, or solicits the application of VOC-containing coatings used in the finishin g or refinishing of Vehicles and Equipment, and their parts and components. This also includes the organic solvent cleaning, and the storage and disposal of all solvents and waste solvent materials associated with such coating operations.

District Rule 4612 limits the VOC content limit of coatings us ed to coat motor vehicles and mobile equipment. In lieu of complyi ng with VOC content lim its, operators may operate an APCO-approved VOC emission contro l system. District Rule 4612 replaced District Rule 4602 on January 1, 2009. Distric t Rule 4612 incorporates all of the

elements of the California Air Resources Bo ard’s (ARB’s) Suggested Control Measures (SCM) for this source category.

How does District Rule 4612 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

1. EPA-450/2-76-028 1976/11 Control of Volatile Organic Emissions from Existing Stationary Sources - Volume I: Control Methods for Surface Coating Operations

The CTG applies to surface coating operations located in marginal, moderate, serious

or severe ozone nonattainment areas that has t he potential to emit greater than or equal to 25 tons/year of VOC, and equal to great er than 10 tons/year of VOC for extreme

ozone nonattainment areas. This CTG will not be compared to District Rule 4612 since the source category (Motor Vehicle and Mobile Equipment Coating) is addressed in

another CTG: EPA-450/2-77-008 1977/05 Control of Volatile Or ganic Emissions from Existing Stationary Sources – Volume II: Su rface Coating of C ans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks (See discussion below).San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-239 2. EPA-450/2-77-008 1977/05 Control of Volatile Organic Emissions from Existing Stationary Sources - Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks

The CTG applies to motor vehicle surface coating oper ations located in marginal, moderate, serious or severe ozone nonattainment areas that has the potential to emit greater than or equal to 25 tons/year of VO C, and equal to greater than 10 tons/year of

VOC for extreme ozone nonattainment areas.

The table below identifies the CTG require ments and how Rule 4612 compares to the automobile and light-duty truc k coating requirements.

Coating Type CTG (lb/gal) 4612 (lb/gal)

Prime 2.8 2.1 Topcoat 4.2 2.1 Final Repair Topcoat 5.5 2.1

As shown in the table above, District Rule 4612 is more stringent than all CTG limits.

3. EPA-453/R-08-006 2008/09 Control Techniques Guidelines for Automobile and Light-Duty Truck Assembly Coatings

The CTG applies to vehicle assembly coating operations located in marginal, moderate,

serious or severe ozone nonattainment areas that has the potential to emit greater than or equal to 25 tons/year of VOC, and equal to greater th an 10 tons/year of VOC for extreme ozone nonattainment areas. There are no vehicle assembly plants in the District; therefore, this CTG will not be examined.

B. EPA - Alternative Control Technology (ACT)

EPA-453/R-94-017 1994/02 Alternative Control Techni ques Document - Surface Coating of Automotive/Transportati on and Business Machine Plastic Parts

The ACT applies to the coating of plastic parts for the automotive industry, business machines, and other miscellaneous plastic par ts. The ACT identifies an automotive coating work practice standards, VOC cont ent limits, application methods, and add-on

control efficiencies based on California Distric t rules as of 1994. Since SJVAPCD Rule 4612 is at least as stringent overall compared to other Districts (see analysis below in Section III), a detailed evaluation of the ACT is not necessary.

C. Standards of Performance fo r New Stationary Sources (NSPS)

40 CFR 60 Subpart MM (Standards of Perfor mance for Automobile and Light Dusty Truck Surface Coating Operations) app lies to assembly plant coatings.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-240 There are no vehicle assembly plants in the District; therefore, th is NSPS will not be

examined.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

NESHAPs and MACTs are requirements contai ned in 40 Code of Federal Regulations (CFR) Part 61 and 40 CFR Part 63. Since EPA has delegated the authority to implement NESHAP requirements to the Dis trict, NESHAPs and MACTs promulgated by EPA are usually incorporated by reference into District Rule 4002 (National Emission

Standards for Hazardous Air Pollu tants). It is impor tant to mention that the District implements NESHAPs and MACTs by incor porating the emission standards as

conditions of the Permits to Operate issued to affe cted sources.

40 CFR 63 Subpart IIII (National Emission St andards for HAPs: Surface Coating of Automobiles and Light-Duty Trucks)

The requirements in this subpart are not dire ctly comparable to the District Rule 4612

limits. The NESHAP HAP emissi on limits which are expressed in terms of % HAP, HAP emission concentration, and mass (kg) of HAP per mass (kg) of solids are not directly comparable to the coatings VOC limit which is expressed in terms of grams (or lb) of VOC per liter (or gallons) of coatings, less water and exempt compounds, as applied. In addition, some HAPs may be exempt VOCs, and some VOCs may be HAPs; therefore,

there is no direct correlati on between the NESHAP limits ve rsus District Rule 4612 VOC

limits.

How does District Rule 4612 comp are with state regulations?

A. California Air Resources Board (C ARB) Suggested Contro l Measures (SCM)

1. SCM for Automotive Coatings

The table below identifies t he requirements of the SCM:

Rule Comparisons g-VOC/L (lb-VOC/gal)

Coating Category SCM SJ Valley (Rule 4612)

Adhesion Promoter Plastic Parts 540 (4.5) 540 (4.5)

Camouflage 340 (2.8)

Clear Coating 250 (2.1) 250 (2.1)

Color Coating 420 (3.5) 420 (3.5)

Pretreatment 660 (5.5) 660 (5.5)

Precoat 660 (5.5)

Primer 250 (2.1) 250 (2.1)San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-241 Primer Sealer 250 (2.1) 250 (2.1)

Primer Surfacer 250 (2.1)

Single Stage Coating (not primer or multicolor) 340 (2.8) 340 (2.8)

Topcoat - General 250 (2.1)

Topcoat - Metallic/Iridescent 420 (3.5)

Topcoat - Metallic/Iridescent (spot repair) 420 (3.5)

Topcoat - Multicolored 680 (5.7) 420 (3.5)

Topcoat - Multistage 340 (2.8)

Topcoat - Multistage (spot repair) 340 (2.8)

Water-Based Temporary Transit 250 (2.1)

Temporary Protective Coating 60 (0.5) 60 (0.5)

Truck Bed Liner 310 (2.6) 310 (2.6)

Underbody Coating 430 (3.6) 430 (3.6)

Uniform Finish Coating 540 (4.5) 540 (4.5)

Other 250 (2.1) 250 (2.1)

Application Methods SCM SJ Valley (Rule 4612)

Transfer Efficiency Minimum 65% 65%

Add-on Control Efficiency SCM SJ Valley (Rule 4612)

Overall Control 85% by wt 85% by wt and at least equiv to compliant coating

emissions

Solvents SCM SJ Valley (Rule 4612)

Product Cleaning (General) 25 25

Repair and Maintenance Cleaning 25 25

Cleaning of Application Equipment 25 25

As shown in the table above, the SCM does not contain any requirements more stringent than District Rule 4612. As such, District Rule 4612 is at least as stringent at the SCM.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-242 How does District Rule 4612 compare to rules in other air districts?

District staff compared District Rule 4612 with the rules of other California ozone nonattainment air districts’ rules (listed bel ow) auto coating operations. The results of the analysis are discussed below.

• South Coast Air Quality Management Distric t (SCAQMD) Rule 11 51 - Motor Vehicle and Mobile Equipment Non-Assembly Line Coating Operations (Amended December 2, 2005)

• Bay Area Air Quality Management District (BAAQMD) Regulation 8 Rule 45 - Motor Vehicle and Mobile Equipm ent Coating Operations (Amended January 6, 1999)

• Sacramento Metropolitan Air Quality M anagement District (SMAQMD) Rule 459 - Automotive, Truck and Heavy Equipm ent Refinishing Operations) (Amended October 2, 1997)

• Ventura County Air Polluti on Control District (VCPCD) Rule 74.18 - Motor Vehicle and Mobile Equipment Coating Oper ations (Amended September 10, 1996)

Rule Comparisons g-VOC/L (lb-VOC/gal)

Coating Category Bay Area (Rule 8- 45) South

Coast (Rule 1151) Sac Metro (Rule 459) Ventura (Rule 74.18) SJ Valley (Rule 4612)

Adhesion Promoter Plastic

Parts 540 (4.5)

Camouflage 420 (3.5) 420 (3.5) 420 (3.5) 340 (2.8)

Clear Coating 250 (2.1)

Color Coating 540 (4.5) 685 (5.7) 420 (3.5)

Pretreatment 780 (6.5) 750 (6.5) 780 (6.5) 780 (6.5) 660 (5.5)

Precoat 580 (4.8 ) 600 (5.0) 660 (5.5)

Primer 250 (2.1) 250 (2.1) 250 (2.1)

Primer Sealer 340 (2.8) 340 (2.8) 420 (3.5) 340 (2.8) 250 (2.1)

Primer Surfacer 250 (2.1) 250 (2.1) 250 (2.1) 250 (2.1)

Single Stage Coating (not primer or multicolor) 340 (2.8)

Topcoat - General 420 (3.5) 340 (2.8) 420 (3.5) 340 (2.8) 250 (2.1)

Topcoat - Metallic/Iridescent 520 (4.3) 340 (2.8) 520 (4.3) 520 (4.3) 420 (3.5)

Topcoat - Metallic/Iridescent (spot repair) 420 (3.5) 420 (3.5)

Topcoat - Multicolored 540 (4.5) 685 (5.7) 420 (3.5)

Topcoat - Multistage 340 (2.8) 540 (4.5) 340 (2.8) 340 (2.8)

Topcoat - Multistage (spot repair) 420 (3.5) 340 (2.8)

Water-Based Temporary

Transit 420 (3.5) 250 (2.1)San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-243

Temporary Protective Coating 60 (0.5) 60 (0.5) 60 (0.5)

Truck Bed Liner 310 (2.6)

Underbody Coating 540 (4.5) 430 (3.6)

Uniform Finish Coating 540 (4.5)

Other 250 (2.1)

Application Methods Bay Area (Rule 8- 45) South

Coast (Rule 1151) Sac Metro (Rule 459) Ventura (Rule 74.18) SJ Valley (Rule 4612)

LVLP Spray x

Transfer Efficiency Minimum 65% 65% APCO/EPA approved 65% 65%

Add-on Control Efficiency Bay Area (Rule 8- 45) South

Coast (Rule 1151) Sac Metro (Rule 459) Ventura (Rule 74.18) SJ Valley (Rule 4612)

Control 85%

Overall Control Equiv to compliant

coating

emissions Equiv to compliant

coating

emissions 85% 85% by

wt 85% by

wt and Equiv to compliant

coating

emissions

Solvents Bay Area (Rule 8- 45) South

Coast (Rule 1171)* Sac Metro (Rule 459) Ventura (Rule 74.18) SJ Valley (Rule 4612)

Product Cleaning (General) 72 (0.6) 25 72 (0.6) 200 25

Repair and Maintenance Cleaning 25 72 (0.6) 200 25

Cleaning of Application Equipment 25 72 (0.6) 200 25

*Per Rule 1171 (Solvent Cleaning)

As shown in the table above, SJVAPCD Ru le 4612 is as stringent or more stringent

than other District in all cat egories except for two categories (precoat and Topcoat - Metallic/Iridescent). Since the overwhelmingl y majority of coating categories are as stringent or more stringent than other Districts , Overall SJVAPCD Rule 4612 is at least as stringent as Bay Area Rule 8-45, South Coast Rule 1151, Sac Metro Rule 459, and

Ventura Rule 74.18.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-244 Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, Distric t staff concludes that District Rule 4612

satisfies RACT for motor vehicle and mobile equipment coating operations.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-245 

### Rule 4621 – Gasoline Transfer Into Stationary Storage Containers, Delivery Vessels, and Bulk Plants

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NO X 0.019 0.021 0.023 0.023 0.024 0.027 0.028 0.03

VOC 3.4 3.6 3.7 3. 8 4.1 4.2 4.4 4.5
(Source: District 2007 Ozone Plan)

The emission inventory shown is the comb ined inventory for District Rule 4621,

Gasoline Transfer into Stat ionary Storage Cont ainers, Delivery Vessels, and Bulk Plants, and Rule 4624, Transfer of Organic Liquid

.

District Rule 4621 Description

This rule includes all operations that transfer gasoline between delivery vessels and storage containers and loading ra cks that are used to load organic liquids with a TVP of 1.5 psia or greater. The purpose of this rule is to lim it VOC emissions from stationary storage containers, delivery vessels, and bulk plants.

How does District Rule 4621 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

1. EPA-450/2-77-026 Guideline for Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals

This CTG is related to the control of vola tile organic compounds (V OC) from tank truck terminals with daily throughputs of greater than 76,000 liters of gasoline. District Rule 4621 applies to all operations that trans fer gasoline between delivery vessels and storage containers and loading ra cks that are used to load organic liquids with a TVP of 1.5 psia or greater. Since this CTG only applies to the loading of tank trucks, only the sections of District Rule 4621 that apply to tank truck loading will be evaluated.

This CTG identifies RACT for the control of VOCs from tank tr uck gasoline loading terminals as having an emission limit of 80 mg-hydrocarbon/L-gasoline loaded. District Rule 4621 requires that the VOC emissions from the transfer of gasoline from a stationary storage tank to a gasoline tank truck shall be controlled by 95%. The CTG lists the emission factor for hydrocarbon em issions generated during submerged fill (top or bottom) gasoline loadi ng operations is 600 mg/liter transferred. Therefore, District

Rule 4621 emission limit can be calculated as 30 mg/liter (600 mg/liter * (1 – 0.95)).San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-246 Since this emission limit is lower than the o ne listed in the CTG as RACT, District Rule

4621 satisfies RACT for this CTG.

2. EPA-450/2-77-035 Guideline for Control of Volatile Organic Emissions from Bulk

Gasoline Plants

This CTG outlines the design of control dev ices to control vapors from the loading and unloading activities at a gaso line bulk plant. The CTG discusse s the effective control of

VOC emissions with the installation of subm erged fill pipes and vapor control systems. District Rule 4621 requires that all bulk plant s shall be equipped with an ARB certified vapor recovery system for the loading racks . In addition, District Rule 4621 also describes inspection procedures to verify that the operation is operating leak free. The requirements in District Rule 4621 are equival ent to the control technology discussed in

this CTG.

3. EPA-450/2-78-051 Guideline for Control of Volatile Organic Compound Leaks from Gasoline Tank Trucks and Vapor Collection Systems

This guideline is related to the control of volatile organic compounds (VOC) from gasoline tank trucks and vapor collection systems at bulk terminals, bulk plants, and service stations. The intent of this guideline is to define leak tight conditions and related test procedures for vapor collection systems and tank trucks while loading and unloading at these facilities. Since this CT G only applies to the definition of a leak, only

the definition of a leak from District Rule 4621 will be evaluat ed. In addition, the District does not regulate the emissions from gasoline tank trucks.

The CTG requires that vapor collection syst ems during loading or unloading operations at service stations, bulk plants and bulk termi nals, there shall be no reading greater than or equal to 100 percent of the lower explosiv e limit (LEL, measured as propane) at 2.5 centimeters around the perimet er of a potential leak source as detected by a combustible gas detector. In addition, ther e are to be no avoida ble visible leaks. District Rule 4621 requires that, for delivery vessels, leak emissions shall not exceed the dripping of VOC-containing liquid at a rate of more than three drops per minute, or a reading of greater than 100 per cent of the lower explosiv e limit (21,000 ppm measured as equivalent propane). Both of the regulations limit leaks to equal to or lower than 100 percent LEL, therefore thes e requirements are equivalent.

The CTG also requires the vapor collect ion and vapor processi ng equipment must be designed and operated to prevent gauge pressure in the tank truck from exceeding 4500 pascals (18 inches of water) and prevent vacuum from exceeding 1500 pascals (6 inches of water). District Rule 4621 only ad dresses the transfer of gasoline into tank trucks from bulk plants. District Rule 4621 st ates that the loading rack vapor recovery system shall not create a back pressure in ex cess of the pressure limits of the delivery vessel certification leak test (18 inches wate r column). Since both of these regulations have the same back pressure limit t hese two regulations are equivalent.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-247 Bulk terminal, bulk plant and service station owners or operators must keep records for two years indicating the last time a vapor collection facility passed the required leak testing. District Rule 4621 requires that bulk plants and loading racks keep records of all inspections and all actions conducted on any part of the storage c ontainer or loading racks shall be maintained in chronological order showing date of inspection, description and location of any equipment replaced, and a description of the problem which required repair. In addition, all bulk pl ants are required to maintain daily gasoline throughput records. District Rule 4621 also requires that all records required to demonstrate compliance with the requirements of this rule shall be retained on the premises for a minimum of five years. Therefore the recordkeeping requirements of District Rule 4621 are more stringent than the CTG.

As demonstrated in the discussions above, Distr ict Rule 4621 is equivalent to or more stringent than the similar r equirements form the CTG.

B. EPA – Alternative Control Technology (ACT)

1. EPA-450/R-75-102 Alternativ e Control Technology Document for Stage I Vapor Control Systems on Gaso line Service Stations

This document outlines the design of Phase I vapor control systems for facilities that are required to install such syst ems. CARB now publishes Ex ecutive Orders which details the specific equipment needed for certain v apor recovery systems to meet certain

Executive Orders. The ACT al so states that EPA requires vapor control systems control 90% of the vapors from the P hase I side of a gasoline dis pensing operation. Currently District Rule 4621 requires 98% vapor control from the Phase I vapor control system for underground tanks.

C. Standards of Performance fo r New Stationary Sources (NSPS)

There is no NSPS for this source category.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

There is no NESHAP for this source category.

How does District Rule 4621 compare to rules in other air districts?

District staff compared VOC lim its, optional control require ments, and work practice standards in District Rule 4621 to comparable requirements in rule s from the following

California nonattainment areas:

• South Coast AQMD Rule 461, as amended March 2008

• Bay Area AQMD Regulation 8 Ru le 7, as adopted November 2002San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-248 • Bay Area AQMD Regulation 8 Rule 39, as adopted June 1994

• Sacramento Metro AQMD Rule 448, as amended February 1995

• Ventura County APCD Rule 70, as amended July 2004

A. South Coast AQMD Rule 461

South Coast AQMD Rule 461 (Gasoline Tr ansfer and Dispensing) applies to the transfer of gasoline from any tank truck, tra iler, or railroad tank car into any stationary storage tank or mobile fueler (Phase I), and fr om any stationary storage tank or mobile fueler into any mobile fueler or motor vehi cle fuel tank (Phase II). District Rule 4621 only applies to storage containers located at bulk plants with capacities greater than 250 gallons and less than 19,800 gallons; to other stationary st orage containers with capacities greater than 250 gallons; and to thos e storage containers that are not subject to the control requirements of Rule 4623 (Sto rage of Organic Liquids) Section 5.0. The rule also applies to gasoline delivery vessels . Since District Rule 4621 only applies to the Phase I side of gasoline transferring, Dis trict Rule 4621 will only be compared to the gasoline Phase I requirement s of SCAQMD Rule 461.

SCAQMD Rule 461 requires underground st orage tanks to be equipped with a "CARB certified" enhanced vapor recovery system hav ing a minimum volumetric efficiency of 98% and aboveground storage tanks to be equip ped with a "CARB certified” vapor recovery system having a minimum volumetric efficiency of 95%. The rule also states that the vapor recovery syst ems are required to be mainta ined and operated according to the manufacturer's specif ications and the applicable CARB Executive Orders. District Rule 4621 contains the same vapor recovery requirements for underground and aboveground tanks.

SCAQMD Rule 461 requires mobile fueler t anks to be equipped with a “CARB certified” vapor recovery system having a minimum volumetric efficiency of 95% and to maintained and operated the vapor recovery system according to the manufacturer’s specifications and the applicabl e CARB Executive Orders.

B. Bay Area AQMD Re gulation 8 Rule 7

Bay Area AQMD Regulation 8 Rule 7 (Gasoli ne Dispensing Facilities) applies to both the Phase I and Phase II side of gasoline dispensing facilities. Since District Rule 4621 only applies to the Phase I side of gasoli ne transferring, District Rule 4621 will only be compared to the gasoline Phase I requireme nts of Bay Area AQMD Regulation 8 Rule

7.

BAAQMD Reg 8 Rule 7 exempts storage tan ks with capacities less than 250 gallons, storage tanks with capacities less than 550 gallons that are us ed primarily for the fueling of implements of husbandry and that have a submerged fill pipe, and storage tanks installed before January 1, 1999 where t he APCO determines that Phase I vapor recovery is not feasible. District Rule 4621 contains the same exemptions based on the storage tanks capacities, but also exempts spec ific types of storage tanks that were inSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-249 operation prior to July 1, 1975. Therefore, the applicability of these two rules can be considered equivalent.

BAAQMD Reg 8 Rule 7 requires gasoline st orage tanks to be equipped with a CARB certified Phase I vapor recovery system. This vapor recove ry system is required to be maintained and operated according to the manufacturer's specifications and the applicable CARB Executive Order. In addition, this rule states that no person shall install or modify a Phase I vapor recovery system unless the system vapor recovery rate is 98% or the highest vapor recovery rate spec ified by CARB if the highest rate is less

than 98%. District Rule 4621 contains t he same vapor recovery requirements for gasoline storage tanks therefor e the vapor recovery require ments of these rules are equivalent.

BAAQMD Reg 8 Rule 7 and District Rule 4621 have the same monitoring and testing requirements, however BAAQMD Reg 8 Rule 7 only requires the facility to maintain records for 2 years while District Rule 4621 re quires that records be kept for 5 years.

C. Bay Area AQMD Re gulation 8 Rule 39

Bay Area AQMD Regulation 8 Rule 39 (Gas oline Bulk Plant and Gasoline Delivery Vehicles) applies to gasoline transfer operations at gasoline bulk plants and delivery vehicles. Since BAAQMD Regulation 8 Rule 39 only applies to bulk plants and delivery vessels, only the bulk plant and delivery vess el requirements District Rule 4621 will be compared to the requirements of BAAQMD Regulation 8 Rule 39.

BAAQMD Regulation 8 Rule 39 states that a person shall not load or permit the loading of gasoline into or out of a gasoline bulk plant unless a CARB certified vapor recovery system is properly connected and used. In addition, BAAQMD Regulation 8 Rule 39 states that the loading rack vapor recovery system shall be maintained and operated in a manner that prevents gauge pressure in the delivery tank from exceeding 46cm (18 in.) of water column during product loading. District Rule 4621 contains the same vapor recovery requirements for bulk plants; t herefore the bulk plant vapor recovery requirements of these rules are equivalent.

BAAQMD Regulation 8 Rule 39 states the fo llowing requirements for delivery vessels:

• A person shall not operate, or allow t he operation of, a gasol ine delivery vehicle

unless valid State of California decals , as required by Section 41962 of the Health and Safety Code which attest to the vapor integrity of the tank, are displayed.

• Any gasoline delivery vehicle loading at a facility subject to the requirements of Section 8-33-302 shall be equipped with and use a vapor recovery system.

• A person shall not purge gasoline vapor from the tank of a delivery vehicle to the atmosphere.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-250 District Rule 4621 contains the same vapor recovery requirements for delivery vessels; therefore the delivery vessel vapor recovery requirements of these rules are equivalent.

D. Sacramento Metro AQMD Rule 448

Sacramento Metro AQMD Rule 448 (Gaso line Transfer Into Stationary Source Containers) applies to operations were gasol ine is transferred to stationary storage
containers. Since Sacramento Metro AQMD Rule 448 only applies to transferring of gasoline to stationary storage tanks, only t hese requirements from District Rule 4621 will be compared to the requirem ents of Sacramento Metro AQMD Rule 448. Both rules also do not apply to tanks with capacities less than 250 gallons equipped with a submerged fill pipe.

Sacramento Metro AQMD Rule 448 requires gasoline storage tanks to be equipped with a CARB certified vapor recovery system. This vapor recovery system is required to be maintained and operated according to the manufacturer's specifications and the applicable CARB Executive Order. In addition, th is rule states that the vapor recovery system shall prevent emission to the atmos phere of at least 95%, by weight, of the gasoline vapors displaced from the storage container during the transfer of gasoline into

the container. District Ru le 4621 requires the vapor recovery system to have a minimum volumetric control efficiency of 98%. Therefore the vapor recovery requirements of District Rule 4621 are more stringent than that of Sacramento Metro
AQMD Rule 448.

Sacramento Metro AQMD Rule 448 requires t hat delivery vessels shall be maintained leak free and a vapor tight. In addition, this rule also prohibits any person from purging gasoline vapors, gases, or hydrocarbon va pors from a delivery vessel to the atmosphere. District Rule 4621 has the same requirements for delivery vessels; therefore the delivery vessel require ments for both rules are equivalent.

District Rule 4621 requires the same m onitoring and testing requirements as
Sacramento Metro AQMD Rule 448.

E. Ventura County APCD Rule 70

Ventura County APCD Rule 70 (Storage and Trans fer of Gasoline) applies to operations were gasoline is transferred and to storage operations with gasoline containers less than 40,000 gallons. Since District Rule 4621 only applies to the Phase I side of gasoline transferring. Both rules have ex emptions in place for storage tanks with capacities of 250 gallons or less, however Ventura County APCD contains other exemptions in excess of what District Rule 4621 exempts. Therefore District Rule 4621 is applicable to more types of operations. District Rule 4621 will only be compared to the gasoline Phase I requirements of V entura County APCD Rule 70.

Ventura County APCD Rule 70 requires gas oline storage tanks to be equipped with a CARB certified vapor recovery system. This vapor recovery system is required to beSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-251 maintained and operated according to the manufacturer's specifications and the applicable CARB Executive Order. In addition, th is rule states that the vapor recovery system shall prevent emission to the atmospher e of at least 95% of the gasoline vapors displaced from the storage cont ainer during the transfer of gas oline into the container. District Rule 4621 requires the vapor recove ry system to have a minimum volumetric control efficiency of 98%. For bulk plant s, both Ventura Count y APCD Rule 70 and District Rule 4621 require that the loadi ng racks are equipped with an ARB certified vapor recovery system. Therefore the vapor recovery requirements of District Rule 4621 are more stringent than that of Ventura County APCD Rule 70.

Ventura County APCD Rule 70 requires that delivery vessels shall only load and unload at facilities with CARB certified vapor recove ry systems. In addition, both rules have the same requirements when opening the hatch to per form a visual inspection. District Rule 4621 has the same requirements for deliver y vessels; therefore the delivery vessel requirements for both ru les are equivalent.

Ventura County APCD Rule 70 and District Rule 4621 have the same monitoring and testing requirements, however Ventura County APCD Rule 70 only requires the facility to maintain records for 2 years while District Rule 4621 requires that records be kept for 5 years.

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, Distric t staff concludes that District Rule 4621 satisfies RACT for gasoline transfer into st ationary storage containers, delivery vessels, and bulk plants.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-252 

### Rule 4622 – Gasoline Transfer in to Motor Vehicle Fuel Tanks

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

VOC 2.7 2.8 2.9 3. 0 3.3 3.4 3.6 3.6
(Source: District 2007 Ozone Plan)

District Rule 4622 Description

Rule 4622, recently amended on December 20, 2007, limits VOC emissions from the transfer of gasoline into motor vehicle fuel tanks. The main rule requirement is that gasoline dispensing units used to transfer gaso line from a stationary source to a motor vehicle tank must be equipped with a ARB cert ified Phase II vapor recovery system.

On May 30, 2007 EPA took direct final acti on to approve revisions to the San Joaquin Valley Unified Air Pollution Control District portion of the California State Implementation Plan. These revisions included approval of District Rule 4622. EPA, in evaluating and approving Rule 4622 included the following:

“We believe these rules are consistent with the relevant policy and guidance regarding enforceability, RACT, BACM, and SIP relaxations.” ( CFR Volume 72,

Number 103 )

Since Rule 4622 was recently approved by EPA as meeting RACT requirements, the District did not pursue a det ailed RACT analysis.

How does District Rule 4622 compare wi th federal rules and regulations?

The District did not conduct a detailed analysis of federal rules and regulations for Rule

4622.

How does District Rule 4622 compare to rules in other air districts?

The District did not conduct a detailed comparison to rules in other air districts for Rule

4622.

Conclusion

District staff concludes that District Rule 4622 satisfies RACT for the transfer of gasoline

into motor vehicle fuel tanks.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-253 

### Rule 4623 – Storage of Organic Liquids

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

VOC 0.107 0.109 0.109 0.109 0.11 0.12 0.12 0.107
(Source: District 2007 Ozone Plan)

District Rule 4623 Description

District Rule 4623, recently amended on May 19, 2005, regulates VOC emissions from tanks that store organic liquids if the tank capacity is 1, 100 or greater and the true vapor pressure (TVP) of the stored li quid is 0.5 psia or greater. Current VOC controls require pressure-vacuum relief valves, internal floati ng roof tanks, external floating roof tanks, fixed roof tanks with vapor recovery system of at least 95% control efficiency, or pressure vessels. Specific control require ments vary depending on the tank capacity and TVP of the stored liquid. Di fferent tank control requirem ents are specified for tanks operated by small producers or by non-sm all producers. Leak detection and repair (LDAR) provisions include periodic inspecti on and repair of leaking components within a specified time frame. The com ponent leak standard is 10,000 ppmv.

On May 30, 2007 EPA took direct final acti on to approve revisions to the San Joaquin Valley Unified Air Pollution Control District portion of the California State Implementation Plan. These revisions included approval of District Rule 4623. EPA, in evaluating and approving Rule 4623 included the following:

“We believe these rules are consistent with the relevant policy and guidance regarding enforceability, RACT, BACM, and SIP relaxations.” ( CFR Volume 72,

Number 103 )

Since Rule 4623 was recently approved by EPA as meeting RACT requirements, the District did not pursue a det ailed RACT analysis.

How does District Rule 4623 compare wi th federal rules and regulations?

The District did not conduct a detailed analysis of federal rules and regulations for Rule

4623.

How does District Rule 4623 compare to rules in other air districts?

The District did not conduct a detailed comparison to rules in other air districts for Rule

4623.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-254 Conclusion

District staff concludes that District Rule 4623 satisfies RACT for Storage of Organic Liquids.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-255 

### Rule 4624 – Transfer of Organic Liquid

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 0.019 0.021 0.023 0. 023 0.024 0.027 0.028 0.03

VOC 3.4 3.6 3.7 3. 8 4.1 4.2 4.4 4.5

The emission inventory shown is the comb ined inventory for District Rule 4621, Gasoline Transfer into Stationary Storage Co ntainers, Delivery Vessels, and Bulk Plants, and Rule 4624, Transfer of Organic Liquid

.

District Rule 4624 Description

The purpose of this rule is to limit VOC em issions from the transfer of organic liquids, which are liquids that contain VOCs and have a True Vapor Pressure (TVP) of 1.5 psia or greater at the storage container’s maximum organi c liquid storage temperature.

The rule exempts the followin g categories: (a) transfer of less than 4,000 gallons of organic liquids per day; (b) gasol ine stations – which are covered by District rules 4621 and 4622; (c) transfer operations using vacuum trucks; (d) equipment or components subject to District rules 4409 (Components at Light Crude Oil Production Facilities, Natural Gas Production Facilities, and Natural Gas Processing Facilities), 4455 (Components at Petroleum Refineries, Gas Li quids Processing Facilities, and Chemical Plants), or 4623 (Storage of Organic Liquid s) are exempt from leak inspection requirements of Rule 4624, and (e) bottom loading is not required for facilities handling only liquefied petroleum gas.

Facilities transferring 20,000 gallons or more per day of organic liquid must comply with

a VOC emission limit of 0. 08 lb per 1,000 gallons, use bottom loading, and route VOC vapors to a vapor collection and control system , a fixed roof contai ner, a floating roof container, a pressure vessel, or ot her closed VOC emission control system.

Facilities transferring less than 20,000 gallons per day of organic liqui d must capture at least 95% of VOC vapors disp laced during loading, use bo ttom loading, and route VOC vapors to a vapor collection and control system , a fixed roof contai ner, a floating roof container, a pressure vessel, or ot her closed VOC emission control system.

Pressure in the delivery tank being loaded must be maintained within the range of 18 inches water column pressure and six (6) inches water column vacuum. Delivery tanks which previously contained organic liquids sha ll be filled only at transfer facilities that are compliant with the vapor capture requirements. Transfer racks and vapor collection equipment shall have no leaks and no excess organic liquid drainage at disconnections. New top loading facilities or the expansions of any existing one are prohibited.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-256 Quarterly inspection for leaks is required. A facility may apply to reduce inspection frequency to annual after passing five quarterly inspections. Leaking equipment must be repaired or taken out of service within 72 hours.

In addition to an initial source test, VOC c ontrol systems must be source tested every 5

years.

Record keeping is required for organic li quid daily throughput and TVP for facilities exempt based on throughput or TVP, daily throughput and leak inspection records for

affected facilities. Vacuum truck operators claiming exem ption must submit, on a onetime basis, records showing number of vacuum trucks in operation, capacity of each vacuum truck storage container, average m onthly throughput per vehicle, type of organic liquid transferred, and VOC c apture and control equipment utilized.

Records must be retained for a minimum of five years.

How does District Rule 4624 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals.

This CTG applies to facilities with a throughput of more than 20,000 gallons per day.

The CTG states that the recommended loadi ng terminal emission limit that can be achieved through the application of reasonably available control technology (RACT) is 0.64 lb VOC per 1,000 gallo ns of gasoline loaded.

District Rule 4624 is more stringent than this CTG because it requires a VOC emission limit of 0.08 lb per 1,000 gallons for fac ilities with a throughput of 20,000 gallons or more, compared to the CTG’s recommended limit of 0.64 lb per 1,000 gallons.

B. EPA – Alternative Control Technology (ACT)

There is no ACT for this source category.

C. Standards of Performance fo r New Stationary Sources (NSPS)

40 CFR 60 Subpart XX, Standards of Perfor mance for Bulk Gasoline Terminals

This NSPS applies to facilities with a th roughput of more than 19,984 gallons per day (75,700 liters per day), and requires the us e of a vapor collect ion system with VOC emissions to the atmosphere not exceeding 0. 28 lb/1,000 gallons (35 milligrams/ liter). The VOC emission limit for vapor collecti on systems at existing (pre-December 17, 1980) facilities is 0.64 lb/1,000 gallons (80 mi lligrams/liter). The vapor collection system shall be designed to prevent vapors colle cted at one loading rack from passing toSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-257 another loading rack, and only vapor-tight gasoline tank trucks shall be loaded. The operator shall obtain the vapor tightness documentation for tr ucks to be loaded. Tank

numbers are to be recorded dur ing loading and subsequently cross-checked with filed vapor tightness documentation. If the cross-checking reveals that a non-vapor tight tank was loaded, the operator must notify the tank owner and ensu re that the tank is not reloaded at that facility until vapor tightness documentation is obtained.

The NSPS also requires that the vapor collection and liquid lo ading equipment is designed and operated to prevent gauge pressure in the delivery tank from exceeding 4,500 Pascals (450 mm of water) during product loading. Monthly inspection for leaks is required.

Records must be maintained for tank tr uck vapor tightness documentation, leak inspections, and component additions or replac ements. Record must be retained for at least two years.

District Rule 4624 is more stringent than 40 CFR 60 Subpart XX because it applies to loading racks at all terminals, whereas 40 CFR 60 Subpart XX applies only to racks at facilities with a throughput exceeding 19,984 gallons per day.

District Rule 4624 is more stringent than 40 CFR 60 Subpart XX because it requires a

VOC emission limit of 0.08 lb /1,000 gallons, whereas 40 CFR 60 Subpart XX allows the much lower limits of 0.28 lb/1,000 gallons for new facilities and 0.64 lb/1,000 gallons for existing facilities.

There are no significant differences between District Rule 4624 and 40 CFR 60 Subpart XX for source testing, monito ring and reporting requirements.

District Rule 4624 is more stringent under this category because it requires records to be retained for at least 5 years, whereas 40 CFR 60 Subpart XX requires only 2 years

for record retention.

The preceding comparison demonstrates that Dis trict Rule 4624 is more stringent than 40 CFR 60 Subpart XX.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

40 CFR 63 Subpart EEEE, Organic Liqui ds Distribution (Non-Gasoline)

This NESHAP applies to various equipment and components used in organic liquids distribution, including loading racks.

The NESHAP requires the that vapors displa ced during loading (1) be routed through a closed vent system into any combination of c ontrol devices achieving at least 98 weightpercent HAP reduction, or a reduction to an ex haust concentration less than or equal toSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-258 20 ppmv (control devices must meet applic able testing, monitoring and operating standards depending on type of devic e); (2) be routed into fuel gas systems or back into a process; or (3) captured in a vapor balancing system that routes organic HAP vapors to the storage tank from which the liquid being loaded originated or to another storage

tank connected to a common header.

The requirements of District Rule 4624 and 40 CFR 63 Subpart EEEE are similar as far as the collection and disposal of vapors displaced during organic liquid loading is concerned. However, it is possible to comp are destruction efficiencies of the control equipment directly, because District Rule 4624 addresses only VOC (requiring a destruction efficiency of 95%), while 40 CFR 63 Subpart EEEE addresses HAPs (requiring a destruction efficiency of 98%).

In addition, the District implements 40 CFR 63 Subpart EEEE by re ference under Distri ct Rule 4002.

How does District Rule 4624 compare to rules in other air districts?

District staff compared emission limits, opti onal control requirements, and work practice standards in District Rule 4624 to comparable requirements in rule s from the following

California nonattainment areas:

• South Coast AQMD Rule 462 (amended 5/14/1999)

• South Coast AQMD Rule 1142 (adopted 7/19/1991)

• Bay Area AQMD Regulation 8 Rule 6 (amended 2/2/1994)

• Bay Area AQMD Regulation 8 Rule 33 (amended 6/1/1994)

• Bay Area AQMD Regulation 8 Rule 39 (amended 6/1/1994)

• Ventura County APCD Rule 70 (revised 11/11/2003)

• Ventura County APCD Rule 71.3 (revised 6/16/1992)

• Sacramento Metro AQMD Ru le 447 (revised 4/2/1998)

A. South Coast AQMD Rule 462

The purpose of South Coast AQMD Rule 462 is to control emissions of volatile organic compounds (VOC) from facilities that load or ganic liquids with a vapor pressure of 1.5 psia. The rule provides an exemption fr om the vapor recovery system and associated continuous monitoring system for facilities that vent loading v apors to a flare or

combustion device.

The rule requires loading of organic liquids at facilities with a throughput of 20,000 gallons or more to be done only using a CA RB vapor recovery or vapor disposal system, or equivalent system appr oved by the air District. The vapor recovery/disposal system shall be equipped with a continuous monitoring syst em, and must reduce the

emissions of VOCs to 0.08 lb/1,000 gallons of organic liquid transferred. Only bottom loading is to be used, and there shall be no ov erfills or leaks. The backpressure in theSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-259 vapor recovery and/or disposal system sha ll not exceed 18 inches of water column

pressure.

For facilities with a throughput of less than 20,000 gallons, the vapor recovery/disposal system must reduce VOC emissions by at leas t 90%. Only bottom loading is to be used,

and there shall be no overfills or leaks. The backpressure in the vapor recovery and/or disposal system shall not exceed 18 inches of water column pressure.

For facilities with a throughput of less t han 4,000 gallons per day and less than 500,000 gallons per year no vapor recovery/disposal system is required. Only bottom loading is to be used, and there shall be no overfills or leaks

Uncontrolled switch loading is prohibited exc ept only at those facilities with a throughput of less than 4,000 gallons/day and less than 500,000 gallons/yr.

Monthly leak inspection is required if the inspection is to be done by sight, sounds and smell. If an organic vapor analyzer is us ed, the inspection ma y be done quarterly.

Required records include (1) daily and year -to-date throughput records (2) inspection records. Records are required to be retained for two years.

South Coast AQMD Rule 462 is slightly mo re stringent under this category. Whereas District Rule 4624 has no requirements at all fo r facilities with a throughput of less than 4,000 gallons a day (equivalent to an annual throughput of ar ound 1,460,000 gallons), South Coast AQMD Rule 462 imposes vapor reco very requirements on such facilities if they exceed 500,000 gallons per year. S outh Coast Rule 462 also requires bottom loading for facilities that are below 4,000 gallons per day and 500,000 gallons per year in throughput.

Both rules have similar requirements for facilities with organic liquid throughputs of 20,000 gallons per day or more. For fa cilities between 4,000 and 20,000 gallons per day in throughput, District Rule 4624 is more stringent because it requires the vapor recovery system for such facilities to reduce VOC emi ssions by at least 95%, whereas South Coast AQMD Rule 462 requires a 90% reduction. For facilities with less than 4,000 gallons per day in thr oughput, South Coast AQMD Rule 462 is more stringent because it requires vapor recovery and/or bottom loading, depending on annual throughput, whereas District Rule 4624 has no requirements.

South Coast AQMD Rule 462 is more st ringent for source testing and monitoring because it requires more frequent inspecti ons (monthly for sigh t/smell/sound method, and quarterly for analyzer). District Rule 4624 requires quarterly inspection and has a provision for reducing the frequen cy further to annual inspection. In addition, South Coast AQMD Rule 462 is more stringent under monitoring because it requires the installation and use of a c ontinuous monitoring system for the vapor recovery system.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-260 There is no significant difference between the tw o rules for reporting. District Rule 4624 is more stringent for recordk eeping because it requires records to be retained for at least 5 years, whereas South Coast AQMD Ru le 462 has a two-year record retention requirement.

South Coast AQMD Rule 462’s requirement of a continuous monitoring system for vapor recovery systems represents a standard that is more stringent than District Rule 4624. A cost effectiveness analysis is requi red to determine if such a requirement should be incorporated into District Rule 4624. However, there is no data that can be

used to determine the emission reductions attributable to a continuous monitoring system. It is therefore re commended that the continuous monitoring requirement is

considered under the context of a rule amendment or rule making process which allows

for detailed studies to determine factors su ch as emission reductions, feasibility,

economic and socio-economic costs.

B. South Coast AQMD Rule 1142

South Coast AQMD Rule 1142 applies to th e loading of organic liquids into marine vessels, among other operations. The rule requi res emissions of VOCs to be limited to 0.05 lb/1,000 gallons (2 lb/1,000 barrels) of liquid loaded into a marine tank vessel; or the emissions of VOCs to be reduced by at least 95 percent by weight from uncontrolled conditions. All equipment is required to be l eak-free. Records of organic liquid loading events are required to be retai ned for at least two years.

As far as applicability is concerned, Distric t Rule 4624 is a much more comprehensive rule because it applies to all organic liqui d loading events. On the other hand, South
Coast AQMD Rule 1142 is much narrower in scope because it applies only to the loading of marine vessels.

As far as exemptions are c oncerned, South Coast AQMD Rule 1142 is more stringent because it does not offer any exemptions, whereas District Rule 4624 has a throughput exemption for facilities transferring less than 4,000 gallons of liquid per day, as well as other fairly insign ificant exemptions.

District Rule 4624 is more stringent than S outh Coast AQMD Rule 1142 under this category. Rule 4624 has two emission control requirements: (1) reduction of loading VOC emissions by 95% for facilities with a throughput of less than 20,000 gallons per day, and (2) a stricter limit of 0.08 lb/1, 000 gallons for facilities with a throughput of 20,000 gallons per day or more. On the other hand, South Coast AQMD Rule 1142 gives all facilities a choice between a limit of 0.05 lb VOC/1,000 gallons and reduction of VOC emissions by 95%. It is reasonable to assume that, gi ven a choice, facilities will take the less stringent requirement of 95% emissions reduction, hence the South Coast

Rule will result in less overall emissions control in comparison to District Rule 4624.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-261 Source Testing and Monitoring :

There is no significant difference betw een the two rules under this category.

Reporting :

There is no significant difference betw een the two rules under this category.

Record Keeping :

District Rule 4624 is more stringent under this category because it requires records to be retained for at least 5 years, whereas South Coast AQMD Rule 1142 requires only two years of record retention.

The preceding comparison demonstrates that, taking all the comparison categories into consideration, District Rule 4624 is more stringent than South Coast AQMD Rule 1142.

C. Bay Area AQMD Re gulation 8 Rule 6

The purpose of Bay Area AQMD Regulation 8 Rule 6, Terminals and Bulk Plants , is to limit emissions of organic co mpounds from transfer operatio ns at non-gasoline organic liquid bulk terminals and bulk plants.

The rule provides the following exemptions: (a ) liquids with a TVP less then 0.5 psi; (b) facility-wide annual organic liquid (with TVP of at least 1.5 psia) throughput of 600,000 gallons or less; (c) spills resulting from ma intenance and repair; (d) liquefied gases such

as LPG.

The rule require loading of organic liquids to be done only using a vapor loss control system which limits VOC vapor emissions into the atmospher e to 0.17 lb/1,000 gallons for bulk terminals and 0.35 lb/1,000 gallons for bulk plants. Submerged fill pipe or bottom loading is required for transferring or ganic liquid into delivery vehicles or transportable containers. The rule requires th e vehicles loaded with organic liquid shall be equipped to allow proper connection to the vapor balance system or vapor loss control system and shall be maintained to be vapor tight, leak, free, and in good working

order.

Required records include (1) true vapor pre ssure of each organic liquid and organic liquid mixture (2) monthly thr oughput records. Records are required to be retained for two years.

District Rule 4624 is compared to Bay Area AQMD Regulation 8 Rule 6 under the following categories:San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-262 Applicability/Exemption :

The applicability is the same for both rule s. San Joaquin Valley APCD has one rule (4624) that applies to loading /transfer operations regardless of the type of facility doing the loading/transfer , whereas Bay Ar ea AQMD applies the loading/transfer requirements through three differ ent facility-specific rules.

District Rule 4624 is less stringent in the throughput-based exemption because it allow an exemption up to 4,000 gallons a day (1,4 60,000 gallons per year), whereas Bay Area AQMD Regulation 8 Rule 6 allows only 600,000 gallons per year.

There is no difference in the TVP exempt ions since requirements for both rules generally apply to liquid with a TVP of at least 1.5 psia.

Requirements :

District Rule 4624 is more stringent than Ba y Area AQMD Regulation 8 Rule 6 because it requires a VOC emission limit of 0.08 lb/1,000 gallon, whereas Bay Area AQMD Regulation 8 Rule 6 requires a VOC em ission limit of 0.17 lb/1,000 gallon.

Source Testing and Monitoring :

There is no significant difference betw een the two rules under this category.

Reporting :

There is no significant difference betw een the two rules under this category.

Record Keeping :

District Rule 4624 is more stringent under this category because it requires records to be retained for at least 5 years, whereas Bay Area AQMD Regulation 8 Rule 6 has a two-year record retention requirement.

The preceding comparison demonstrates that, taking all the comparison categories into consideration, District Rule 4624 is more stringent than Bay Area AQMD Regulation 8 Rule 6. Although District Rule 4624’s throughput exemption is only half as stringent, its VOC emission, which is a much more critical aspect of the regulation, is twice as stringent as the corresponding Bay Area AQMD Regulation 8 Rule 6 limit.

D. Bay Area AQMD Re gulation 8 Rule 33

The purpose of Bay Area AQMD Regulation 8 Rule 33, Gasoline Bulk Terminals and Gasoline Delivery Vehicles , is to limit emissions of organic compounds from transfer operations at gasoline bulk te rminals and delivery vehicles.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-263 The rule provides the following exemptions: (a) delivery vehicles delivering exclusively to small tanks (< 550 gallons) or tanks for which vapor recovery is not feasible; (b) spills resulting from maintenance and repair.

The rule requires loading of gasoline to be done only using a vapor recovery system which limits VOC vapor emissions into the atmosphere to 0.08 lb/1,000 gallons. Bottom loading is required for transferring gasoline in to delivery vehicles. All gasoline transfer equipment shall be maintained leak-free, v apor tight and in good working condition. The vapor recovery system shall be operated and main tained to prevent pressure in the tank from exceeding 18” water column during loading.

District Rule 4624 is compared to Bay Ar ea AQMD Regulation 8 Rule 33 under the following categories:

Applicability/Exemption :

The applicability is the same for both rule s. San Joaquin Valley APCD has one rule (4624) that applies to loading /transfer operations regardless of the type of facility doing the loading/transfer, whereas Bay Area AQMD applies the loading/ transfer requirements through three different facility-specific rules.

Exemptions are fairly compar able between the two rules. T he main exemption provided by District Rule 4624 is the throughput exem ption for facilities transferring less than 4,000 gallons of liquid per day, whereas t he main exemption offered by Bay Area AQMD Regulation 8 Rule 33 is loading of deliv ery vehicles that serve small tanks or tanks without vapor recovery.

Requirements :

There is no significant difference betw een the two rules under this category. Source Testing and Monitoring :

There is no significant difference betw een the two rules under this category. Reporting :

There is no significant difference betw een the two rules under this category. Record Keeping :

District Rule 4624 is more stringent under this category because it requires records to be retained for at least 5 years, whereas Ba y Area AQMD Regulation 8 Rule 33 has no record retention requirement.

The preceding comparison demonst rates that, taking all the comparison categories into consideration, District Rule 4624 is as stri ngent as Bay Area AQMD Regulation 8 Rule 33. Both rules offer fairly comparable exempti ons, and require the use of a vapor recovery system with a VOC emission lim it of 0.08 lb/1,000 gallons and bottom loading.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-264 E. Bay Area AQMD Re gulation 8 Rule 39

The purpose of Bay Area AQMD Regulation 8 Rule 39, Gasoline Bulk Plants and Gasoline Delivery Vehicles , is to limit emissions of organic compounds from transfer operations at gasoline bulk pl ants and delivery vehicles.

The rule provides the following exemptions: (a) delivery vehicles delivering exclusively to small tanks (< 550 gallons) or tanks for which vapor recovery is not feasible; (b) spills resulting from maintenance and repair.

The rule requires loading of gasoline to be done only using a vapor recovery system which limits VOC vapor emissions into t he atmosphere to 0.50 lb/1,000 gallons. All gasoline transfer equipment shall be maintai ned leak-free, vapor tight and in good working condition. The vapor recovery system shall be operated and maintained to prevent pressure in the tank from exc eeding 18” water colu mn during loading.

District Rule 4624 is compared to Bay Area AQMD Regulation 8 Rule 39 under the following categories:

Applicability/Exemption :

The applicability is the same for both rule s. San Joaquin Valley APCD has one rule (4624) that applies to loading /transfer operations regardless of the type of facility doing the loading/transfer, whereas Bay Area AQMD applies the loading/ transfer requirements through three different facility-specific rules.

Exemptions are fairly compar able between the two rules. T he main exemption provided by District Rule 4624 is the throughput exem ption for facilities transferring less than 4,000 gallons of liquid per day, whereas t he main exemption offered by Bay Area AQMD Regulation 8 Rule 39 is loading of deliv ery vehicles that serve small tanks or tanks without vapor recovery.

Requirements :

District 4624 is more stringent under this category because it requires a vapor recovery system with a VOC emission limit of 0.08 lb/1,000 gallons, whereas Bay Area AQMD Regulation 8 Rule 39 allows VOC emissions up to 0.50 lb/1 ,000 gallons from the vapor recovery system. Rule 4624 also requires bottom loading, whereas Bay Area AQMD Regulation 8 Rule 39 does not.

Source Testing and Monitoring :

There is no significant difference betw een the two rules under this category.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-265 Reporting :

There is no significant difference betw een the two rules under this category.

Record Keeping :

District Rule 4624 is more stringent under this category because it requires records to be retained for at least 5 years, whereas Ba y Area AQMD Regulation 8 Rule 39 has no record retention requirement.

The preceding comparison demonstrates that, taking all the comparison categories into consideration, District Rule 4624 is more stringent than Bay Area AQMD Regulation 8 Rule 39. Both rules offer fairly compar able exemptions, but Rule 4624 has a more stringent VOC emission limit of 0.08 lb/1 ,000 gallons and requires bottom loading.

F. Sacramento Metro AQMD Rule 447

Sacramento Metro AQMD Rule 447, Organic Liquid Loading , is applicable to the loading of organic liquids into any tank truck, traile r, or railroad tank car from a bulk plant or a

bulk terminal.

The rule provides an exemption for organic li quids with a vapor pressure of less than 0.5 psia.

The rule requires emissions to be limited to 0.08 lb VOC/1,000 gall ons for organic liquid bulk terminals and 0.6 lb VOC/1,000 gallons fo r bulk plants. The system of achieving the emission limits is not specified. However, the rule further stat es that for gasoline loading a CARB-certified vapor recovery system must be used. Loading equipment

must be maintained leak-free.

Records required include inspection record s and any testing results. Records are required to be retained for at least three years.

District Rule 4624 is compared to Sacr amento Metro AQMD Rule 447 under the following categories:

Applicability/Exemption :

There is no significant difference betw een the two rules under this category.

Requirements :

District 4624 is more stringent under this category because it requires a vapor recovery system with a VOC emission limit of 0.08 lb/1 ,000 gallons (or 95% control efficiency for facilities with less than 20,000 gallons thr oughput) for all loading operations, whereasSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-266 Sacramento Metro AQMD Rule 447 allows emission as high as 0.6 lb VOC/1,000 gallons for loading operations at bulk plants.

Source Testing and Monitoring :

There is no significant difference betw een the two rules under this category.

Reporting :

There is no significant difference betw een the two rules under this category.

Record Keeping :

District Rule 4624 is more stringent under this category because it requires records to be retained for at least 5 years, whereas Sacramento Metro AQMD Rule 447 requires a record retention perio d of only 3 years.

The preceding comparison demonstrates that, taking all the comparison categories into consideration, District Rule 4624 is more stringent than Sacramento Metro AQMD Rule

447.

G. Ventura County APCD Rule 70

Ventura County APCD Rule 70, Storage and Transfer of Gasoline , is applicable to the storage and transfer of gasoline.

The rule provides several exemptions for: (a) gasoline bulk plants where the average daily gasoline throughput has not exceeded 4,000 gallons on a thirty day rolling average and the gasoline throughput has not excee ded 200,000 gallons on a twelve month rolling average; (b) gasoline bulk plants that load exclusively to gasoline delivery vessels that service only storage containers t hat are not required to be equipped with Phase I vapor recovery systems;

The rule requires the transfer of gasoline at bulk plants to be done only using a vapor recovery system that prevent s 90 percent of the displaced vapors from being released into the atmosphere, and has a maximum emi ssions factor of 0.84 lbs of hydrocarbon emitted per 1000 gallons of throughput. For tr ansfers at gasoline terminals, the vapor recovery system shall have a VOC emission limit of 0.08 lb/1,000 gallons, and only bottom loading shall be used. Switch-loading at bulk plants or terminals must be done only with the use of a vapor recovery system. Vapor recovery equipment shall be maintained leak-free and in good working order.

Records required include throughput record s and delivery destination records needed to substantiate gasoline loading vapor recove ry exemption; and vapor recovery system

maintenance records.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-267 Records are required to be retained for up to two years.

District Rule 4624 is compared to Ventur a County APCD Rule 70 under the following categories:

Applicability/Exemption :

The applicability is the same for both rule s. San Joaquin Valley APCD has one rule (4624) that applies to loading /transfer operations regardless of the type of facility doing the loading/transfer, whereas Ventura County APCD applies the loading/transfer requirements through two different facility-specific rules.

Exemptions are fairly com parable between the two rules. The main exemption provided by District Rule 4624 is the throughput ex emption for facilities transferring less than 4,000 gallons of liquid per day, whereas Ve ntura County APCD Rule 70 provides a throughput exemption and also an exemptio n for gasoline loads destined for vapor recovery-exempt tanks. Ventura County APCD Rule 70’s exemption is stricter (4,000 gallons per month and 200, 000 gallons per year.

Requirements :

District 4624 is more stringent under this category because it requires a vapor recovery system with a VOC emission limit of 0.08 lb /1,000 gallons, or 95% control efficiency depending on facility throughput, whereas Ventur a County APCD Rule 70 allows VOC emissions up to 0.84 lb/1,000 gallons (or 90% control efficiency) fo r bulk plant gasoline transfer vapor recovery systems. Rule 46 24 also requires bottom loading, whereas Ventura County APCD Rule 70 does not r equire bottom loading for bulk plants.

Source Testing and Monitoring :

There is no significant difference betw een the two rules under this category.

Reporting :

There is no significant difference betw een the two rules under this category. Record Keeping :

District Rule 4624 is more stringent under this category because it requires records to be retained for at least 5 years, whereas Ventura County APCD Rule 70 requires a record retention perio d of only 2 years.

The preceding comparison demonstrates that, taking all the comparison categories into consideration, District Rule 4624 is more stringent than Ventura County APCD Rule 70. Both rules offer fairly comparable exempt ions, but Rule 4624 has a more stringent VOC emission limit of 0.08 lb/1,000 gallons for liquid transfer vapor recovery systems, and also requires bottom loading.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-268 H. Ventura County APCD Rule 71.3

Ventura County APCD Rule 71.3, Transfer of Reactive Organic Compound Liquids , is applicable to equipment used to transfer reactive organic compound (ROC) liquids with a Modified Reid Vapor Pressure (MRVP) greater than or equal to 0.5 psia.

The rule provides several exemptions for: (a) organic liquid with a modified Reid Vapor Pressure of less than 0.5 psia; (b) transfer, production or separation of crude oil; (c)

tank marker calibration activities.

The rule requires the use of submerged fill pi pe or bottom loading for transfer of organic liquids. For facilities with a throughput of 20,000 gallons per day or 150,000 gallons per year, a vapor recovery system must be used during liquid transfer and collected vapors condensed and sent into a gas pipeline of tr eated in a vapor treatment system capable of a 90% destruction efficiency. An overf ill protection device is also required during loading. The loading e quipment shall be leak-free and the vapor recovery system shall be operated and maintained so t hat it does not cause the pressure in any delivery vessel to exceed 18 inches water gauge or the vacuum to exceed 6 inches water

gauge.

The rule requires operators to annually m onitor one complete loading operation for leaks and for proper operation of the l oading equipment and delivery vessel vapor recovery and overfill protection systems, and notify the APCD wit hin 72 hours if any problems were detected.

Records required include inspection record s, throughput and vapor pressure records needed to substantiate exemptions; and vacuum truck loading records.

Records are required to be retained for at least two years.

District Rule 4624 is compared to Ventura County APCD Rule 71.3 under the following categories:

Applicability/Exemption :

The applicability is the same for both rule s. San Joaquin Valley APCD has one rule (4624) that applies to loading /transfer operations regardless of the type of facility doing the loading/transfer, whereas Ventura County APCD applies the loading/transfer requirements through two different facility-specific rules.

District Rule 4624 is more stringent in the ex emptions provided bec ause it exempts only facilities transferring less than 4,000 gallons of liquid per day, whereas Ventura County APCD Rule 71.3 basically exempts (by not requiring a vapor recovery system) loading operations where the throughput is less than 20,000 gallons per day.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-269 Requirements :

District 4624 is more stringent under this category because it requires a vapor recovery system with a VOC emission limit of 0.08 lb /1,000 gallons, or 95% control efficiency depending on facility throughput, whereas Vent ura County APCD Rule 71.3 requires only a 90% control efficiency for the vapor recovery system.

Source Testing and Monitoring :

There is no significant difference betw een the two rules under this category.

Reporting :

There is no significant difference betw een the two rules under this category. Record Keeping :

District Rule 4624 is more stringent under this category because it requires records to be retained for at least 5 years, whereas Ventura County APCD Rule 71.3 requires a record retention perio d of only 2 years.

The preceding comparison demonstrates that, taking all the comparison categories into consideration, District Rule 4624 is mo re stringent than Ventura County APCD Rule

71.3.

Conclusion

After evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, District staff concludes that District Rule 4624 satisfies RACT for Transfer of Organic Liquid.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-270 

### Rule 4625 – Wastewater Separators

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

VOC 0.17 0.17 0.17 0.17 0.17 0.17 0.17 0.19
(Source: District 2007 Ozone Plan)

District Rule Description

Rule 4625, amended on Decem ber 17, 1992, applies to wa stewater separators. The rule does not apply to the separation of crude oil and water prior to custody transfer. The rule prohibits the use of any compartment of any vesse l or device operated for the recovery of oil or tar from effluent water, from equipment which processes, refines, stores, or handles petroleum or coal ta r products unless such compartments are equipped with one of the fo llowing: (1) a solid cover with all openings sealed and totally enclosing the liquid contents of the compar tment; (2) a floating pontoon or double deck type cover with closure seals that meet specif ic requirements of the rule; or (3) a vapor recovery system with a combined collection and control efficiency of at least 90%. Control devices must be under District pe rmit. Any gauging and sa mpling device in the compartment cover must be equipped with a cove r or lid, which must be closed at all times except when the device is in actual use. Although not s pecifically indicated in Rule 4625, components that are used in refinery wa stewater separator operations are also subject the leak standards, inspection and r epair provisions specified in Rule 4455 (Components at Petroleum Refi neries, Gas Liquids Processi ng Facilities, and Chemical Plants).

How does District Rule 4625 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

EPA-450/2-77-025 (Control of Refinery Vacuum Producing Systems, Water Separators and Process Unit Turnarounds), October 1977, indicates t hat RACT for wastewater separators requires control of VOC emissions by covering the forebays and separator sections to minimize the amount of oily water exposure to t he atmosphere. The requirements include a solid cover with all openings sealed totally enclosing the compartment liquid contents; or a floating pontoon or double deck type cover, equipped with closure seals to enclose the space between the cover’s edge and compartment wall. Rule 4625 control requirements are basically the same as the CTG.

EPA also published a Draft CTG (EPA-453/D- 93-056) dated September 1992 for control

of VOC emissions from industrial wastewater. EPA has not yet finalized the draft CTG. In April 1994, EPA published an ACT document: Air Emissions from IndustrialSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-271 Wastewater. The ACT consists of cover memo with option tables and a draft CTG. Since the draft CTG has not been finalized by EPA, District staff be lieves that it would not be appropriate to consider it for RACT determinations.

B. EPA – Alternative Control Techniques (ACT) Document

As discussed above, in April 1994, EPA published an ACT document: Air Emissions

from Industrial Wastewater. The ACT consists of cover memo with option tables and a

draft CTG. Since the draft CTG has not been finalized by EPA, District staff believes that it would not be appropriate to c onsider it for RACT determinations.

C. Standards of Performance fo r New Stationary Sources (NSPS)

40 CFR 60 Subpart QQQ (Standards of Perf ormance for VOC Emissions from Petroleum Refinery Wastewater Systems), also known as a New Source Performance Standard (NSPS) applies to petroleum refineries for which construction, modification, or reconstruction is commenced after May 4 1987. The NSPS requires a fixed roof that completely covers oil water separator tanks, slop oil tanks, storage vessels, or other auxiliary equipment with no separation between the roof and wall including certain requirements that are basically similar to Rule 4625. As an alternative to operating a fixed roof cover, the NSPS allows an operator to operate a floating roof cover provided it meets certain requirements specified in t he NSPS. Rule 4625 seal gap requirement (i.e., gap between the seal and the separator wa ll) is more stringent than specified in the NSPS. It should be noted that any tank or vessel could be subject to the VOC emission control requirements of Rule 4623 (Storage of Or ganic Liquids) depending on the tank size and the TVP of the organic liquid. Rule 4623 includes a design and operational requirements for floati ng roof tanks. Overall, Ru le 4625 is as stringent as the NSPS. There are only six facilities that operate a tota l of eight permitted oil/water separators in the District. Se ven of the eight wastewater separators are located in petroleum refineries which are subject to th e NSPS requirements by permit conditions. One is a liquid waste management company (non-re finery) wastewater separator so it is not subject to the NSPS.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

40 CFR 63 Subpart VV (National Emission Standards for Oil-Water Separators and Organic-Water Separators) require s a fixed roof or a floating roof to control emissions from wastewater separators. The design an d operational requirements for a fixed roof are essentially similar to Rule 4625. The allowable gap between the primary seal and the separator wall perimeter is 3.8 cm (1 .469 inch) and for secondary seal the gap allowance is 1.3 cm (0.5 inch). The gap allowances are greater than 0.125 inch gap allowed by Rule 4625. Based on the above di scussion, District staff believes that is as stringent as the NESHAP/MACT standards.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-272 How does District Rule 4625 compare to rules in other air districts?

District staff reviewed other nonattainment Calif ornia air districts’ rules (South Coast Air Quality Management District (SCAQMD), Ba y Area Air Quality Management District (BAAQMD), Sacramento Air Quality Management District (SMAQMD) and Ventura County Air Pollution Control District (VCAPC D) that control the VOC emissions from wastewater separators as discussed below.

A. SCAQMD Rule 1176 (VOC Emissions from Wastewater Systems), amended September 13, 1996

SCAQMD Rule 1176 requires either a fixed roof cover equipped with a closed vent system vented to a control device, or a float ing roof cover, with seals, which meets certain specific design and operational require ments. Wastewater separators with fixed roof covers are not required to be equipped with closed vent system if the hatches on covers are kept closed and free of gaps except when opened for active inspection, maintenance, sampling, or repair. This requirement is ess entially as stringent as Rule 4625 requirement for fixed roof cover requi ring all openings be sealed, and any gauging and sampling device in the cover be equipped with a cover or lid which must be in a closed position at all times except when the device is in actual use. The seal gap requirements of Rule 1176 (i .e., gap between the separator wall and the seal does not exceed 1/8 inch for a cumulative length of 97% of the perimeter the separator, and no gap between the wall and the seal must exceed 1⁄2 inch) are similar to Rule 4625.

District staff believes that the VOC control requirements of Rule 4625 are equivalent to
SCAQMD Rule 1176.

B. BAAQMD Regulation 8 Rule 8 (Organi c Compounds – Wastewater Collection and Separation Systems), amended September 15, 2004

BAAQMD Regulation 8 Rule 8 requires fixed roof covers or a floating roof covers on wastewater separators and/or forebays that meet spec ific design and operational requirements. Rule 8 fixed roof cover r equires that no gap greater than 0.32 cm (0.125 inch) to occur in the roof or between the roof and the wall. In comparison Rule 4625 does not allow any gap on the roof or betw een the roof and wall, except for breathing vents as are structurally necessary.

In lieu of a fixed cover, BAAQMD Regulation 8, Rule 8 allows the operation of a floating pontoon or double deck vapor-tight cover that mu st rest entirely on the liquid surface, and consists of a primary seal and secondar y seal. Rule 8 specifies that no gap between the wall and the primar y seal should not exceed 1.5 inch; no continuous gap greater than 0.125 inch should exceed 10% of the perimeter of the separator; the cumulative length of all primary seal gaps ex ceeding 0.5 inch should be not more than 40 percent of the perimeter. For secondar y seal, the gap between the wall and the secondary and wiper seals should not exceed 0.06 inch; the cumulative length of all secondary and wiper seal gaps exceeding 0.02 in ch should not be more than 5% of the perimeter of the separator.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-273 In comparison, Rule 4625 requires a fl oating pontoon or double deck type cover with primary and secondary seals installed and ma intained so that gaps between the compartment wall and seal should not exceed 1/8 inch (0.125 inch) for an accumulative length of 97% of the perimeter of the t ank, and should not exceed 1⁄2 inch for a cumulative length of the remain ing 3% of the perimet er of the tank. No gap between the compartment wall and the seal shall exceed 1⁄2 inch. Rule 4625 is more stringent than BAAQMD Regulation 8, Rule 8 for primary s eal (i.e., 0.125 inch for 97 percent versus 0.125 for 90 percent of the per imeter of the tank). T he difference in secondary seal gap between Rule 4625 and Rule 8 (i.e., 0.125 in ch versus 0.06 inch for secondary seal gap) is relatively small such that the overa ll VOC emissions reduction is not significantly affected. It is important to note that there are no wastew ater separators with a floating roof permitted for operation in the District.

C. VCAPCD Rule 74.8 (Refinery Vacuum Pr oducing Systems, Wastewater Separators and Process Turnarounds), amended July 5, 1983

VCAPCD Rule 74.8 prohibits the use of any distribution header or compartment of a wastewater separator unless the header or compartment is equipped with a solid cover with all openings sealed totally enclosing the compartment liquid contents except for breathing vents as are struct urally necessary, or equipped with a floating cover which

extends to within 0.125 inches of the wall of the compartment or he ader at all points on the perimeter of the cover exc ept for over a cumulative lengt h of no more than 3 percent of the perimeter; for over 3 percent of the perim eter, the cover should extend to within

0.5 inches of the wall.

In comparison, Rule 4625 requires a fl oating pontoon or double deck type cover with primary and secondary seals installed and ma intained so that gaps between the compartment wall and seal should not exceed 1/8 inch (0.125 inch) for an accumulative length of 97% of the perimeter of the t ank, and should not exceed 1⁄2 inch for a cumulative length of the remaining 3% of t he perimeter of the t ank. No gap between the compartment wall and the seal shall exceed 1⁄2 inch. Based on the above discussion,

District staff believes that the VOC control requirements of Rule 4625 are equivalent to

VCAPCD Rule 74.8.

D. SMAQMD has no rule fo r wastewater separators.

Conclusion

District staff concludes that District Ru le 4625 satisfies RACT for Wastewater Separators.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-274San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-275 

### Rule 4641 ( 

### Cutback, Slow Cure, and Emulsified Asphalt, Paving and Maintenance Operations)

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 0 0 0 0 0 0 0 0

VOC 2.3 2.3 2.3 2.3 2.4 2.4 2.4 2.7
(Source: District 2007 Ozone Plan)

District Rule 4641 Description

District Rule 4641 applies to the manufacturi ng and use of cutback asphalt, slow cure asphalt, and emulsified asphalt for paving and maintenance operations. The rule does not apply to the manufacturing of cutback as phalt or emulsified asphalt where such materials are for shipment and use outside the District. The rule prohibits manufacture for sale or use in the District for penetrating prime coat, tack coat, dust palliative, or other paving and maintenance oper ations any rapid cure cutback asphalt, medium cure asphalt, slow cure asphalt containing mo re than 0.5 % organic compounds which evaporate at 500 O F or lower, and emulsified asphalt containing more than 3% by volume organic compounds which evaporate at 500 O F. Manufacturers of cutback, slow cure, or emulsified asphalt for dust pallia tive or other road paving and maintenance operations are required to keep daily record s showing the types and amount of organiccompounds containing asphalt produced and the destination of such products. Users of such asphalt must also keep records of t he types and amount of asphalt received, and

the amounts used.

District Rule 4641 does not apply to the manufa cture of cutback asphalt or emulsified asphalt in the manufacturing of paving material s where such materials are for shipment

and use outside the District. The use of medium cure asphalt is allowed where the

National Weather Service official forecast of the high temperature for the 24 hour period following application is below 50 0 F.

How does District Rule 4641 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

EPA-450-2-77-037 (Control of Volatile Organ ic Compounds from Use of Cutback Asphalt)

This CTG establishes the recommended standar ds to control of VOC emissions from paving asphalts liquefied by petroleum distilla tes. Liquefied asphalt is generally referred to as cutback asphalt. The VOC content of cutback asphalt ranges from 20 to 50 percent by volume. VOC emissions occur as the cutback asphalt evaporates. The CTGSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-276 indicates that the control technique for reducing VOC emissions from the cutback asphalt for paving application is to substitu te an emulsifying agent or water for the petroleum distillates. Emul sified asphalt consist of asphal t suspended in water (98%) containing emulsifier (2%). “Federal RACT for cutback asphalt is defined in terms of substitution of emulsified asphalt for cutbac k asphalt, rather than in terms of emission

limit.” 14 The substitution of emulsified asphalt reduces VOC emissions by 0.78 tons per ton of slow cured asphalt, 0.209 tons per ton of medium cured asphalt, and 0.204 tons per ton of rapid cure asphalt. The CTG does not indicate any specific VOC content limits for cutback asphalt and emulsified asphalt.

Rule 4641 prohibits manufacture for sale or use in the District for penetrating prime coat, tack coat, dust pallia tive, or other paving and main tenance operations any rapid cure cutback asphalt, medium cure asphalt, sl ow cure asphalt containing more than 0.5 % organic compounds wh ich evaporate at 500 O F or lower, and emulsified asphalt containing more than 3% by volume organic compounds whic h evaporate at 500 O F. Based on the above discussion, District staff deems that District Rule 4641 is as stringent as the CTG.

In response to April 1, 2009 EPA comments recommending the District explain why Rule 4641 exempts the use of medium cur ed asphalt when the ambient temperature is

less than 50 0 F, District staff has include d the following information:

• The exemption for medium cured asphal t during colder ambient temperatures which occurs during winter (non-ozone) s eason is similar to EPA’s Blue Book on Cutback and Emulsified Asphalt reco mmended seasonal exemptions (i.e., outside of the ozone season) as opposed to temperature forecasting (e.g., applied when <50 0 F).

• During colder ambient te mperature, VOCs do not ev aporate rapidly especially from medium cured asphalt that is limited by Rule 4641 to no more than 5% organic compounds that evaporate at 500 O F.

• Road construction and road repairs usi ng asphalt are very minimal during the colder winter months, exce pt for emergency road repairs . In addition, during winter months the San Joaquin Valley experi ences the majority of rainy season and asphalt will not properly cure or harden when there is moisture on the surfaces or areas where asphalt is applied.

• District staff agrees with SCAQMD’s Te chnical Assessment for SCAQMD Rule 1108 (Cutback Asphalt), dated June 2008 that other states (Maine, Missouri, New York, Pennsylvania, and Rhode Island) who have adopted rules on cutback asphalt that prohibit their use during ozone season, but provided specific exemptions for applications they are act ually used (e.g., prime coats, stockpiled material for pothole and road patching, dus t pallatives, etc.) completely negates

14 EPA-453/R-95-010 (Beyond Volatile Organic Compound – Reasonably Available Control Technology – Control TechnIques Guidelines Requirements)San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-277 the seasonal restriction. As such, Rule 4641 exemption for medium cured asphalt during colder ambient temperatures is more stringent than the seasonal exemption recommended by the EPA Blue Book, and therefore meets RACT.

B. EPA – Alternative Control Techniques (ACT) Document

District staff’s review of the EPA ACT list in dicates that there is no ACT for cutback asphalt, slow cure asphalt, or emulsified asphalt.

C. Standards of Performance fo r New Stationary Sources (NSPS)

40 CFR 60 (Standards of Performance for New Sources) does not specify any NSPS for cutback asphalt, slow cure as phalt, and emulsified asphalt.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

40 CFR 61 (NESHAP) and 40 CFR (NESHAP for S ource Categories) do no specify any NESHAP or MACT for cutback asphalt, slow cure asphalt, and emulsified asphalt.

How does District Rule 4641 compare to rules in other air districts?

District staff compared emission limits, opti onal control requirements, and work practice standards in District Rule 4641 to comparable requirements in rules from the following

California nonattainment areas:

• South Coast AQMD Rule 1108 (Cutback Asphalt) amended February 1, 1985

• South Coast Air Quality Management Distr ict (SCAQMD) Rule 1108.1 (Emulsified Asphalt) amended November 4, 1983

• Bay Area Air Quality Management District (BAAQMD) Regulation 8 Rule 15 (Emulsified and Liquid Asphalts) amended June 1, 1994

• Sacramento Metropolitan Air Quality M anagement District (SMAQMD) Rule 453 (Cutback and Emulsified Asphalt Pavi ng Materials) amended August 31, 1982

• Ventura County Air Polluti on Control District (VCAPCD) Rule 74.4 (Cutback Asphalt) amended July 5, 1983

A. South Coast Air Quality Manage ment District (SCAQMD) Rule 1108 (Cutback Asphalt)

SCAQMD Rule 1108 prohibits the sale or offe r for sale for use in the South Coast any cutback asphalt containing more than 0. 5% by volume organic compounds which evaporate at 260 0 C (500 0 F) or lower. The rule does not apply to the use of cutback asphalt that is subject to other SCAQMD Regulation XI, or spec ifically exempted in such rules. There are no specific recordkeeping requirements in SCAQMD Rule 1108.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-278 The organic compounds limit of cutback asphal t in SCAQMD Rule 1108 is the same as the limit for slow cure asphalt in District Ru le 4641. Unlike District Rule 4641, SCAQMD Rule 1108 allows the use of cutback asphalt (r apid cure, medium cure, and slow cure) if the organic content is no more than 0. 5% by volume organic compounds which evaporate at 260 0 C (500 0 F) or lower. District Rule 4641 only allows use of medium asphalt where the National Weather Service official forecast of the high temperature for the 24 hour period followin g application is below 50 0 F. Based on the above discussion,

District staff deems that District Rule 4641 is more stringent than SCAQMD Rule 1108.

B. South Coast Air Quality Manage ment District (SCAQMD) Rule 1108.1 (Emulsified Asphalt)

SCAQMD Rule 1108.1 prohibits the sale, offe r for sale for use, or use within the air district, any emulsified asphalt containing more than 3% by volume organic compounds which evaporate at 260 0 C (500 0 F) or lower. The rule do es not apply to the use of emulsified asphalt that is subject to other SCAQMD Regulation XI, or specifically exempted in such rules. There are no spec ific recordkeeping requ irements in SCAQMD

Rule 1108.

District rule 4641 is as stringent as SCAQMD Rule 1108.1 because organic compounds content limit for emulsified asphalt are the same.

C. Bay Area Air Quality Management Di strict (BAAQMD) Regul ation 8 Rule 15 (Emulsified and Liquid Asphalts)

BAAQMD Regulation 8 Rule 15 limits the emi ssions of volatile organic compounds caused by the use of emulsified and liquid asphalt in paving materials and paving and maintenance operations. It pr ohibits the manufacture, offe r for sale, or sell a liquid asphalt which will be applied at any physical location within BAAQMD. The rule contains monitoring and recordkeeping require ments. The rule prohibits use of the following asphalt in paving material or in paving and maintenance operations:

• Rapid cure asphalt

• Medium cured asphalt (except during c ool weather (National Weather Service Forecasts atmospheric temperature fo r the 24 hour period following application

will not exceed 10 0 C (50 0 F).

• Emulsified asphalt containing petroleum solvents in excess of 3% by volume.

• Slow cure asphalt (road oil) which contai ns more than 0.5% by volume petroleum

solvents which boil at less than 260 0 C (500 0 F).

BAAQMD Regulation 8 Rule 15 prohibition s and organic compound limits for cutback asphalt (rapid cure, medium cure, and slow cu re) and emulsified asphalt are the same as District Rule 4641. BAAQMD Regulation 8 Rule 15 that allows the use of medium cure asphalt during cold weather condition is the same as the exemption in District Rule 4641. Based on the above discussion, District staff deems that District Rule 4641 is as stringent as BAAQMD Regulation 8 Rule 15.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-279 D. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 453 (Cutback and Emulsified Asphalt Paving Materials)

SMAQMD Rule 453 limits the emissions of VOC from the use of cutback and emulsified asphalt in paving materials, paving and maint enance operations. The rule prohibits the

manufacture for sale or use in Sacramento Metropolitan air district for paving, road construction or road maintenance any rapid cu re or medium cure cutback asphalt; slow cure cutback asphalt containing organi c compounds which evaporate at 260 0 C (500 0 F) or lower; and emulsified asphalt (slow cure , medium cure, and rapid cure) containing more than 3% organic com pounds which evaporate at 260 0 C (500 0 F).

SMAQMD Rule 453 does not apply to use of cutback (rapid cure and medium cure) and emulsified asphalt in the manufacturing of pa ving materials if such materials are for immediate shipment and eventual use outside of the County of Sacramento, California. The rule does not apply to the use of m edium cure cutback asphalt as a penetrating prime coat until such time that as the APCO determines that a suitable substitute

material is available.

SMAQMD Rule 453 prohibition on the use of rapid and medium cure asphalt is the same as District 4641, except that District Rule 4641 specifies that slow cure asphalt must not have more than 0.5% organi c compounds which evaporate at 500 0 F or lower while SMAQMD Rule 453 only specifies that sl ow cure asphalt must not contain organic compounds that evaporate at 500 0 F or lower. In addition, SMAQMD exempts the use of medium cure cutback asphalt as penetrating pr ime coat within their air district until a

suitable substitute material becomes availa ble while District Rule 4641 exempts use of medium cure asphalt only when the weat her temperature for the 24 hour period following application is predicted below 50 0 F. Based on the above discussion, District

staff deems that District Rule 4641 is more stringent than SMAQMD Rule 453

E. Ventura County Air Pollution Control District (VCAPCD) Rule 74.4 (Cutback Asphalt)

VCAPCD Rule 74.4 prohibits the manufacture, sa le, or offer for sale , use or application of rapid cure cutback asphalt for highway or str eet paving or maintenance, except if it is to be used as a penetrating prime coat or wh ere the National Weather Service official forecast of the high temperat ure for the 24 hour period fo llowing application is below

50 0 F (10 0 C). In the South Zone, VCAPCD Rule 74. 4 prohibits the use or application of emulsified asphalt containing more than 3% by volume petroleum solvents (diluents) or cutback asphalt for highway or street paving ma intenance. The rule prohibits the use of road oils (slow cure asphalt) containing mo re than 0.5% organic compounds which boil

at less than 500 0 F for highway or street paving or maintenance applications. VCAPCD Rule 74.4 prohibits manufacture, sale, or of fer for sale cutback asphalt for use or application within Ventur a County. VCAPCD Rule 74.4 does not have any recordkeeping requirements.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-280 Both VCAPCD Rule 74.4 and District Rule 4641 prohibits the use of rapid cure cutback asphalt, emulsified asphalt containing more t han 3% by volume petroleum solvents, slow cure asphalt that contains more t han 0.5% organic compounds which boil at less

than 500 0 F for highway or street paving or main tenance applications. District Rule 4641 allows the use of medium cure asphalt only if the official weather forecast of the high temperature for the 24 hour period following application is below 50 0 F (10 0 C), but

VCAPCD Rule 74.4 allows the use or application of cutback asphalt if it is to be used as a penetrating prime coat or where t he weather forecast is below 50 0 F (10 0 C) the 24 hour period following application. Distric t Rule 4641 has recordkeeping requirements

while VCAPCD Rule 74.4 has none. Bas ed on the above discussion District staff

deems District Rule 4641 is more stri ngent than VCAPCD Rule 74.4.

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, Distric t staff concludes that District Rule 4641 satisfies RACT for cutback and emulsified asphalt.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-281 

### Rule 4642 – Solid Waste Disposal Sites

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

VOC 1.6 1.7 1.8 1. 8 1.9 1.9 2.0 2.1
(Source: District 2007 Ozone Plan)

District Rule 4642 Description

The purpose of this rule is to reduce vo latile organic compound (V OC) emissions from solid waste disposal sites. The rule applies to any solid waste disposal site which has a gas collection system and/or c ontrol device in operation, or undergoing maintenance or repair. The rule exempts active disposal areas in a landfill, landfills which are subject to the requirements of 40 CFR 60 Subpart WWW (S tandards of Performance for Municipal Solid Waste Landfills), or Subpart Cc (Emi ssion Guidelines and Compliance Times for Municipal Solid Waste Landfil ls), and hazardous waste disposal sites. Temporary exemption is also provided during maint enance of the landfill gas collection system

and/or control device.

The rule requires that the landfill gas collection system be operated in such a manner

that landfill surface VOC concentrations sha ll not exceed 1,000 ppmv at any point. The rule requires landfill gas to be treated with a control dev ice that achieves a VOC destruction efficiency of at least 98 per cent by weight, or reduces the VOC concentration to 20 ppmv or less (measured as Methane) corrected to 3 percent oxygen. For facilities which received Author ities to Construction prior to the rule adoption date (July 20, 1995), the rule require s the control device to achieve a VOC destruction efficiency of at least 90 percen t, or reduce the VOC concentration to 30

ppmv.

The rule also requires that whenever buried solid waste is brought to the surface during the installation or preparation of wells, trenches, piping, or other equipment or when landfill solid waste is excavated or moved, the operator shall cover the excavated solid waste using fresh soil, plastic sheeting, or va por retarding foam as necessary in order to prevent odorous emissions and to mini mize the release of landfill gas.

The rule allows the control system to be shut down for up to 144 hours per year for

maintenance.

Initial source testing is required to demonstr ate the destruction efficiency of the landfill gas control system. Annual source testing is also required to measure landfill surface

VOC concentrations.

Records are required to be retained for a period of 5 years.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-282 How does District Rule 4642 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

There is no CTG for this source category.

B. EPA – Alternative Control Technology (ACT)

There is no ACT for this source category.

C. Standards of Performance fo r New Stationary Sources (NSPS)

1. 40 CFR 60 Subpart Cc - Emission Guide lines and Compliance Ti mes for Municipal
Solid Waste Landfills.

This NSPS applies to landfills that were in existence prior to May 30, 1991. The NSPS requires the control of landfill emissions from landfills that have accepted waste at any time since November 8, 1987 or have additi onal design capacity available for future waste deposition; have a design capacity greater than or equal to 2.5 million megagrams and 2.5 milli on cubic meters; and have a nonmethane organic compound emission rate of 50 megagrams per year or more. Landfills meeting these conditions are required to install a landfill gas collection and control system meeti ng the specifications of 40 CFR 60.752(b)(2)(ii), which are summarized below:

• Collection systems shall be designed to handl e the maximum expected gas flow rate

from the entire area of the landfill; collect gas from each area, ce ll, or group of cells

in the landfill in which the initial solid waste has been plac ed for a period of 5 years or more if active (2 years or more if closed or at final grade); collect gas at a sufficient extraction rate; and be designed to minimize off-si te migration of subsurface gas. In addition, passive coll ection systems must al so be installed with

liners on the bottom and all sides in all areas in which gas is to be collected.

• Collected landfill gas shall be treat ed by one of the following methods:

(1) an open flare designed and operated in accordance with 40 CFR 60.18.

(2) a control system designed and operated to reduce NMOC by 98 weight-percent, or, when an enclosed combustion device is used for control, to either reduce NMOC by 98 weight percent or reduce the outlet NMOC concentration to less than 20 parts per million by volume, dry bas is as hexane at 3 percent oxygen.

(3) a treatment system that processes the collected gas for subsequent sale or use.

The gas collection system must be operat ed in such a manner that the methaneSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-283 concentration on the landfill surf ace does not exceed 500 ppmv.

The control system must be operat ed at all times when gas is routed to it. In the event the control system is inoper able, the gas mover system shall be shut down and all valves in the collection and control system co ntributing to venting of the gas to the atmosphere shall be closed within one hour.

Landfills below the capacities specified by the NSPS are required to perform initial design capacity and annual emissions calculations to demonstrate continued exemption.

An initial source test is r equired to demonstrate the destruction efficiency of the control system.

For the purpose of demonstrating whether t he gas collection system flow rate is sufficient, the owner or operator shall m easure gauge pressure in the gas collection

header at each individual well.

For the purpose of identifying wh ether excess air infiltration in to the landfill is occurring, the owner or operator shall monitor each well monthly for temperature and nitrogen or

oxygen.

The owner or operator shall monitor surfac e concentrations of methane on a quarterly basis using an organic vapor analyzer, flame i onization detector, or other portable

monitor.

The owner or operator shall implement a pr ogram to monitor for cover integrity and implement cover repairs as necessary on a monthly basis.

District Rule 4642 is compared to 40 CFR 60 Subpart Cc under the following categories:

Applicability/Exemptions :

40 CFR Subpart Cc applies to landfills that were constructed or modified prior to May 30, 1991. Control of landfil l emissions at each landfill that meets the following conditions is required by Subpart Cc: (a) Th e landfill has accepted waste at any time since November 8, 1987, or has additional design capacity available for future waste deposition; (b) The landfill has a design capa city greater than or equal to 2.5 millionmegagrams and 2.5 million cubic mete rs. The landfill may calculate design capacity in either megagrams or cubic meters with the same exemption values; (c) The

landfill has a NMOC emission rate of 50 me gagrams per year or more. Subpart Cc requires operators of landfills with a desi gn capacity less than 2.5 million megagrams by mass or 2.5 million cubic meters, by volume, to submit an initial de sign capacity report. For landfills with a design capacity equal to or greater than 2. 5 million megagrams and 2.5 million cubic meters, operators are requi red to calculate the non-methane organic compounds (NMOC) using t he prescribed methodology. If the calculated NMOCSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-284 emission rate is less than 50 megagrams per y ear, the operator must submit an annual report and then keep recalculating the emissi on rate annually until such time as the emission rate is equal to or greater than 50 megagrams per year. If the NMOC emission rate, upon recalculation, is equal to or greater than 50 megagrams per year, the operator must install a collection and control system that complies with the requirements specified in Subpart Cc. Comp liance schedules are also specified in Subpart Cc.

In comparison with 40 CFR 60 Subpart Cc, Rule 4642 applies to landfills which have a gas collection and control device regardless of the design capacity and the date that the

landfill was constructed or modified. It is important to mention t hat when Rule 4642 was adopted in July 1995, District staff took into consideration that in order to prevent

excessive methane accumulation (i.e., 1.25% by volume in air) within any portion of any

on-site structure and in on-site structures an d more than 5% by volume in air at the disposal site facility boundary, Title 27 of the California Code of Regulations (CCR) requires the operation of a gas collection and control system. Landfills subject to CCR Title 27 are also required to comply with the requirements for explosive gas control, gas monitoring and control, perimet er monitoring well construc tion, structure monitoring, parameter monitoring, moni toring frequency, reporting and control of excessive gas concentration, and other requirem ents. Therefore, to avoid duplication or overlapping of state regulatory requirements, Rule 4642 was adopted so it app lies to landfills that have gas collection and control system with the assumption that landf ills that are permitted by the state Integrated Waste M anagement Resources are already rigorously regulated by CCR Title 27. Likewise, the exemption for l andfills subject to Subparts Cc or WWW are intended to avoid duplication or overlappi ng of regulatory requirements imposed by federal and District regulations. Rule 4642 exempts hazardous disposal sites because they are already subject to more stringent District operating permit requirements than specified in the rule.

Under Rule 4642, any landfill surface emi ssions exceeding 1,000 ppmv (measured as methane by a portable hydrocarbon analyzer) at any point in the landfill would

necessitate the installati on and operation of a Distric t approved gas collection and control system. Based on the above discussion, District staff believes that Rule 4642 applicability is slightly more st ringent than Subpart Cc applicability.

Requirements :

District staff believes that Rule 4642 is as stringent as 40 CFR 60 Subpart Cc under the following requirements:

As stated above, Rule 4642 appli es to landfills that have a gas collection and control system regardless of the design capacity and the date the landfill was constructed or modified compared to Subpart Cc which applies only to landfills having a specified a design capacity and specific construct or m odification date. Although District Rule 4642 does not require design capacity calculat ion and annual emissions calculation forSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-285 landfills that do not have collection and c ontrol devices, District staff expects that

landfills which an excessive surface emissions exceeding 1,000 ppmv would necessitate the operation of a gas collecti on and control system to lower the emissions

below the threshold.

Although District Rule 4642 requires a much lower destruction efficiency of 90% (or reduction of VOC concentrations to 30 ppmv) for control systems that were permitted prior to July 20, 1995, in comparison with 98% control system or 20 ppmv VOC outlet concentration required by Subpart Cc, it shou ld be noted that, in general, VOC control devices such as flares, thermal oxidizer, co mbustion devices (engines, turbines, boilers) that have a high combustion temperature and longer residence times actually achieves at least 98% VOC destruction efficiency. A review of the District Permit database

indicated that landfills with a gas collection and control system are actually required to operate at least 98% destruction efficiency or reduce the VOC concentration to 20 ppmv or less, as a condition of the operating permit. Therefore, Rule 4642 is as stringent as Subpart Cc control device efficiency.

District Rule 4642 requires that a gas colle ction and control system be operated in such

a manner that the surface emissions testi ng of the landfill does not exceed 1,000 ppmv (measured as methane) at any point on the su rface of the landfill or along the gas transfer path. Surface emission testi ng should be performed with by holding the portable hydrocarbon detector probe within three inches of the surface of the landfill and further specifies the wind speed whereby surface emission testing should be terminated. In comparison, Subpart Cc re ferenced the operational standards specified in Subpart WWW that must be me t for landfills that exceed t he applicability threshold for operating a collection and control system. S ubpart WWW specified that the collection system must be operated so t hat the concentration is le ss than 500 ppmv (measured as methane above background) with the detector probe placed within 5 to 10 centimeters of the ground. Based on District Compli ance Division staff’s experience, leak measurements taken at a great er distance from the surface of potential leak source

tend to result in lower emission concentration level due to ambient air dilution compared to higher concentration readings taken very cl ose to the leak surface. For this reason,

District staff believes that Rule 4642 emissi on threshold of 1,000 ppmv measured within

3 inches of the landfill surface is at least as stringent as Subpart CC’s 500 ppmv

measured at 5 to 10 centimeter s from the landfill su rface. In addition, Subpart Cc does not specify any wind velocity for terminating testing but Rule 4642 requires termination of surface emissions testing when the av erage wind speed exceeds five miles per hour because excessive wind velocity affects the re sult of emissions testing. Based on the above discussion, District staff believes that Rule 4642 surface emission threshold is more stringent than Subpart Cc.

District Rule 4642 allows for shutdown of the gas collection and control system for maintenance purposes provided the Distric t is notified at least 24 hours before performing any maintenance work, that the emissi ons of landfill gas into the atmosphere is minimized during shutdown, and that the gas collection and control system should not

be shutdown for more than 144 cumulative hours in any calendar year. In comparison,San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-286 Subpart Cc allows deviation from emissi on standards during perio ds of start-up, shutdown, or malfunction provided the dur ation does not exceed 5 days for collection system and one hour for treatment or control devices. District staff believes that Rule

4642 limited duration for such maintenance allo wance on an annual basis is as stringent as provided by Subpart Cc which does not have any limitation on the frequency of startup, shutdown, or malfunction.

Source Testing :

There is no significant difference between District Rule 4642 and 40 CFR 60 Subpart Cc under this category.

Monitoring :

40 CFR 60 Subpart Cc in monitoring requirem ents. District Rule 4642 does not require collection header pressure monitoring, m onthly well temperature/Nitrogen/Oxygen monitoring, or cover integrity monitoring. Such monitoring requirements appears to be directed at ensuring that the elevated parameters do not cause fires (excess air infiltration) or significantly inhibit anaerobi c decomposition by killing methanogens. In comparison, Rule 4642 requires an operator to submit an Emission Control Plan which includes, among other things, an engineering evaluation of the expected landfill gas generation rate and design specifications wh ich demonstrate that the gas collection system will meet the requi rements of the rule, description of techniques used to ensure that excess vacuum and gas withdrawal result ing in air intrusion into the landfill are minimized. Although Rule 4642 does not have identical monito ring requirements,

District staff believes that the Emission Control Plan requirements are accomplish

similar concerns for which the above-ment ioned parametric monitoring required by Subpart Cc.

Record Keeping :

There is no significant difference between District Rule 4642 and 40 CFR 60 Subpart Cc under this category.

Based on the above discussion, District staff believes that overall Rule 4642 is as stringent as 40 CFR 40 Subpart Cc.

2. 40 CFR 60 Subpart WWW - Standards of Pe rformance for Municipal Solid Waste

Landfills.

This NSPS applies to solid waste landfills that commenced construction, reconstruction

or modification on or after Ma y 30, 1991. All requirements ar e similar to those discussed under 40 CFR 60 Subpart Cc.

The District implements 40 CFR 60 Subpart WWW by reference under District Rule 4001, New Source Performance Standards . A comparison between District Rule 4642San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-287 and 40 CFR 60 Subpart WWW is therefore not requi red since there is no overlap between sources covered by Rule 4642 (landfills in existence prior to May 30, 1991) and those covered by 40 CFR 60 Subpart WWW (landfills constructed or modified on or after May 30, 1991).

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

There is no NESHAP that could apply to solid waste disposal sites.

There is one MACT standard that applies to solids waste disposal sites – 40 CFR 63 Subpart AAAA National Emission Standards for Hazardous Air Pollutants from Municipal Solid Waste Landfills. This MACT onl y requires that affected sources comply with the requirements of t he NSPS. No different standard that could define an applicable RACT for solid waste disposal sites is provided, hence no analysis is required.

How does District Rule 4642 compare to rules in other air districts?

District staff compared emission limits, opti onal control requirements, and work practice standards in District Rule 4642 to comparable requirements in rule s from the following

California nonattainment areas:

• South Coast AQMD Rule 1150 (adopted 10/15/1982)

• South Coast AQMD Ru le 1150.1 (amended 3/17/2000)

• Bay Area AQMD Regulation 8 Rule 34 (amended 6/15/2005)

• Ventura County APCD Rule 74-17-1 (revised 2/9/1999)

• Sacramento Metro AQMD Rule 485 (amended 7/23/1998)

A. South Coast AQMD Rule 1150

South Coast AQMD Rule 1150 (Excavation of Landfill Sites) requires the submission of an Excavation Management Plan primarily to prevent nuisanc e conditions. Although this rule does not have a specific standard for VOC emissions, the mitigation measures required for the prevention of nuisance conditi ons also reduce VOC emissions. The rule states that mitigation measures such as gas collection and disposal, baling, encapsulation, covering of the material, c hemical neutralizing, or other measures approved by the Executive Officer may be required.

District Rule 4642 is compared to South Coast AQMD Rule 1150 under the following categories:San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-288 Applicability/Exemption :

District Rule 4642 is less stringent than Sout h Coast AQMD Rule 1150 because it applies only to landfills that were in exis tence prior to May 30, 1991 and have collection and control systems, whereas S outh Coast AQMD Rule 1150 applies to all landfills.

Requirements :

There is no significant difference in requi rements between District Rule 4642 and South Coast AQMD Rule 1150. Both rules require mitigation measures such as covering using fresh soil, plastic sheeting, or vapor retard ing foam as necessary in order to prevent odorous emissions that may cause a public nuisance.

Source Testing, Monitori ng and Record Keeping :

There are no source testing, monitoring or record keepi ng requirements associated with

landfill excavations.

B. SCAQMD Rule 1150.1

South Coast AQMD Rule 1150.1 (Control of Gaseous Emissions From Municipal Solid Waste Landfills) requires the installation of a collection and control system capable of reducing VOC emissions by at least 98 perc ent by weight or r educing the outlet VOC concentration to less than 20 parts per million by volume (ppmv), dry basis as hexane at 3 percent oxygen. The rule also requires land fill boundary probes and a limit of 5% by volume (50,000 ppmv) for subsurface re fuse boundary VOC concentrations. The rule

has two limits for landfill surface emissi ons: (1) 50 ppmv (as determined by portable integrated bag sampler and lab analysis) for any one 50,000 square foot landfill grid and (2) 500 ppmv (as determined by instantaneous monitoring using FID probe) at any

location on the landfill. The rule has si x main monitoring requirements: (1) annual source testing of landfill gas control system (2) monthly sampling and analysis of landfill gas entering control system (3) monthl y sampling and lab analysis for each 50,000 square foot grid of landfill (4) quarterly in stantaneous FID probe sampling for any spot on landfill surface (5) m onthly boundary ambient air sa mpling and (6) monthly subsurface boundary probes sampling.

District Rule 4642 is compared to South Coast AQMD Rule 1150.1 under the following categories:

Applicability/Exemption :

District Rule 4642 applies to landfills that have a gas collection and control system regardless of whether the landf ills are active or inactive status and date the landfills have received waste. Rule 4642 exempts landfills that are subject to 40 CFR 60 Subpart Cc and Subpart WWW and haz ardous waste disposal sites. It is important to

mention that when Rule 4642 was adopted in July 1995, District staff took intoSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-289 consideration that in order to prevent ex cessive methane accumulation (i.e., 1.25% by volume in air) within any portion of any on-si te structure and in on-site structures and more than 5% by volume in air at the dis posal site facility boundary, Title 27 of the California Code of Regulations (CCR) r equires the operation of a gas collection and control system. Landfills subject to CCR Title 27 are also required to comply with the requirements for explosive gas control, gas monitoring and control, perimeter monitoring well construction, structure monitoring, par ameter monitoring, monitoring frequency, reporting and control of excessive gas c oncentration, and other requirements. Therefore, to avoid duplicati on or overlapping of state r egulatory requirements, Rule 4642 was adopted so it applies to landfills th at have gas collection and control system with the assumption that landfills that ar e permitted by the st ate Integrated Waste Management Resources are already rigorously regulated by CCR Title 27. Likewise, the exemption for landfills t hat are subject to Subparts Cc or WWW are intended to avoid duplication or overlappi ng of regulatory requirements imposed by federal and District regulations. Rule 4642 exempts hazardous disposal sites because they are already subject to more stri ngent District operating permit requirements than specified in the rule. Rule 4642 exempts hazardous disposal sites because they are already subject to more stringent District operating permit re quirements than specified in the rule.

SCAQMD Rule 1150.1 applies to active and inactive landfills. Rule 1150.1 defines

active landfills as landfills that have rece ived waste on and after November 8, 1987.

Inactive landfills are those where wastes had been disposed of before November 8, 1987. Rule 1150.1 exempts landf ills that operates a collect ion system such that the total organic compounds (TOC), measured as methane, do not exceed 5% by volume subsurface boundary sampling probes, and does not exceed 50 ppmv as determined by integrated samples taken on a numbered 50,000 s quare foot landfill grids, and does not exceed 500 ppmv above background by instant aneous monitoring at any location on the landfill. The rule also exempts landfills that emit less than 55 tons per year of nonmethane organic compounds and those that are in compliance with SCAQMD

Nuisance Rule 402.

Based on the above discussion, District staf f believes that the applicability and exemptions of District Ru le 4642 are as stringent as SCAQMD rule 1150.1

Requirements :

District Rule 4642 allows a VOC destruction e fficiency of 90% (or a VOC reduction to 30 ppmv or less) for landfill gas control equipm ent permitted before July 20, 1995, and a destruction efficiency of at least 98% (or a VOC reduction to 20 ppmv or less) for all other permitted control equipment . SCAQ MD Rule 1150.1 requires a destruction efficiency of 98% (or reduction to 20 ppmv) for all landfill gas control systems.

As discussed above, although District Rule 4642 does not have any requirements for subsurface landfill boundary VOC limits, District staff relied on the premise that landfills operating in the San Joaquin Valley air basin are already required to comply with CCR Title 27 which, among other requirements, include subsurface and boundary monitoring, recordkeeping, and reporting for specified landfill gas emissions. SCAQMD Rule 1150.1San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-290 requires the use of subsurface landfill bo undary sampling probes and a subsurface landfill boundary VOC limit of 5% by volume.

District Rule 4642 requires a landfill surface VO C emission concentration limit of 1,000 ppmv or less, whereas South Coast AQMD Rule 1150.1 requires the higher limits of 50 ppmv measure by integrated sample on an y 50,000 square foot grid and 500 ppmv instantaneous sample taken at an y point on the landfill surface.

District Rule 4642 does not specifically have any requirement for the cessation atmospheric venting of landfill gas when the control system is inoperable, whereas South Coast AQMD Rule 1150.1 requires that when the treatment or control system is inoperable the gas conveying system and all valves in th e collection, treatment and control system contributing to venting of t he gas to the atmosphere shall be shut down within one hour. However, District rule 4642 has specific requirements that the gas collection and control system be operated in a m anner which maximizes the amount of landfill gas extracted while preventing overdraw causi ng fires or damage to the collection system as well as minimizing em issions of landfill gas during maintenance, start-up, or shutdown.

Source Testing and Monitoring :

District Rule 4642 does not require any source testing of monitoring of subsurface landfill boundary emissions, w hereas South Coast AQMD Ru le 1150.1 requires monthly sampling and lab analysis of subsurface l andfill boundary emissions. However, it is important to mention that Distr ict staff relied on the premise t hat landfills operating in the San Joaquin Valley air basin are already required to comply with CCR Title 27 which, among other requirements, include subsurface and boundary monitoring, recordkeeping, and reporting for specified landfill gas emissions. Such requirements are not included in Rule 4642 to avoid duplic ation of state regul atory requirements.

District Rule 4642 requires semi-annual (annual after two successful tests) FID probe sampling of landfill surface emissions, w hereas South Coast AQMD Rule 1150.1 requires monthly integrated sampling and la b analysis for the 50,000 square foot grid VOC limit of 50 ppmv, and quarte rly instantaneous probe sampling for the overall landfill surface limit of 500 ppmv without any specific reference to the wind speed. Although Rule 4642 has a 1,000 ppmv surface emission limi t, it is important to mention that such readings are required to be taken when t he average wind speed does not exceed 5 miles per hour or the instantaneous wind speed does not exceed 10 miles per hour.

District Rule 4642 does not require landfill gas or ambient air testing/monitoring,
whereas South Coast AQMD Rule 1150.1 r equires monthly sampling and lab analysis for both landfill gas and ambient air.

Record Keeping :

The is no significant difference between the tw o rules under this category. Both rules require record maintenance for a period of 5 years.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-291 Based on the above discussion, District staff believes that overall District Rule 4642 is as stringent as SCAQMD Rule 1150.1. analysis is required to determine whether t he stricter requirements of South Coast AQMD Rule 1150.1 should be incorporated in to District Rule 4642 for RACT purposes. A cost effectiveness and feasibility analysis is required to determine whether the stricter requirements of 40 CFR Subpart Cc should be incorporated into District Rule 4642 for RACT purposes.

Because of the extent of the differenc es between District Rule 4642 and South Coast AQMD Rule 1150.1, it is preferable that the required analysis be conducted under the context of a rule amendment process.

C. Bay Area AQMD Re gulation 8 Rule 34

Bay Area AQMD (BAAQMD) Regulation 8 Rule 34 (Solid Waste Disposal Sites) applies to Methane and VOC emissions from solid waste disposal sites.

The rule exempts old and inactive landfills (those that stopped accepting solid waste before November 8, 1987) and small landfills (those with an in in-place tonnage of less than 907,194 megagrams (1,000,000 tons) of decomposable solid waste, and a maximum design capacity of less than 2. 5 million megagrams (2, 755,000 tons) or less

than 2.5 million cubic meters ; or emit less than 50 megagr ams of VOC per year). Control requirements do not apply during system s shutdowns, as long as shutdowns do not exceed 240 hours per year, and emission s into the atmosphere are minimized. Requirements are also no applicable during we ll raising, system component repairs and

other construction activities.

The rule requires the use of a landfill gas collection and control system that reduces VOCs by 98 percent by weight, or reduces VOCs to less than 120 ppmv at the outlet, and limits component leaks to 1,000 ppmv. Landfill surface VOC concentrations are limited to 500 ppmv. The rule requires each gas wellhead to operate under vacuum, and provides specifications for wellhead te mperature, nitrogen and oxygen levels.

Exempt landfills are required to submit des ign capacity and emission rate reports to demonstrate their exemption status.

Required monitoring requirements include annual source testing for the control system, quarterly testing for collection equipment l eaks, monthly well-head monitoring, quarterly monitoring of landfill surface emissions, cont inuous temperature monitoring for flares, gas flow meter for inlet into control devic e and monthly monitoring of landfill surface cover integrity.

District Rule 4642 is compared to BAAQMD R egulation 8 Rule 34 under the following categories:San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-292 Applicability/Exemption :

District Rule 4642 is more stringent than BAAQMD Regulation 8 Rule 34 because Rule 4642 applies to landfills which have a gas collection and control system regardless of the age and design capacity of the landfill, wher eas Rule 34 applies only to landfills that accepted waste after November 8, 1987. In addition, Rule 34 contains numerous landfill exemptions (e.g., inactive or closed landfills, small design capacity landfills, low emission landfills, permanent shut down of collection and cont rol system, etc.), whereas Rule 4642 only exempts landfills subject to 40 CFR 60 Subparts Cc and WWW or hazardous waste landfills as previously discussed above.

Requirements :

District Rule 4642 requires a landfill surface emission limit of 1,000 ppmv, measured, as methane, with a portable hydr ocarbon analyzer with the detec tor probe within 3 inches of the surface, whereas BAAQMD Rule 34 requires a 500 ppmv above background. Rule 34 defines background as ambient concentration of total organic compounds determined at least 3 meters upwind of the source to be inspected, whereas District Compliance generally considers background as a distance of 2 meters upwind of the source of the leak. In addition, Rule 4642 surface emission measurement is taken

within 3 inches of the landfil l surface while Rule 35 emissi on limit does not include any specific distance measuremen t. Based on District Complianc e staff’s field experience, leak measurements based on greater backg round distance and instrument probe tip

distance from the leak surface are less stri ngent even though the leak limit is 500 ppmv when compared to 1,000 ppmv measured at a lesser background distance and closer

distance from leak surface.

BAAQMD Rule 34 an emission control system wh ich reduces the amount of NMOC by at least 98% or emit less than 120 ppmv (co rrected to 3% oxygen) of NMOC at the outlet. In contrast, District Rule 4642 is mo re stringent because the control efficiency is 98% control efficiency or a VOC concent ration reduction of 20 ppmv or less.

Source Testing and Monitoring :

District Rule 4642 requires semi-annual (annual after two successful tests) FID probe sampling of landfill surface emissions, w hereas Bay Area AQMD Regulation 8 Rule 34 requires quarterly sampling.

Bay Area AQMD Regulation 8 Rule 34 requires quarterly testing for equipment leaks. District Rule 4642 requires semiannual surface emission testing which includes leak measurements along the gas transfer path of the gas and coll ection system. Leak measurement of the gas tr ansfer path (which also includes any components and equipment) is deemed equivalent to Rule 34 equipment leak testing requirement.

District Rule 4642 does not require landfill su rface cover monitoring, whereas Bay Area AQMD Regulation 8 Rule 34 requires monthly monitoring of surface cover integrity.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-293 However, Rule 4642 surface emission test ing is adequate such that any crack or degradation in the integr ity of the surface cover that results to a emission level exceeding the threshold would need to be repair ed/replaced so as to lower the leak to

below the threshold.

District Rule 4642 does not require well-he ad monitoring, whereas Bay Area AQMD Regulation 8 Rule 34 requires monthly well-head m onitoring. However, it is important to mention that in developing Ru le 4642, District staff relied on the premise that landfills operating in the San Joaquin Valley air basin are already required to comply with CCR Title 27 which, among other requirements, include subsurface and boundary monitoring, monitoring well construction and monitoring frequency, recordkeeping, and reporting for specified landfill gas emissions. Such requirements are not included in Rule 4642 to avoid duplication of state regulatory requirements.

Record Keeping :

The is no significant difference between the tw o rules under this category. Both rules require record maintenance for a period of 5 years.

Based on the above discussion, District staff believes that District Rule 4642 is as stringent as BAAQMD regulation 8 Rule 34.

D. Ventura County APCD Rule 74-17-1

Ventura County APCD Rule 74-17-1 (Municipal Solid Waste Landfills) applies to landfills

that were in existenc e prior to May 30, 1991.

The rule requires affected landfill with a design capacity equal to or greater than 2.5 million megagrams and 2.5 million cubic meters, and a NMOC emission rate of 50 megagrams per year, or more than 500,000 tons of degradable waste in place, to comply with 40 CFR 60 Subpart WWW.

In addition, the rule requires that NOx emissi ons from flares used as landfill gas control devices shall not exceed 0.06 lb/MMBtu of heat input.

Applicable source testing, monitoring and record keeping requirements those from 40 CFR 60 Subpart WWW.

District Rule 4642 is compared to Ventura County APCD (VCAPCD) Rule 74-17-1

under the followin g categories:

Applicability/Exemption :

District Rule 4642 is more stringent than VCAPCD Rule 74-17-1 because Rule 4642 applies to landfills which have a gas collect ion and control system r egardless of the age and design capacity of the landfill, whereas Rule 74-17-1 applies to landfills that were in existence prior to May 30, 1991 and landfills that have acc epted waste since NovemberSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-294 8, 1987 or has additional design capacity available for future waste deposition. Similar to Rule 4642, Rule 74-17-1 also exempts land fills subject to 40 CFR 60 Subpart WWW.

Requirements :

VOC requirements for VCAPCD Rule 74-17-1 are similar to 40 CFR 60 Subpart WWW requirements. Since a comparison between District Rule 4642 and 40 CFR 60 Subpart WWW has already been conducted, additional analysis is not necessary. However, it should be noted that Subpar t WWW does not specify the frequency of conducting

landfill surface emission te sting, whereas District Rule 4642 requires semiannual testing.

District Rule 4642 allows for shutdown of the gas collection and control system for maintenance purposes provided the Distric t is notified at least 24 hours before performing any maintenance work, that the emissi ons of landfill gas into the atmosphere is minimized during shutdown, and that the gas collection and control system should not

be shutdown for more than 144 cumulative hours in any calendar year. In comparison, Subpart WWW allows deviation from emission standards during periods of start-up, shutdown, or malfunction provided the dur ation does not exceed 5 days for collection system and one hour for treatment or control devices. District staff believes that Rule

4642 limited duration for such maintenance allo wance on an annual basis is as stringent as provided by Subpart WWW which does no t have any limitation on the frequency of start-up, shutdown, or malfunction.

District Rule 4642 does not have any NOx emi ssion limits for flares used as control devices, whereas VCAPCD Rule 74-17-1 has a NOx emission limit of 0.06 lb/MMBtu for landfill gas control flares. However, Distr ict staff’s review of the Permit database, indicates that permitted flares operated in landfills have NOX limits similar to Rule 74-

17-1.

Source Testing, Monitori ng and Record Keeping :

Applicable source testing and monitoring requirements for VCAPCD Rule 74-17-1 are those for 40 CFR 60 Subpart WWW. A com parison between District Rule 4642 and 40 CFR 60 Subpart WWW has already been conduct ed, hence additional analysis is not

necessary

Based on the above discussion, District staff believes that overall Rule 4642 is more stringent than VCAPCD Rule 74-17-1

E. Sacramento Metro AQMD Rule 485

The purpose of this rule is to implement the requirements of 40 CFR 60 Subpart Cc. A comparison between District Rule 4642 and 40 CFR 60 Subpart Cc has already been conducted, hence additional analysis is not required.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-295 Conclusion

After evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, District staff concludes that District Rule 4642 meets RACT for Municipal Waste Disposal Sites.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-296 

### Rule 4651 – Soil Decontamination Operations

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

VOC 0.11 0.11 0.12 0. 12 0.14 0.14 0.15 0.75
(Source: District 2007 Ozone Plan)

District Rule 4651 Description

The purpose of this rule is to reduce vo latile organic compound (V OC) emissions from

soil that has been contaminated with a VOC-containing liquid. This source category includes all activities involving the remediat ion of contaminated soils. Soil contamination from organic material occurs due to l eaking storage and handli ng systems, operating losses, and accidental spills.

The rule exempts the followin g categories: (a) excavation , handling, transportation, and decontamination of less than one (1) cubic yard of contaminated soil per occurrence; (b) operations related to the accidental spillage of up to 42 gallons of VOC-containing liquid per occurrence; (c) contaminated soil expos ed for the sole purpose of sampling; and (d) soil contaminated solely by a known VOC-cont aining liquid or a petroleum liquid that has an initial boiling point of 302°F or higher.

The rule requires a written notice to be provided to the APCO, except for emergency excavations, prior to commencement of ex cavation of possibly contaminated soil. A notice must also be provided within 48 hours of detection of contaminated soil and a written verification of completion of the ex cavation must be provided within 30 days of the completion.

The rule requires VOC monitoring every 15 minutes during excavation of contaminated soils, except during emergency excavations. Contaminated soil shall be sprayed with water or vapor suppressant and covered with plastic sheeting or a 6-inch layer of

uncontaminated soil. Piles of contaminated soil must be covered if they have been inactive for more than one hour. For emergency excavations, contaminated soil must be covered within 24 hours. Stockp iles of contaminated soil mu st be inspected every 24 hours (except when operators are not on-site fo r more than 24 hours) to ensure integrity of the covering. Contaminated soil must be decontaminated, recycled, or disposed of in an approved facility within 30 days.

The rule requires that soils contaminated with a VOC concentratio n of 1,000 ppm or greater shall be sprayed with water or v apor suppressant and placed in sealed containers or transported to a treatment facilit y within 30 minutes after excavation. Contaminated soil must be covered during tr ansportation. VOC emissions from in onsite decontamination of cont aminated soil shall be controlled by a VOC collection andSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-297 control device with a VOC destruction or remova l efficiency of at least 95%. The rule prohibits aeration of contaminated soil.

Decontaminated soil must be m onitored for VOC concentrati ons before proper disposal or return to decontamination process, depending on the VOC readings. Lab analysis of VOC concentrations is required for decontam inated soil that is to be treated as

uncontaminated.

Record keeping is required for VOC moni toring readings during excavations, daily inspection of contaminated soil cover, VO C concentration readings for decontaminated soil, and chain of custody for transporta tion and transfer of contaminated soil.

How does District Rule 4651 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

There is no CTG for this source category.

B. EPA – Alternative Control Technology (ACT)

There is no ACT for this source category.

C. Standards of Performance fo r New Stationary Sources (NSPS)

There is no NSPS for this source category.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

There is no NESHAP or MACT for this source category.

How does District Rule 4651 compare to rules in other air districts?

District staff compared emission limits, opti onal control requirements, and work practice standards in District Rule 4651 to comparable requirements in rule s from the following

California nonattainment areas:

• South Coast AQMD Rules 1166 (amended 5/11/2001)

• Bay Area AQMD Regulation 8 Rule 40 (amended 6/15/2005)

• Sacramento Metro AQMD (no applicable rule)

• Ventura County APCD Rule 74-29 (revised 4/8/2008)San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-298 A. South Coast AQMD Rule 1166

South Coast AQMD Rule 1166 (Volatil e Organic Compound Emissions from Decontamination of Soil) appl ies to the emission of Vola tile Organic Compounds (VOC) from excavating, grading, handl ing and treating VOC-contaminat ed soil as a result of leakage from storage or trans fer operations, accidental sp illage, or other deposition.

The following categories are ex empt: (a) excavation, handling, and treating of less than one (1) cubic yard of contaminated soil; (b ) removal of soil for sampling purposes; (c) accidental spillage of 5 gallons or less of VOC-containing material; and (d) emergency

excavations.

The rule requires monitoring for VOC contamination every 15 minutes during excavation, and contaminated soil to be sprayed with water and/or approved vapor suppressant and covered with plas tic sheeting. A daily visual inspection of all covered VOC contaminated soil stockpiles is required to ensure the integrity of the covering. The

contaminated soil must be treated or removed from an excavation or grading site within 30 days.

The rule requires that soil contaminated with a VOC concentration measuring more than 1000 ppm be sprayed with water or vapor suppr essant and placed in sealed containers or loaded into covered trucks for transporta tion offsite within 15 minutes. The rule requires that the treatment of contaminated soil shall be done using control equipment meeting Best Available Control Technology. The rule prohibits spreading, grading or screening of VOC-contaminated soil. Trucks transporting c ontaminated soil are required

to be loaded and covered in a manner t hat prevents spillage, and cleaned off before leaving the loading site.

Facilities planning to excavate possibly contaminated soil must first submit a mitigation plan for approval by the APCO, and notify t he APCO 24 hours before excavation. The

APCO must also be notified within 24 hours of the detection of contaminated soil.

Record keeping is required for VOC monitori ng readings during excavations, calibration records for monitoring equipment, daily in spection of contaminated soil cover,

identification and busine ss addresses of the generat ors, transporters and storage/treatment facilitie s for contaminated soil.

District Rule 4651 is compared to South Coast AQMD Rule 1166 under the following categories:

Applicability/Exemption :

District Rule 4651 is less stringent than S outh Coast AQMD Rule 1166 because it exempts accidental spillages up to 42 gallons of VOC containing material, whereas South Coast AQMD Rule 1166 exempts only 5 gallons.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-299 District Rule 4651 is more stringent than South Coast AQMD Rule 1166 because it requires emergency excavations to follow the same treatment and decontamination procedures as regular excava tions, whereas South Coast AQMD has no requirements for emergency excavations other than notification of the APCO.

Requirements :

There are no significant differences between District Rule 4651 and South Coast AQMD Rule 1166 under this category. District Rule 4651 allows a maximum of 30 minutes to

contain or truck off soils with a VOC reading of 1,000 ppm, whereas South Coast AQMD

Rule 1166 allows a maximum of 15 minutes. In both cases, this requirement conveys the urgency with which the contaminated soil must be removed to a treatment facility, but it is unlikely that there will be any difference in total emissions when the overall excavation, transportation and treat ment process is considered. Source Testing and Monitoring :

There are no significant differences between District Rule 4651 and South Coast AQMD Rule 1166 under this category. The fo llowing minor differences are noted:

• District Rule 4651 provides an exemption fr om daily monitoring for contaminated soil cover integrity when operators are not on- site for more than 24 hours, whereas
South Coast AQMD Rule 1166 does not provide such an exemption. Cover monitoring applies only to soil with low contam ination (since soil high contamination

must be sealed in containers or trucked o ff in less than an hour). It is therefore unlikely will make a significant diffe rence in emissions from such soil.

• District Rule 4651 requires VOC monitoring of decontaminated soil to determine whether it is safe to dispose of or must be further treated. S outh Coast AQMD Rule 1166 does no state this requirem ent explicitly, but the requi rement is implied in the

definition of c ontaminated soil. Reporting :

South Coast AQMD Rule 1166 is more stringent under this category because it requires submittal of a detailed excavation plan, in ad dition to notification of the APCO prior to

commencement of excavation. District Rule 4651 does not require an excavation plan, but some of the information required to be in cluded in the pre-excava tion notification is similar to information required by South Coast AQMD Rule 1166’s excavation plan. Further, District Rule 4651 requires submittal of a completion of excavation report.

Record Keeping :

District Rule 4651 is more stringent under this category because it requires records to be retained for at least 5 years, whereas South Coast AQMD Rule 1166 requires only 2 years for record retention.

The preceding comparison demonstrates that Dis trict Rule 4651 is just as stringent as South Coast AQMD Rule 1166. The most signi ficant difference between the rules is inSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-300 the exemptions category as discussed above. While District Rule 4651 has a very lax exemption for accidental spillage, South Coast AQMD Rule 1166 has an equally lax exemption for emergency exca vations. Differences under the requirements, source testing and monitoring, reporting and record keeping categories are generally minor and not likely to affect overall emissions control effectiveness for either rule.

B. Bay Area AQMD Re gulation 8 Rule 40

The purpose of Bay Area AQMD Regulation 8 Rule 40 is to limit the emission of organic compounds from soil that has been contami nated by organic chemical or petroleum chemical leaks or spills and to control emi ssions from underground storage tanks during removal or replacement.

The rule provides the following exempti ons: (a) contaminated soil exposed only for sampling purposes; (b) soil contaminated wit h a non-volatile hydr ocarbon with an initial boiling point of 302 o F or higher; (c) excavation of c ontaminated not exceeding 1 cubic yard, or not exceeding 8 cubic yards if or ganic content does not exceed 500 ppmw; (d) soil contaminated by accidental spillage of five gallons or less of liquid organic compounds.

The rule requires that contaminated soil shal l be kept visibly moist by water spray, treated with a vapor suppressant, or co vered with continuous heavy duty plastic sheeting or other covering to minimize emissions of organic compounds to the atmosphere. Inactive piles of contami nated soil must be covered within one hour.

The rule requires that contam inated soils loaded into trucks or trailers for off site disposal or treatment shall be covered wit h continuous heavy duty plastic sheeting or other covering. The rule requires that within 45 days of excavation (or within 90 days for soil of organic content less than 500 ppmw), contaminated soil shall be backfilled and

covered with at least 6 inches of uncontaminated soil, remov ed from the site, or treated

to remove the contamination.

Treatment of contami nated soil shall be subject to all applicable District Rules and Regulations. Aeration of cont aminated soil is prohibited.

A written notice of intention to excavate must be submitted 5 days prior to start of excavation. For emergency excavation, notice is required only as soon as possible, but still before the excavation, and must be follow ed by written verification no later than 30 days after the excavation. For pipeline repai r excavations, notice is required no later than 30 days after the excavation.

Sampling and VOC content analysis is r equired to demonstrate any exemptions

claimed.

District Rule 4651 is compared to Bay Area AQMD Regulation 8 Rule 40 under the following categories:San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-301 Applicability/Exemption :

District Rule 4651 is less stringent than Bay Area AQMD Regulation 8 Rule 40 because it exempts accidental spillages up to 42 ga llons of VOC containing material, whereas Bay Area AQMD Regulation 8 Rule 40 exempts only 5 gallons.

District Rule 4651 is more stringent than Bay Area AQMD Regulation 8 Rule 40 because its small excavation exemption is limited to only one cubic yard of contaminated soil, whereas Bay Area AQMD Regulation 8 Rule 40 provides an exemption for up to eight cubic yards.

Requirements :

There are no significant differences betw een District Rule 4651 and Bay Area AQMD Regulation 8 Rule 40 under this category. The following minor difference is noted:

• District Rule 4651 is more stringent t han Bay Area AQMD Regulation 8 Rule 40 because it requires treatment or disposal of contaminated soil to be done within 30 days, whereas Bay Area AQMD Regulation 8 Rule 40 allows 45 days for soil above 500 ppm in VOC concentration and 90 days for soil with less than 500 ppm VOC.

• District Rule 4651 is more stringent t han Bay Area AQMD Regulation 8 Rule 40 because it requires soil with 1, 000 ppm or more of VOC to be sealed in containers or trucked off to an approved treatment/dis posal facility within 30 minutes of excavation, whereas Bay Area AQMD Regulation 8 Rule 40 has no such requirement. Source Testing and Monitoring :

District Rule 4651 is more stringent than Bay Area AQMD Regulation 8 Rule 40 because it requires monitoring of soil for VOC concentration every 15 minutes during excavation, whereas Bay Area AQMD Regulat ion 8 Rule 40 has no such requirement. Reporting :

There are no notable differences between the two rules under this category.

Record Keeping :

District Rule 4651 is more stringent under this category because it requires records to be retained for at least 5 years, whereas Ba y Area AQMD Regulation 8 Rule 40 has no requirement for the retention of records.

The preceding comparison demonstrates that Dis trict Rule 4651 is more stringent than Bay Area AQMD Regulation 8 Rule 40. Under the applicability/exemptions category, District Rule 4651 has a very lax exemption for accidental spillage, but Bay Area AQMD Regulation 8 Rule 40 has an equa lly lax exemption for small excavations. As discussedSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-302 above, District Rule 4651 is stricter than Bay Area AQMD Regulation 8 Rule 40 under the requirements, monitoring an d record keeping categories.

C. Ventura County APCD Rule 74-29

Ventura County APCD Rule 74-29 (Soil Decont amination Operations ) is applicable to soils that contain gasoline, diesel fuel, or jet fuel.

The rule provides several exemptions fo r: (a) contamination due to leaking storage tanks used in an agricultural operations; (b) soil moving, loading or transport activities performed for the sole purpose of complying wit h local, state, or federal laws; (c) soil excavation or handling occurring as a result of an emergency; (d) soil aeration involving less than 1 cubic yard; (e) contamination due to a spill or release of less than five (5) gallons of VOC-containing liquid; (f) cont aminated soil used as daily cover at permitted Class III Solid Waste Disposal Sites.

The rule prohibits aeration of soil emitti ng VOC concentrations of more than 50 ppmv. Vapor extraction, bioremediation or biov enting of soils with a VOC concentration exceeding 100 ppm are also prohibited. The rule r equires monitoring for VOC contamination every 15 minutes during exca vation of potentially contaminated soil and that all exposed contaminated soil surfac es shall be moistened with water or treated with a vapor suppressant or covered with continuous heavy duty plastic sheeting.

Decontamination treatment or removal of soil from excavati on site must begin within 30 days. Treatment must be conducted in compli ance with all applicable District rules. Measures such as covering and not overloadi ng are required to prevent spillage during transportation.

Records required include dates that soil wa s disturbed and the quantit y of soil disturbed on each date, reasons for excavation or gr ading, cause of VOC soil contamination and history of the site, description of tanks or piping associated with t he soil contamination, description of mitigation measures employ ed for dust, odors and ROC emissions,

details of treatment and/or di sposal of ROC contaminated so il, description of monitoring equipment and techniques, and facility layout maps.

Records are required to be retained for up to two years.

District Rule 4651 is compared to Ventur a County APCD Rule 74-29 under the following categories:

Applicability/Exemption :

District Rule 4651 is more stringent than V entura County APCD Rule 74-29 because it has fewer exemptions. The exemptions pr ovided by Ventura C ounty APCD Rule 74-29, including exemptions for contamination due to tanks used in agricultural operations and

the use of contaminated soil as landfill cover, are likely to re sult in larger quantities of emissions in comparison to the exempt ions provided by District Rule 4651.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-303 Requirements :

District Rule 4651 is more stringent than V entura County APCD Rule 74-29 because it requires soil with 1,000 ppm or more of VOC to be sealed in containers or trucked off to an approved treatment/disposal facility wit hin 30 minutes of excavation, whereas Ventura County APCD Rule 74-29 has no such requirement. Source Testing and Monitoring :

District Rule 4651 is more stringent than V entura County APCD Rule 74-29 because it requires monitoring of soil for VOC concent ration every 15 minutes during excavation, whereas Ventura County APCD Rule 74-29 has no such requirement. Reporting :

Ventura County APCD Rule 74-29 is more stringent than District Rule 4651 under this category because it requires more detailed information about each excavation to be

recorded.

Record Keeping :

District Rule 4651 is more stringent under this category because it requires records to be retained for at least 5 years, wher eas Ventura County APCD Rule 74-29 requires only two years of record retention.

The preceding comparison demonstrates that Dis trict Rule 4651 is more stringent than Ventura County APCD Rule 74-29, since it has stricter requirements under all categories discussed above, except for reporting. It is also unlikely that reporting has any significant effect on the rule’s emission control effectiveness.

Conclusion

After evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, District staff concludes that District Rule 4651 satisfies RACT for Soil Decontamination Operations.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-304 

### Rule 4652 - Coatings and Ink Manufacturing

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 0 0 0 0 0 0 0 0

VOC 0.02 0.02 0.02 0. 02 0.02 0.02 0.02 0.02
(Source: District 2007 Ozone Plan)

District Rule 4652 Description

District Rule 4652, last amended on December 17, 1992, limits VOC emissions from coating and ink manufacturing operations.

District Rule 4652 specifies equipment desi gn and operational procedures for processes

associated with the manufacture of coatings or inks. The rule requires that portable mixing vats be covered, and includes lid conf iguration requirements . Stationary mixing vats are to be covered and grinding mills must have fully enclosed screens. For cleaning portable and stationary vats, as we ll as for cleaning high-speed dispersion mills, grinding mills, and roller mills, APC O-approved cleaning methods are required.

How does District Rule 4652 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

There is no EPA CTG guidance document for coating and ink manufacturing.

B. EPA - Alternative Control Technology (ACT)

There is no EPA ACT guidance document for coating and ink manufacturing.

C. Standards of Performance fo r New Stationary Sources (NSPS)

There is no NSPS guidance document for coating and ink manufacturing.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

NESHAPs and MACTs are requirements contai ned in 40 Code of Federal Regulations (CFR) Part 61 and 40 CFR Part 63. Si nce EPA has delegated the authority to implement NESHAP requirements to the Dis trict, NESHAPs and MACTs promulgated by EPA are usually incorporated by reference into District Rule 4002 (National Emission

Standards for Hazardous Air Pollu tants). It is impor tant to mention that the DistrictSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-305 implements NESHAPs and MACTs by inco rporating the emission standards as

conditions of the Permits to Operate issued to affe cted sources.

40 CFR 63 Subpart HHHHH - National Emis sion Standards for Hazardous Air

Pollutants: Miscellaneous Coating Manufacturing

This NESHAP contains some of the work prac tice standards in Rule 4652, in addition to HAP vapor pressure reduction requirem ents. The NESHAP vapor pressure requirements are not directly comparable to t he work practice standards in Rule 4652. In addition, some HAPs may be exempt VOCs, and some VOCs may be HAPs; therefore, there is no dire ct correlation between the NE SHAP requirements versus District Rule 4652 VOC requirements.

How does District Rule 4652 compare to rules in other air districts?

District staff compared District Rule 4652 to the rules of other California ozone

nonattainment air districts’ rules for coat ing and ink manufacturing operations. The results of the analysis are discussed below.

A. South Coast Air Quality Management Distri ct (SCAQMD) Rule 1141.1 - Coatings and Ink Manufacturing (Amended November 17, 2000)

SCAQMD Rule 1141.1 applies to coating and ink manufacturing. The table below

identifies where the rules diffe r. Categories not discussed means the two rules have the same requirement.

Category Bay Area SJ Valley More Stringent for Category

Throughput Exemption 500 gal/day or 11,000 gal/mo 50 gal/day SJ Valley

As shown in the table above, SJVAPCD Rule 4652 is more stringent than SCAQMD

Rule 1141.1.

B. Bay Area Air Quality Ma nagement District (BAAQMD ) Regulation 8 Rule 35 - Coating, Ink, and Adhesive Manufacturing (June 15, 1994)

BAAQMD Regulation 8 Rule 35 applies to c oating and ink manufacturing. The table below identifies key category comparisons for the rules. Categories not discussed means the two rules have the same requirement.

Category Bay Area SJ Valley More Stringent for Category

ExemptionsSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-306

Waterbased Coatings and/or Paste

Inks Not Exempt Exempt Bay Area

Low VOC Coatings/Inks Exempt Not Exempt SJ Valley

Vats less than 12 gal Not Exempt Exempt Bay Area

Produce less than 50 gal/day No t Exempt Exempt Bay Area

Requirements

Stationary Mixing Vats Limit 15 lbVOC/day or

80% control Covers, except to add/sample

ingredients Bay Area

Equipment Cleaning 200 g/l, closed system, or 80%

control Minimize

emissions and

APCOapproved (per Rule 4661:

833 lb-VOC/mo or 90% control) SJ Valley

As shown in the table above, there are se veral categories that the rules differ in stringency. However, the difference in over all emissions reductions on a mass basis is insignificant since the emissions inventory fo r this category is small and there are only four facilities in the SJVAPCD subject to th is rule, none of which are Major Sources. Overall, SJVAPCD Rule 4652 is considered equivalent to BAAQMD Reg 8 Rule 35.

C. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 464 (Organic Chemical Manufacturing Operations) amended September 25,

2008

SMAQMD Rule 464 applies to organic chemic al manufacturing operations. Per Rule 464, organic chemicals can include coatings. The table below identi fies key category comparisons for the rules. Categories not discussed means the two rules have the same requirement.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-307 Category Sac Metro SJ Valley More Stringent

for Category
Exemptions
Waterbased Coatings and/or Paste

Inks Not Exempt Exempt Sac Metro

Vats less than 12 gal Not Exempt Exempt Sac Metro

Produce less than 50 gal/day Not Exempt Exempt Sac Metro

Facility less than 15 lb-VOC/day Exempt Not Exempt SJ Valley

Process tank less than 15 lbVOC/day Exempt Not Exempt SJ Valley

Requirements/Standards

Process Tanks/Mixing Vats Limit 15 lbVOC/day or

90% control Covers, except to add/sample ingredients Sac Metro

Equipment Cleaning 25 g/l (2009), or

90% control Minimize emissions

and APCOapproved (per Rule 4661: 833

lb-VOC/mo or 90% control) Equivalent

As shown in the table above, there are se veral categories that the rules differ in stringency. However, the difference in over all emissions reductions on a mass basis is insignificant since the emissions inventory fo r this category is small and there are only four facilities in the SJVAPCD subject to th is rule, none of which are Major Sources. Overall, SJVAPCD Rule 4652 is consider ed equivalent to SMAQMD Rule 464.

F. Ventura County Air Polluti on Control District (VCAPCD)

No rule for coating and/or ink manufacturing facilities.

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, Distric t staff concludes that District Rule 4652 satisfies RACT for coating and ink manufacturing operations.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-308 

### Rule 4653 - Adhesives

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 0 0 0 0 0 0 0 0

VOC 3.2 3.3 3.5 3. 6 3.9 4.1 4.3 4.9
(Source: District 2007 Ozone Plan)

I. District Rule 4653 Description:

District Rule 4653, recently amended on Septem ber 20, 2007, sets VOC content limits for adhesives. In lieu of adhering to the VOC limits, owners/oper ators may use VOC control devices with a control efficiency of at least 85%, by mass. Adhesives used in laboratories, sold for specific limited uses , sold in quantities no more than 8 ounces, or used in quantities of no more than 20 gallons per year are exemp t. VOC emissions are over 80% controlled, compar ed to uncontrolled emissions.

II. How does District Rule 4653 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

The CTG EPA-453/R-08-005 2008/09 ( Control Techniques Guidelines for

Miscellaneous Industrial Adhesives ) applies to industrial adhesives applications located in marginal, moderate, serious or seve re ozone nonattainment areas that has the potential to emit greater than or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of VOC for extrem e ozone nonattainment areas.

This CTG, dated September 2008, will be evaluat ed by the District for inclusion into District rules within one year.

B. EPA - Alternative Control Technology (ACT)

There is no EPA ACT guidance document for adhesives.

C. Standards of Performance for New Stationary Sources (NSPS)

There is no NSPS document for adhesives.

D. National Emission Standards for Ha zardous Air Pollutants (NESHAPs) and Maximum Achievable Control Technologies (MACTs)

There is no NESHAPs/MACT document for adhesives.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-309 III. How does District Rule 4653 compar e to rules in other air districts?

District staff compared District Rule 4653 with the rules of other California ozone nonattainment air districts’ rules (listed bel ow) for adhesives operations. The results of the analysis are discussed below.

E. South Coast Air Quality Management Dis trict (SCAQMD) Rule 1168 - Adhesive and Sealant Applications (Amended January 7, 2005) F. Bay Area Air Quality Management Distr ict (BAAQMD) Regulation 8 Rule 51 -

Adhesive and Sealant Products (Amended July 17, 2002) G. Sacramento Metropolitan Air Quality M anagement District (SMAQMD) Rule 460 - Adhesives and Sealants (Amended November 30, 2000) H. Ventura County Air Poll ution Control District (VCP CD) Rule 74.20 - Adhesives and Sealants (Amended January 1, 2005)

The table below identifies the category com parisons for the rule s. Categories not shown means all of the rules have the same requirement.

General Adhesive Application

Processes Bay

Area (Rule 8-51) South

Coast (Rule 1168) Sac

Metro (Rule 460) Ventura (Rule 74.20) SJ Valley (Rule 4653)

Fiberglass 80 200 200

Flexible vinyl 250 250

Flexible vinyl toother substrate 250

Other Substrates 250 250 250 250

Plastic Foams 120 50 120 120

Porous Material 120 120 120

Porous Material (except wood and plastic foam) 150

Porous Material (except wood) 50

Rubber 250 250 250

Wood 30 30 30 30

Specialty Adhesive Application

Processes Bay

Area (Rule 8-51) South

Coast (Rule 1168) Sac

Metro (Rule 460) Ventura (Rule 74.20) SJ Valley (Rule 4653)

ABSWelding 400 325 400 400 400

Carpet Pad Installation 50

Cellulosic plastic welding (except ethyl cellulose) 100San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-310

Ceramic Tile Installation 130 65 130 130 130

Computer Diskette Manufacturing 850 350 850

Contact Adhesive Special 250 250

Contact Adhesive Specialty Substrate 250 200

Contact Adhesive 80 250 200 250

Cove Base Installation 150 50 150 150

Dry Wall and Panel Installation 50

Floor covering installation (except ceramic tile) 150

Immersible Product Manufacturing 650

Indoor Carpet Adhesives 50

Indoor Floor Covering Installation 150 150

Metal to Urethane/Rubber Molding or Casting Adhesive 250

Multipurpose Architec tural (except cove base installation) 200

Multipurpose Construction 200 70 200 200

Non membrane Roof Installation/Repair 300 300 300

Other Plastic Cement Welding Adhesive 450 450

Other Plastic Welding 500 500

Outdoor Floor Covering Installation 350 150 250

Perimeter Bonded Sheet Vinyl Flooring

Installation 660 660 660

Plastic Cement Welding 250

Rubber Floor Installation 60

Rubber Vulcanization Bonding 850 850

Sheet rubber lining installation adhesive 850

Single- Ply Roof Material Installation/Repair 250 250

Single Ply Roof Membrane Installation/Repair Adhesive 250 250 250San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-311

Staple and Nail Manufacturing 640

Structural Wood Member Adhesive 140

Styrene-acrylonitrile welding adhesive 100

Subfloor Installation 50

Thin Metal Laminating 780 780

Tire Retread 100 100 100 100

Top and Trim Installation 540 250

Traffic Marking Tape Adhesive 150

VCT and Asphalt Tile Installation 50

Water proof Resorcinol Glue 170 170 170

Wood Flooring Installation 100

Adhesive Primer Application

Processes Bay

Area (Rule 8-51) South

Coast (Rule 1168) Sac

Metro (Rule 460) Ventura (Rule 74.20) SJ Valley (Rule 4653)

Automotive Glass 700 700 700

Plastic Cement Welding 650 400 650 650

Single Ply Roof Membrane 250 250

Traffic Marking Tape 150 150 250

Other 250 Included

Above

250 250

Application Methods Bay

Area (Rule 8-51) South

Coast (Rule 1168) Sac

Metro (Rule 460) Ventura (Rule 74.20) SJ Valley (Rule 4653)

Aerosol Cans x

Air Atomized (for contact adhesives) x

Airless Spray, Air Assisted Airless Spray, Air Atomized Spray (for contact adhesives) x

Airless Spray, Air Assisted Airless Spray, Air Atomized Spray (for viscosity 200 cp or greater) xSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-312

Brush or Roll Coat x x x

Dip Coat x x x

Electro deposition x x x

Electrostatic Spray x x x

Flow Coat x x x

Hand Application x x x

HVLP Spray x x x

LVLP Spray x x

Other, Transfer Efficiency Minimum 65% 65%

Add-on Control Efficiency Bay

Area (Rule 8-51) South

Coast (Rule 1168) Sac

Metro (Rule 460) Ventura (Rule 74.20) SJ Valley (Rule 4653)

Capture 90% by

wt

Control 95% by

wt

Overall Control 80% 85% by

wt 85% by

wt

Solvents Bay

Area (Rule 8-51) South

Coast (Rule 1171)* Sac

Metro (Rule 460) Ventura (Rule 74.20) SJ Valley (Rule 4653)

Product Cleaning (General) 25 70 70 25

Surface Prep Prior to Rubber

Vulcanization 850

Repair and Maintenance Cleaning 25 70 70 25

Cleaning of Application Equipment 25 70 if not

enclosed 70 25

*Per Rule 1171 (Solvent Cleaning)

As shown in the table above, SJVAPCD Ru le 4653 varies in stringency when compared to other Districts’ adhesive requirements, an d in some categories is less stringent.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-313 Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, District staff concludes that Rule 4653 will be reevaluated for RACT purposes upon the nex t amendment to rule (see Table 4-3), already scheduled for revision under the current ozone plan.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-314 

### Rule 4661 - Organic Solvents

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 0 0 0 0 0 0 0 0

VOC 4.294 4.295 4.296 4.297 4.295 4.295 4.295 4.296
(Source: District 2007 Ozone Plan)

I. District Rule 4661 Description:

District Rule 4661, recently amended on Septem ber 20, 2007, controls VOC emissions

from organic solvents. District Rule 4661 has a facility solvent VOC emission limit of 833 lb/month or a VOC capture and control syst em with efficiencies of 90% and 95% respectively.

II. How does District Rule 4661 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

1. The CTG EPA-450/2-77-022 1977/11 ( Control of Volatile Organic Emissions from Solvent Metal Cleaning ) applies to degreasing operations located in marginal, moderate, serious or severe ozone nonattain ment areas that has the potential to emit greater than or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of VOC for extreme oz one nonattainment areas. Degreasing operations are covered under District Rule 4662 (Organic Solvent Degreasing Operations). As such, this CTG is addr essed within the RACT analysis for Rule

4662.

2. The CTG EPA-453/R-06-001 2006/09 ( Control Techniques Guidelines for Industrial Cleaning Solvents ) applies to solvent cleaning operations located in marginal, moderate, serious or severe ozone nonattainment areas that has the potential to emit greater than or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of VOC for extreme ozone nonattainment areas.

The CTG requirement is a solvent VOC cont ent limit of 50 g/L or an overall VOC control efficiency of 85%. District Ru le 4661 has a solvent VOC limit of 833

lb/month or an overall VOC control efficienc y requirement greater than 90%. As such, Rule 4661 is more stringent than this CTG.

B. EPA - Alternative Control Technology (ACT)

1. The ACT EPA-450/3-89-030 1989/08 ( Alternative Control Technology Document – Halogenated Solvent Cleaners ) applies to cleaning machines that use halogenated solvents. The hal ogenated solvents listed in the ACTSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-315 that EPA is concerned about are meth ylene chloride, trichloroethylene, perchloroethylene (tetrachloroethylene) , CFC-113 (1,1,2-trichloro-1,2,2- Trifluoroethane), and methyl chlorofo rm (1,1,1-trichloroethane). Rule 4661, Section 4.4 exempts haloge nated hydrocarbons from the rule. However, the District addresses HAPs via rule 4102 (Nuisance) along with a

Health Risk Assessment-Emissions modelin g process, in addition to District

7000 series toxic rules.

2. The ACT EPA-453/R-94-015 1994/02 ( Alternative Control Techniques

Document – Industria l Cleaning Solvents ) applies to industrial cleaning with organic solvents. The ACT focuses on suggested solvent accounting and management practices. District Ru le 4661 has a facility solvent VOC

emission limit of 833 lb/month or an overall VOC control efficiency requirement greater than 90%. As su ch, Rule 4661 is more stringent than

this ACT for VOCs.

C. Standards of Performance for New St ationary Sources (NSPS) – There are no NSPS regulations that apply to solvents.

D. National Emission Standards for Ha zardous Air Pollutants (NESHAPs) and Maximum Achievable Control Technologies (MACTs)

NESHAPs and MACTs are requirements contained in 40 Code of Federal Regulations (CFR) Part 61 and 40 CFR Part 63. Since EPA has delegated the authority to implement N ESHAP requirements to the District, NESHAPs and MACTs promulgated by EPA are usually inco rporated by reference into District Rule 4002 (National Emission Standards fo r Hazardous Air Pollutants). It is important to mention that the Distr ict implements NESHAPs and MACTs by incorporating the emission standards as conditions of the Permits to Operate

issued to affected sources.

1. 40 CFR 63 Subpart T (Nationa l Emission Standards for HAPs: Halogenated Solvent Cleaning)

Subpart T applies to cleaning machines that use any of the following halogenated solvents: methylene chloride, trichloroethylene, perchloroethylene (tetrachloroethy lene), methyl ch loroform (1,1,1- trichloroethane), carbon tetrachloride, and chloroform.

Rule 4661, Section 4.4 exempts halogenat ed hydrocarbons from the rule. However, the District addresses HAPs via rule 4102 (Nuisance) along with

a Health Risk Assessment-Emissions m odeling process, in addition to

District 7000 series toxic rules.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-316 III. How does District Rule 4661 compar e to rules in other air districts?

District staff compared District Rule 4661 with the rules of other California ozone

nonattainment air districts for solvents. T he results of the analysi s are discussed below.

A. South Coast Air Quality Management Dist rict (SCAQMD) Rule 1171 - Solvent Cleaning Operations (Amended February 1, 2008)

SCAQMD Rule 1171 applies to solvent cl eaning operations. The rule requires solvent VOC content limits, or a VOC c apture and control system with efficiencies of 90% and 95% respectively. District Rule 4661 has a facility solvent VOC

emission limit of 833 lb/month or a VOC capture and control system with efficiencies of 90% and 95% respectively. Since the two both allow identical add control efficiencies, the rules are c onsidered equivalent. Ov erall SJVAPCD Rule 4661 is at least as stringent as SCAQMD Rule 1171.

B. Bay Area Air Quality Ma nagement District (BAAQMD ) Regulation 8 Rule 16 - Solvent Cleaning Operations (amended October 16, 2002)

BAAQMD Reg 8 Rule 11 applies to solvent cleaning operations. The rule requires work practice standards and solvent VOC c ontent limits, or fo r some categories a VOC capture and control system with a control efficiency of 90%. District Rule 4661 has a facility solvent VOC emission lim it of 833 lb/month or a VOC capture and control system with efficiencies of 90% and 95% respectively. Overall

SJVAPCD Rule 4661 is at least as st ringent as BAAQMD Regulation 8 Rule 16.

C. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 441 (Organic Solvents) amended December 6, 1978

SMAQMD Rule 441 applies to solvent cleani ng operations. The rule requires work practice standards and solvent VOC em ission limits (e.g. 39.7 lb/day for photochemically reactive solvents, and 2970 lb/day for non-photochemically reactive solvents), or a VOC reduction of 85% via add on control. District Rule 4661 has a facility solvent VOC emission lim it of 833 lb/month or a VOC capture and control system with efficiencies of 90% and 95% respectively. Overall

SJVAPCD Rule 4661 is at least as stringent as SMAQMD Rule 441.

D. Ventura County Air Pollution Control District (VCPCD) - No organic solvent

rule.

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, Distric t staff concludes that District Rule 4661 satisfies RACT for organic solvents.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-317 

### Rule 4662 - Organic Solvent Degreasing Operations

Emissions Inventory: Tons per day - summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 0 0 0 0 0 0 0 0

VOC 4.294 4.295 4.296 4.297 4.295 4.295 4.295 4.296
(Source: District 2007 Ozone Plan)

I. District Rule 4662 Description:

District Rule 4662, recently amended on Septem ber 20, 2007, controls VOC emissions

from organic solvent degreasers (tanks, trays, drums, or other containers).

District Rule 4662 has solvent VOC content requirements for cold cleaners (25 gVOC/L), or an equivalent control system with no less than 85% overall control for cold cleaners, open-vapor, and conveyorized degreasers. The rule also contains work practice standards and design requirem ents for these categories of source.

II. How does District Rule 4662 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

1. The CTG EPA-450/2-77-022 1977/11 ( Control of Volatile Organic Emissions from Solvent Metal Cleaning ) applies to degreasing operations located in marginal, moderate, serious or severe ozone nonattain ment areas that has the potential to emit greater than or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of VOC for extrem e ozone nonattainment areas.

This 1977 CTG refers to requirements, controls, design, and work-practice

standards that are no more stri ngent than SJVAPCD Rule 4662.

B. EPA - Alternative Control Technology (A CT) – There are no ACTs that apply to degreasers.

C. Standards of Performance for New St ationary Sources (NSPS) – There are no NSPS regulations that apply to degreasers.

D. National Emission Standards for Ha zardous Air Pollutants (NESHAPs) and Maximum Achievable Control Technolog ies (MACTs) – There are no NESHAP regulations that apply to degreasers.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-318 III. How does District Rule 4662 compar e to rules in other air districts?

District staff compared District Rule 4662 with the rules of ot her California ozone

nonattainment air districts for solvents. T he results of the analysi s are discussed below.

A. South Coast Air Quality Management District (SCAQMD) Rule 1122 - Solvent Degreasers (Amended October 1, 2004)

SCAQMD Rule 1122 applies to solvent degr easers. SCAQMD Rule 1122 contains solvent VOC content requirements for cold cleaners (25 g-VOC/L) , or an equivalent control system with no less than 85% overall control for cold cleaners, open-vapor, and conveyorized degreasers. The rule also contains equivalent work practice standards and design requirements for thes e categories of s ource compared to

SJVAPCD Rule 4662.

Since the two both allow identical (or equiva lent) control efficienc ies, the rules are considered equivalent. Overall SJVAPCD Ru le 4662 is at least as stringent as
SCAQMD Rule 1122.

B. Bay Area Air Quality Management Di strict (BAAQMD) - No degreasing rule.

C. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 454 (Degreasing Operations) amended September 25, 2008

SMAQMD Rule 454 applies to solvent degr easers. SMAQMD Rule 454 contains solvent VOC content requirements for cold cleaners (25 g-VOC/L) , or an equivalent control system with no less than 85% overall control for cold cleaners, open-vapor, and conveyorized degreasers. The rule also contains equivalent work practice standards and design requirements for thes e categories of s ource compared to

SJVAPCD Rule 4662.

Since the two both allow identical (or equiva lent) control efficiencies, the rules are considered equivalent. Overall SJVAPCD Ru le 4662 is at least as stringent as
SMAQMD Rule 454.

D. Ventura County Air Pollution Contro l District (VCPCD) Rule 74.6 (Surface Cleaning and Degreasing) amended July 1, 2004

VCPCD Rule 454 applies to solvent degr easers. VCPCD Rule 74.6 contains solvent VOC content requirements for cold cleaners (25 g-VOC/L) , or an equivalent control system with no less than 85% overall control for cold cleaners, open-vapor, and conveyorized degreasers. The rule also contains equivalent work practice standards and design requirements for thes e categories of s ource compared to

SJVAPCD Rule 4662.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-319 Since the two both allow identical (or equiva lent) control efficienc ies, the rules are considered equivalent. Overall SJVAPCD Ru le 4662 is at least as stringent as

VCPCD Rule 454.

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, Distric t staff concludes that District Rule 4662 satisfies RACT for organic solvent degreasing operations.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-320 

### Rule 4663 - Organic Solvent Clean ing, Storage, and Disposal

Emissions Inventory: Tons per day - summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 0 0 0 0 0 0 0 0

VOC 4.294 4.295 4.296 4.297 4.295 4.295 4.295 4.296
(Source: District 2007 Ozone Plan)

I. District Rule 4663 Description:

District Rule 4663, recently amended on Septem ber 20, 2007, controls VOC emissions

from organic solvent cleaning outside a degreaser (tank, tray, drum, or other container) as well as storage and disposal of the solvents.

District Rule 4663 has solvent VOC content requirements for general product cleaning or surface preparation, repair and maintenance cleaning, and cleaning of coating/adhesive application equ ipment (all 25 g-VOC/L), as well as specific other categories (ranging from 100-800 g-VOC/L) or an equivalent control system with no less than 90% overall control for the emissions g enerated. The rule al so requires containers for solvent storage and disposal.

II. How does District Rule 4663 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

1. The CTG EPA-450/2-77-022 1977/11 ( Control of Volatile Organic Emissions from Solvent Metal Cleaning ) applies to degreasing operations located in marginal, moderate, serious or severe ozone nonattain ment areas that has the potential to emit greater than or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of VOC for extrem e ozone nonattainment areas.

Since this CTG covers degreasers, it will not be compared to SJVAPCD Rule

4663.

2. The CTG EPA-453/R-06-001 2006/09 ( Control Techniques Guidelines for Industrial Cleaning Solvents ) applies to solvent cleaning operations located in marginal, moderate, serious or severe ozone nonattainment areas that has the potential to emit greater than or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of VOC for extreme ozone nonattainment areas.

The CTG requirement is a solvent VOC cont ent limit of 50 g/L or an overall VOC control efficiency of 85%. District Ru le 4663 has a solvent VOC limits or anSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-321 overall VOC control efficiency requirement no less than 90%. As such, Rule 4663 is more stringent than this CTG.

B. EPA - Alternative Control Technology (ACT)

1. The ACT EPA-450/3-89-030 1989/08 ( Alternative Control Technology Document – Halogenated Solvent Cleaners ) applies to cleaning machines that use halogenated solvents. The hal ogenated solvents listed in the ACT

that EPA is concerned about are meth ylene chloride, trichloroethylene, perchloroethylene (tetrachloroethylene) , CFC-113 (1,1,2-trichloro-1,2,2- Trifluoroethane), and methyl chlorofo rm (1,1,1-trichloroethane). The District addresses HAPs via rule 4102 (Nuisance) along with a Health Risk Assessment-Emissions modeling process, in addition to District 7000

series toxic rules.

2. The ACT EPA-453/R-94-015 1994/02 ( Alternative Control Techniques

Document – Industria l Cleaning Solvents ) applies to industrial cleaning with organic solvents. The ACT focuses on suggested solvent accounting and management practices. District Rule 4663 requires solvent VOC emission

limits or an overall VOC control effici ency requirement greater than 90%. As such, Rule 4663 is more stringent than this ACT for VOCs.

C. Standards of Performance for New St ationary Sources (NSPS) – There are no NSPS regulations that apply to solvents.

D. National Emission Standards for Ha zardous Air Pollutants (NESHAPs) and Maximum Achievable Control Technologies (MACTs)

NESHAPs and MACTs are requirements contained in 40 Code of Federal Regulations (CFR) Part 61 and 40 CFR Part 63. Since EPA has delegated the authority to implement N ESHAP requirements to the District, NESHAPs and MACTs promulgated by EPA are usually inco rporated by reference into District Rule 4002 (National Emission Standards fo r Hazardous Air Pollutants). It is important to mention that the Distr ict implements NESHAPs and MACTs by incorporating the emission standards as conditions of the Permits to Operate

issued to affected sources.

1. 40 CFR 63 Subpart T (Nationa l Emission Standards for HAPs: Halogenated Solvent Cleaning)

Subpart T applies to cleaning machines that use any of the following halogenated solvents: methylene chloride, trichloroethylene, perchloroethylene (tetrachloroethy lene), methyl ch loroform (1,1,1- trichloroethane), carbon tetrachloride, and chloroform.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-322 The District addresses HAPs via rule 4102 (Nuisance) along with a Health Risk Assessment-Emissions modeling proc ess, in addition to District 7000

series toxic rules.

III. How does District Rule 4663 compar e to rules in other air districts?

District staff compared District Rule 4663 with the rules of ot her California ozone

nonattainment air districts for solvents. T he results of the analysi s are discussed below.

A. South Coast Air Quality Management District (SCAQMD) Rule 1171 - Solvent Cleaning Operations (Amended February 1, 2008)

This SCAQMD rule is addressed in t he SJVAPCD Rule 4661 (S olvent Cleaning) RACT-SIP analysis. Staff considers SJVAPCD solvent requirements, Rules 4661 and 4663, at least as stringent as SCAQMD Rule 1171.

B. Bay Area Air Quality Ma nagement District (BAAQMD ) Regulation 8 Rule 16 - Solvent Cleaning Operations (amended October 16, 2002)

This BAAQMD rule is addressed in t he SJVAPCD Rule 4661 (S olvent Cleaning) RACT-SIP analysis. Staff considers SJ VAPCD solvent requirements, Rules 4661 and 4663, at least as stringent as BAAQMD Reg 8 Rule 11.

C. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 441 (Organic Solvents) amended December 6, 1978

This SMAQMD rule is addressed in t he SJVAPCD Rule 4661 (S olvent Cleaning) RACT-SIP analysis. Staff considers SJ VAPCD solvent requirements, Rules 4661 and 4663, at least as stringent as SMAQMD Rule 441.

D. Ventura County Air Pollution Control District (VCPCD) - No organic solvent

rule.

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, Distric t staff concludes that District Rule 4663 satisfies RACT for organic solvent cleani ng, storage, and disposal operations.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-323 

### Rule 4672 – Petroleum Solven t Dry Cleaning Operations

Emissions Inventory:

Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

VOC 0.06 0.06 0.07 0.07 0.07 0.08 0.08 1.09
(Source: District 2007 Ozone Plan)

District Rule 4672 Description:

The purpose of this rule is to limit VOC em issions from petroleum solvent dry cleaning operations.

The rule requires that petroleum solvent dr y cleaning equipment s hall not be operated if solvent liquid and/or vapor is leaking from any portion of the equipment. Solvents shall

be stored in closed containers. All was her lint traps, button traps, access doors and other parts of the equipment where solvent may be exposed to the atmosphere shall be kept closed at all times except as requi red for proper operation or maintenance. All wastes from dry cleaning facilities subject to Department of Health Services regulation shall be stored, transported and disposed of in accordance with Department of Health Services regulations

.

The rule requires used filtering material to be put into a sealed container immediately after removal from the filter, unless filtering material is fully drained in a sealed filter housing for at least 24 hours before being disca rded (12 hours if dried in a dryer is vented to an emission control device); or pet roleum solvent content in all filtration wastes is reduced to 1.0 kilogram or less pe r 100 kilograms dry weig ht of articles dry

cleaned.

Articles which have been cleaned shall be trans ferred to the dryer within five minutes after they are received from the washer, or shall be stored in closed transfer carts.

The rule requires petroleum solvent dry cleaners to be equipped with a control device which reduces the total emissions of petro leum solvent vapors from drying tumblers, washers, and cabinets by at least 90 percent by weight; or to have a solvent recovery dryer that recovers at least 90 percent of pet roleum solvent by weight. The flow rate of recovered solvent from the solvent recovery dryer at the terminat ion of the recovery cycle shall not exceed 0.05 liters per minute.

Leak inspection must be performed every 15 days and any detected leaks repaired within 3 days of detection.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-324 The rule requires the following records to be maintained and retained for at least two years: (a) usage records - records showi ng amounts of solvents purchased and used; (b) solvent filtration records - records of pr e-washed weight of articles cleaned per load; and (c) solvent filtration waste records - reco rds which indicate the amount of volatile organic compounds contained in the filtration waste material per 100 kilograms dry weight of articles dry cleaned.

How does District Rule 4672 compare wi th federal rules and regulations?

1. EPA – Control Technique Guidelines (CTG)

There is no CTG for this category.

2. EPA – Alternative Control Technology (ACT)

There is no ACT for this category.

3. Standards of Performance fo r Petroleum Dry Cleaners (NSPS)

40 CFR 60 Subpart JJJ, Standards of Perf ormance for Petroleum Dry Cleaners.

This NSPS is applicable to dry cleaners with a rated dryer capacity of 84 pounds or greater. The NSPS requires the use of a solvent recovery dryer for all

installations after 12/14/1982. The flow rate of recovered solvent from the solvent recovery dryer at the termination of the recovery cycle should be no greater than 0.05 liters per minute ( In the rules discussed, this standard is equivalent to 90%

control ). The NSPS also requires the use of cartridge filters, and requires such

filters to be drained in their sealed hous ings for at least 8 hours prior to their

removal.

The NSPS further requires leak inspec tions to be conducted every 15 days, and any detected defects to be repair ed within the subsequent 15 days. This NSPS is less stringent than Distric t Rule 4672 because it applies only to petroleum solvent dry cleaners with a minimum dryer capacity of 84 pounds, whereas District Rule 4672 applies to all petroleum solvent dry cleaners.

In addition, the NSPS requires filter s to be drained for only 8 hours before removal, whereas District Rule 4672 requires at least 12 hours. The NSPS also allows up to 15 days for repair of lea ks, whereas District Rule 4672 requires repairs within 3 days of detection.

Thus, District Rule 4672 is more stringent overall than this NSPS.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-325 4. National Emission Standards for Ha zardous Air Pollutants (NESHAPs) and Maximum Achievable Control Technologies (MACTs)

There is no NESHAP or MACT applicable to this category.

How does District Rule 4672 compare to rules in other air districts?

District staff compared emission limits, opti onal control requirements, and work practice standards in District Rule 4672 to comparable requirements in rule s from the following

California nonattainment areas:

• South Coast AQMD Ru le 1102 (amended 11/17/2000)

• Bay Area AQMD Regulation 8 Rule 17 (amended 9/5/1990)

• Ventura County APCD Rule 74.5.1 (adopted 12/4/1990)

• Sacramento Metro AQMD Rule 444 (adopted 8/13/1981)

1. South Coast AQMD Rule 1102 ( amended 11/17/2000 )

South Coast AQMD rule 1102, Dry Cleaners Using Solvents Other Than Perchloroethylene, is applicable to dry cleaning equipm ent using petroleum solvents.

The rule requires that: (a) all washer lint traps, button traps, a ccess doors, and other parts of the equipment where so lvent may be exposed to the atmosphere shall be kept closed at all times except when required fo r proper operation or maintenance; (b) button and lint traps shall be cleaned each working day; (c) the still residue, used filtering material, lint, used solvent and all other wast es containing solvent shall be stored in sealed containers until properly tr ansported for disposal; (d) for any dry cleaning system that is equipped with cartridge filters cont aining paper or carbon or a combination thereof, the cartridge filters sha ll be fully drained in a sealed filter housing for at least 24 hours before removal; (e) all solvents shall be stored in closed containers; (f) waste water evaporators shall be operated to ensure t hat no liquid solvent or visible emulsion is allowed to vaporize to the atmosphere.

The rule further requires the installation and use of a solvent recovery dryer or an equivalent control device that reduces VOC em issions from drying tumblers by at least 90 percent by weight. Materials which hav e been dry cleaned shall be transferred to the dryer by hand or in an enclosed transfer cart within five minutes after they are removed

from the washer. The rule lim its the amount of solvent used to less than 4.5 pounds per 100 pounds of materials dry cleaned.

Monthly leak inspections are required. Dete cted leaks must be repaired within 3 working days of detection.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-326 Records of solvent usage and leak inspecti ons/detection/repair shall be maintained and retained for at least two years.

In terms of the major emission control requirements such as the use of solvent recovery devices, handling of solvent and solvent-l aden material, and leak inspections and repairs, District Rule 4672 and South Coast AQ MD Rule 1102 are similar. Both rules require the use of a solvent recovery drye r or similar add-on dev ice capable of reducing solvent emissions by at least 90%. Both rules require solvent and solvent-laden

materials to be stored in sealed container s, and both rules require regular leak inspections with prompt repai rs of any detected leaks.

The differences between the two rules are not significant enough to make either rule more or less stringent than t he other. Therefore, District Rule 4672 is at least as stringent as South Coas t AQMD Rule 1102.

2. Bay Area AQMD Regulation 8 Rule 17 (amended 9/5/1990)

The purpose of Bay Area AQMD Regulation 8 Rule 17, Petroleum Dry Cleaning Operation s, is to limit the emissions of petroleum solvents used in dry cleaning facilities.

Small facilities using less than 2,642 gallons of solvent per year are exempt, as long as they maintain records of solvent usage.

The rule stipulates that a person shall not operate petroleum solvent dry cleaning equipment unless: (a) there is no solvent liquid or solvent v apor leaking from any portion of the equipment or the leak ing equipment shall not be operat ed; (b) solvents and spent

solvents are stored in closed c ontainers; (c) all washer and dryer traps, access doors, and other parts of these pieces of equipment where solvent may be exposed to the atmosphere are kept closed at all times except when required for proper operation or maintenance; (d) cartridge filters are drained in the filter housi ng for at least 12 hours or placed in an enclosed device including a solvent recovery dryer until dry before being discarded; (e) all wastes from dry cleaning facilities must be maintained and transported in sealed containers and disposed of in a ccordance with Department of Health Services regulations; (f) articles which have been cle aned must be transferred to the dryer within five minutes after they are removed from the washer, or shall be stored in closed

transfer carts.

The rule also requires the installation and us e of an emission control system on the dry cleaning equipment. The required control me thod may be either: (a) an add-on-control

device which reduces the total emissions of precursor organic compounds by at least 85 percent by weight; or (b) a solvent recovery dryer that recovers at least 85% of petroleum solvent by weight.

To comply with solvent filtration requirem ents, an operator may: (a) use a cartridge filtration system, or (b) reduce the total volat ile organic compound content in all filtration wastes to 1.0 kilogram or less per 100 kil ograms dry weight of articles cleaned (or noSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-327 more than 0.25 kilogram of solvent per kilogr am of solvent still or filter waste) before disposal and exposure to the atmosphere.

The rule requires record keeping only for facilities claiming low usage exemption (records of quantities of solvent used) and thos e not using cartridge filters (records of weights of materials washed). Required reco rds must be maintained for a period of two

years.

District Rule 4672 is more stringent than Bay Area AQMD Regulation 8 Rule 17 because it requires a higher control effi ciency (90%) for emission control add-on devices and solvent recovery dryers. In addition, unlike Bay Area AQMD Regulation 8 Rule 17, District Rule 4672 provides no low- use exemption, requires regular inspection of dry cleaning equipment and pr ompt repair of any leaks or defects, and requires record keeping for all affected facilities.

Thus, District Rule 4672 is more stringent overall than Bay Area AQMD Regulation 8

Rule 17.

3. Ventura County APCD Ru le 74.5.1 (adopted 12/4/1990)

Ventura County APCD Rule 74.5.1, Petroleum Solvent Dry Cleaning , stipulates that a person shall not operate petroleum solvent dry cleaning equipment unl ess: (a) there is no solvent liquid or solvent vapor leaking from any porti on of the equipment or the leaking equipment shall not be operated; (b) solvents and s pent solvents are stored in closed containers; (c) all washer and dryer tr aps, access doors, and ot her parts of these pieces of equipment where solvent may be ex posed to the atmosphere are kept closed at all times except when required for pr oper operation or maintenance; (d) cartridge

filters are drained in th e filter housing for at least 24 hours or 12 hours if further dried in

an enclosed container vented to a control dev ice; (e) all wastes from dry cleaning facilities must be maintained and transported in sealed containers and disposed of in accordance with Department of Health Services regulations; (f) articles which have

been cleaned must be transferred to the dr yer within five minutes after they are removed from the washer, or shall be stored in closed transfer carts.

The rule also requires the installation and us e of an emission control system on the dry cleaning equipment. The required control me thod may be either: (a) an add-on-control

device which reduces the total emissions of precursor organic compounds by at least 90 percent by weight; or (b) a solvent recovery dryer that recovers at least 90% of petroleum solvent by weight.

To comply with solvent filtration requirem ents, an operator may: (a) use a cartridge filtration system, or (b) a filt er system or process that re duces the petroleum solvent content in all filtration wastes to no greater than 1.0 lb per 100 lb dry weight of articles

cleaned.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-328 The rule requires record keeping for weight s of materials cleaned, solvent purchase and usage, hazardous waste disposal, and cartridge f ilter draining and drying operations. All records are to be retained for at least two years.

In terms of the major emission control requirements such as the use of solvent recovery devices, handling of solvent and solvent-lade n materials, and record keeping, District Rule 4672 and Ventura County AP CD Rule 74.5.1 are similar. Both rules require the use of a solvent recovery dryer or add-on device capable of reducing solvent emissions by at least 90%. Both rules require solvent and solvent-laden materials to be stored in sealed containers, and both rules require record keeping for materials cleaned and solvent usage.

The differences between the two rules are not significant enough to make either rule more or less stringent than the other. For instance, Ventura C ounty APCD Rule 74.5.1 does not provide a specific leak inspecti on schedule or require leak inspections and repair records, but at the same time it st ipulates that leaking equipment shall not be operated.

Therefore, District Rule 4672 is at leas t as stringent as Ventura County APCD Rule

74.5.1.

4. Sacramento Metro AQMD Rule 444 (adopted 8/13/1981)

The purpose of Sacramento Metro AQMD Rule 444, Petroleum Solvent Dry Cleaning , is to limit the emissions of petroleum so lvents used in dry cleaning facilities.

Small facilities using less than 2,642 gallons of solvent per year are exempt from

emission control installation r equirements, but must observe emission-limiting operating requirements.

The rule stipulates that a person shall not operate petroleum solvent dry cleaning equipment unless: (a) there is no liquid leaking from any portion of the equipment; (b)

solvents are stored in closed containers; (c) all washer and dryer traps, access doors, and other parts of these pieces of equipment where solvent may be exposed to the atmosphere are kept closed at all times except when required for proper operation or maintenance; (d) still residue is stored in sealed containers or underground tanks, and disposed of by procedures approved by t he Air Pollution Cont rol Officer; (e) used filtering material shall be placed in seal ed containers unless the dry cleaning system uses cartridge filters which are drained in the filter housing for at least 12 hours before removal, diatomaceous earth with centrifugal solvent extractor capable of reducing solvent content to less than 0.4 kg per kg of residue, or other filt ering system capable of reducing solvent content of di scarded filter material to le ss than 1.0 kg per 100 kg of

materials cleaned.

The rule also requires that a person operat ing dry cleaning equipment shall: (a) limit solvent emissions to the atmosphere to an av erage of 3.5 kilograms of solvent per 100San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-329 kilograms of articles dry cleaned, or (b) inst all and operate a solvent recovery dryer in a manner such that the dryer remains closed and the recovery phase continues until a

final recovered solvent flow ra te of not more than 50 millilit ers per minute is attained. ( In the comparable rules discussed, this standard is equivalent to an emission control of

90% ).

Although both District Rule 4672 and Sacramento Metro AQMD Rule 444 have a similar control efficiency (90%) for the dry cleaning emission control devices, District Rule 4672 has more stringent operating requirements for the handling of solvent-laden material, inspections and record keeping. District Rule 4672 requires solvent-laden materials to be transferred into dryers within 5 minutes, r equires regular leak inspections and prompt repairs, and also requires record keeping for weights of materials cleaned, solvent usage and leak inspection and repair. Sacr amento Metro AQMD Rule 444 has no corresponding requirements in these categories.

District Rule 4672 is therefore more stri ngent overall than Sacramento Metro AQMD

Rule 444.

Conclusion

After evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, District staff concludes that District Rule 4672 satisfies RACT for Petroleum Solvent Dry Cleaning Operations.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-330 

### Rule 4681 ( 

### Rubber Tire Manufacturing)

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 0 0 0 0 0 0 0 0

VOC 0.27 0.27 0.27 0. 27 0.27 0.27 0.47 0.53

VOC adjusted* 0 0 0 0 0 0 0 0

*The inventory is suspect. This source category has no active facilities.

I. District Rule 4681 Description:

District Rule 4681 limits the VOC emissions from rubber tire and recapping treadstock manufacturing facilities. The rule specifies emission standards for undertread cementing operations, green ti re coating, bead cementing, and tread end cementing as discussed below. The rule requires container s for organic solvents and cements to be leak-free at all times, and covered ex cept when adding or removing solvents and cements or when the containers are being cleaned or during gauging. The rule includes recordkeeping requirements. T here are no exemptions in the rule. It is important to

mention that there are no existing rubber tire manufacturing facilities currently operating

in the District. A new rubber ti re manufacturing facility that would like to operate in the

District will be evaluated for Best Availabl e Control Technology and emission offset requirements pursuant to District Rule 22 01 (New and Modified Stationary Source Review Rule).

District Rule 4681 Control Requirements

3⁄4 Undertread Cementing Operation

• Enclose the cement applicator, cem ent tank, and tread dryi ng conveyor during normal operations so that VO C evaporation are captured.

• All openings to the enclosure must hav e a minimum indraft of 60 meters per minute, except when it is opened to allow work inside.

• Captured VOC must be transported to an emission control device with at least 95% removal efficiency.

• For new sources, the tread drying c onveyor must operate to capture VOC emissions from the operation for at least 30 seconds after undertread cement has been applied.

• As an alternative control, an equival ent reduction technique approved by the

APCO is allowed if the undertread cement emissions are reduced to15 grams VOC or less per tire (daily average)

3⁄4 Green Tire Coating OperationSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-331 • Coating must be waterborne, no more than one percent by weight if based on formulation data or 10 grams/lit er of coating, includi ng water but less exempt compounds, if determined by testing.

3⁄4 Bead Cementing Operation

• Operate an APCO approved emission c ontrol system or demonstrate that emissions, in grams/tire, from bead ce menting operation have been reduced by at least 75% from the daily average for 3 co nsecutive years prior to rule adoption. A carbon adsorption must have at l east 95% VOC removal efficiency and equipped with continuous VOC monitori ng equipment to detect carbon bed breakthrough. An incineration system must oxidize at least 90% of VOC which

enters the incinerator and equipped with temperatur e indicators in the

combustion chambers. The collecti on system must achieve at least 85% collection efficiency.

3⁄4 Tread End Cement ing Operation

• Operate an approved emission contro l system as described above for bead cementing operation or demons trate that emissions, in grams/tire, from tread end cementing operation have been reduced by at least 62% from the daily average for 3 consecutive years prior to rule adoption.

II. How does District Rule 4681 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

1. EPA-450-2-78-030 (Control of Volatile Or ganic Emissions from Manufacture of Pneumatic Rubber Tires), December 1978

This CTG establishes the recommended standar ds to control of VOC emissions from rubber tire manufacturing plants through tight control of solvent operations and the use of effective capture systems and exhaust tr eatment devices. VOCs are added to rubber components to aid in mixing, promote elas ticity, produce tack (s tickiness, or extend (replace) a portion of the r ubber hydrocarbons. The CTG recommendation to reduce solvent emissions is based on lowering the solvent content of the raw material and treating the exhaust gas. The four majo r sources of VOC emissions from tire manufacturing and the control technology for each that is considered reasonably

available are discussed below.

3⁄4 Undertread Cementing

• Carbon adsorption system with a capture efficiency of 65% to 85% and control device efficiency of 95%. The overall c apture and control efficiency is 62% to 81%; or

• Incineration system with a capture effi ciency of 65% to 85% and a control device efficiency of 90%. The overall captur e and control efficiency is 59% to 77%.

3⁄4 Green Tire SprayingSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-332 • Waterbased coating (overall efficiency of 97% depending on formulation; or

• Carbon adsorption system with a capture efficiency of 80% to 90% and control device efficiency of 95%. The overall c apture and control efficiency is 76% to 86%; or

• Incineration system with a capture effi ciency of 65% to 85% and a control device efficiency of 90%. The overall captur e and control efficiency is 59% to 77%.

3⁄4 Bead Dipping

• Carbon adsorption system with a capture efficiency of 75% to 85% and control device efficiency of 95%. The overall c apture and control efficiency is 71% to 81%; or

• Incineration system with a capture effi ciency of 75% to 85% and a control device efficiency of 90%. The overall captur e and control efficiency is 68% to 77%.

3⁄4 Tread End Cementing

• Carbon adsorption system with a capture efficiency of 65% to 85% and control device efficiency of 95%. The overall c apture and control efficiency is 62% to 81%; or

• Incineration system with a capture effi ciency of 65% to 85% and a control device efficiency of 90%. The overall captur e and control efficiency is 59% to 77%.

Comparison of CTG and District Rule 4681

District Rule 4681 emission control require ments (carbon adsorpt ion: 95% control efficiency and 85% capture efficiency; inci neration: 90% control efficiency and 86% capture efficiency) are more stringent than the capture and control efficiency standards for each major source of VOC emissions fr om tire manufacturing recommended by the CTG. It is important to ment ion that there are no rubber tire manufacturing facilities currently operating in the Distric t. If a new rubber tire m anufacturing facility wants to operate in the District in the future, it will be evaluated for Best Available Control Technology and emission offset requirements pursuant to District Rule 2201 (New and Modified Stationary Source Review Rule). Based on the above discu ssion, District staff

deems that District Rule 4681 satisfies RACT.

B. EPA – Alternative Control Techniques (ACT) Document

District staff’s review of the EPA ACT list indi cates that there is no ACT for rubber tire manufacturing.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-333 C. Standards of Performance fo r New Stationary Sources (NSPS)

1. 40 CFR 60 Subpart BBB (Standards of Performance for the Rubber Tire Manufacturing Industry)

This NSPS applies to rubber tire manuf acturing plants (each undertread cementing oepration, each sidewall cem enting operation, each tread end cementing operation, each bead cementing operation, each green tire spraying operation, each Michelin-A operation, each Michelin-B oper ation, and each Michelin-C automatic operation) that commence construction, modification, or reconstruction after January 20, 1983. The NSPS requires operators to meet the follo wing standards:

3⁄4 Each Undertread Cementing Operation

• Discharge into the atmosphere no mo re than 25% of t he VOC used (75% emission reduction) for each month; or

• Maintain total (uncontrolled) VOC use less than or equal to 8,531 lb VOC per 28 days, 8.846 lb VOC/29 days, 9,149 lb VO C per 30 days, 9,436 lb VOC per 31 days, or 10, 670 lb VOC per 35 days.

3⁄4 Each Sidewall Cementing Operation

• Discharge into the atmosphere no more than 25% of the VOC used (75% emission reduction) for each month; or

• Maintain total (uncontrolled) VOC use less than or equal to 7,099 lb VOC per 28 days, 7,363 lb VOC per 29 days, 7,606 VO C per 30 days, 7,870 lb VOC per 31 days, or 8,885 lb VOC per 35 days.

3⁄4 Each Tread End Cementing Operation: Discharge no more than 10 grams (0.022 lb) VOC per bead cemented for each month.

3⁄4 Each Bead Cementing Operation: Di scharge no more than 5 grams (0.011 lb) VOC per bead cemented for each month.

3⁄4 Each Green Tire Spraying Operation using only water based sprays: Discharge no more than 1.2 grams (0.0026 lb) VOC per tire sprayed with an inside green tire spray for each month and no more than 9.3 grams (0.021 lb) VOC per tire sprayed with an outside green tire spray each month.

3⁄4 Each Green Tire Spraying Operation us ing only organic solvent-based sprays: Discharge no more than 25% of the VOC us ed (75% reduction) for each month; or maintain total (uncontrolled) VOC use le ss than or equal to 7,099 lb VOC per 28 days, 7,363 lb VOC per 29 days, 7,606 VOC per 30 days, 7,870 lb VOC per 31 days, or 8,885 lb VOC per 35 days.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-334 3⁄4 Each Green Tire Spraying Operation where both waterbased and organic solventbased sprays are used: Discharge no more t han 1.2 grams (0.0026 lb) VOC per tire sprayed with waterbased inside green tire spray for each month and no more than 9.3 grams (0.021 lb) VOC per tire spray ed with waterbased outside green tire spray for each month; and either discharge no more than 25% of the VOC used in organicsolvent-based green tire sprays (75% reduction) for each month or maintain total (uncontrolled) VOC use less than or equal to 7,099 lb VOC per 28 days, 7,363 lb VOC per 29 days, 7,606 VOC per 30 days, 7,870 lb VOC per 31 da ys, or 8,885 lb VOC per 35 days.

3⁄4 Each Michelin-A Operation

• Discharge no more than 35% of the VOC used (65% reduction) for each month;

or

• Maintain total (uncontrolled) VOC use le ss than or equal to 3,461 lb VOC per 28 days, 3,593 lb VOC per 29 days, 3,726 lb VOC per 30 days, 3,836 lb VOC per 31 days, or 4,343 lb VOC per 35 days.

3⁄4 Each Michelin-B Operation

• Discharge no more than 25% of t he VOC used (75% reduction); or

• Maintain total (uncontrolled) VOC use le ss than or equal to 2,888 lb VOC per 28 days, 2,998 lb VOC per 29 days, 3,086 lb VOC per 30 days, 3,197 lb VOC per 31 days, or 3,616 lb VOC per 35 days.

3⁄4 Each Michelin-C Operation

• Discharge no more than 55% of t he VOC used (75% reduction); or

• Maintain total (uncontrolled) VOC use less than or equal to 3,461 lb VOC per 28 days, 3,593 lb VOC per 29 days, 3,726 lb VOC per 30 days, 3,836 lb VOC per 31 days, or 4,343 lb VOC per 35 days.

Operators of each undertread cementing operation and each sidewall cementing operation in rubber tire manufacturing plants that commenced construction modification, or reconstruction after January 20, 1983 and before September 15, 1987 has the option of complying with Section 60.542a (alter nate standard for VOC) which prohibits discharge into the atmosphere no more than 25 grams (0.55 lb) VOC per tire processed for each month if the operation uses 25 grams (0.055 lb) or less VOC per tire processed and does not employ a VOC emission reduction system.

Comparison of NSPS and District Rule 4681

District Rule 4681 emission control requirement s overall, are more stringent than the NSPS standards. For undertread cementing oper ation, District rule 4641 requires an overall capture and control efficiency of at least 80% for carbon adsorption or 76% for

incineration while the NSPS only require 75% emission reduction. For green tire spraying, District Rule 4681 only allows wa terborne coating which contains no more than one percent by weight if based on formul ation data or 10 grams/ liter of coating, including water but less exempt compounds, if determined by testing, while the NSPSSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-335 allows the use of both waterbased and organic solvent-based coatings that meet certain requirements as discussed above. Although District Rule 4681 does not specify any emission standards for Michelin, the overall capture and control efficiency of District Rule 4681 is more stringent than NSPS emission reduction standard of 65% for Michelin-A, 75% for Michelin-B, and 65% for Michelin-C operations.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

NESHAPs and MACTs are requirements contai ned in 40 Code of Federal Regulations (CFR) Part 61 and 40 CFR Part 63. Si nce EPA has delegated the authority to implement NESHAP requirements to the Dis trict, NESHAPs and MACTs promulgated by EPA are usually incorporated by reference into District Rule 4002 (National Emission

Standards for Hazardous Air Pollu tants). It is impor tant to mention that the District implements NESHAPs and MACTs by inco rporating the emission standards as

conditions of the Permits to Operate issued to affe cted sources.

1. 40 CFR Part 63 Subpart XXXX (NESHAP for Rubber Tire Manufacturing)

This NESHAP applies to a rubber ti re manufacturing that is located at, or is a part of, a major source of HAP emission. A major so urce of HAP emission is any stationary soruce or group of stationary source wit hin a contiguous area and is under a common control that emits or has the potential to em it considering controls, in the aggregate, a single HAP at a rate of 9.07 megagrams (10 tons) or more per year or any combination of HAP at a rate of 22.68 megagrams (25 to ns) or more per year . This NESHAP does not apply if the primary product produced at t he affected major source is subject to another subpart under this part 63 as of the effe ctive date of this subpart, or start of the source, which ever is later; or if the r ubber tire manufacturing affected source is a research and development facility whose prim ary purpose is to conduct research and development into new processes and products, where such a source is operated under the close supervision of technically trained personnel and is not engaged in the manufacture of products for commercial use for commercial sale in commerce, except

in a de minimis manner. An affected sour ce is a new affected source if a new

construction if construction of the affect ed source commenced after October 18, 2000 and it meets the applicability criteria di scussed above. An affected source is

reconstructed if it meets the criteria as defined in 40 CFR Part 63 Subpart A Section 63.2. An affected source is existing if it is not a new or reconstructed.

This NESHAP specify emission limits for ti re production, tire cord production, and puncture sealant application. For tire produc tion or tire cord production, there are two compliance options: HAP constituent opti on or production-based option, both options have specified HAP limits. For puncture sealant application, there two compliance options: percent reduction option (measured as VOC emissions) or HAP constituent option. The percent reduction option includes operating limits for co ntrol devices. InSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-336 addition, the NSPS includes monitoring, oper ation, maintenance, recordkeeping and reporting requirements.

Comparison of NESHAP and District Rule 4681

It is important to mention that the NESHAP HAP emission limits which are expressed in terms of mass (kg) of HAP per mass of cement s, solvents, sealants or coatings used at the tire production operation ar e not directly comparable to t he VOC limits of District rule 4681 because, some HAPs may be exempt VOCs, and some VOCs may be HAPs; therefore, there is no direct correlation between the NESHAP limit versus District Rule 4681 VOC limits. In addition, District Ru le 4681 emission limits cannot be directly compared to the NESHAP limits because Dis trict Rule 4681 specify the limits for undertread cementing, green ti re coating, bead cementi ng, and tread end cementing rule while the NESHAP specify the limits fo r tire production, tire cord production, and puncture sealant application.

III. How does District Rule 4681 compar e to rules in other air districts?

District staff compared District Rule 4641 with the rules of other California ozone

nonattainment air districts’ rules on rubber tire manufacturing. Except for the Bay Area Air Quality Management District, South Coast Air Quality Management District, Sacramento Metropolitan Air Q uality Management Air Distric t, and Ventura County Air

Pollution Control District have no rules for th is source category. The result of the analysis of the BAAQMD rule is discussed below.

1. Bay Area Air Quality Management Dis trict (BAAQMD) Regulation 8 Rule 21 (Rubber Tire Manufacturing Oper ations) adopted March 5, 1980

BAAQMD Regulation 8 Rule 21 limits the emissi ons of volatile organic compounds from pneumatic rubber tire manufactu ring operations. The rule does not apply to operations applying new tread to used tires (exempts re tread operations). Fo r cementing and bead dipping operations, the rule requires the oper ation of an emission control system with at least 85% capture efficiency and 95% control effi ciency. For green tire coating, the rule requires the use of waterbase (less than 3% VOC) coatings only or the operation of a collection system with at leas t 90% collection efficiency and a control device with at least 95% efficiency. An alternative co mpliance option, an operat or may comply with the rule through an APCO-approved emission control plan provided the emissions of VOC, on a daily weighted aver age, is no greater than the am ount which would result if the affected operations complied with the specified limits for cementing and bead dipping operation, and green tire coating operation. In additi on to the emission limits, the rule requires containers for organic solv ents or cements contai ning organic solvents to be covered at all times except when clea ning or adding or removing material, and any leaks must be repaired immediately.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-337 Comparison of BAAQMD Regulation 8 Rule 21 and District Rule 4681

BAAQMD Regulation 8 Rule 21 exempts retr ead of used tires while District Rule 4681 does not have such exemption. BAAQMD Regulation 8 Rule 21 green tire coating requirements allow the use of waterbase co ating with a VOC cont ent of no more than 3% or operate an emission cont rol system with at least 85% capture efficiency and 95% control efficiency. In cont rast, District Rule 4681 only allows the use of waterbase coating with no more than 1% by weight which is more stringent than BAAQMD Regulation 8 Rule 21 VOC lim it of 3%. Both BAAQMD Regulation 8 Rule 21 and

District Rule 4681 have the same emissi on control system capture and control efficiencies for cementing and bead di pping operations. Based on the above discussion, District staff deems that overa ll, District Rule 4681 is as stringent as BAAQMD Regulation 8 Rule 21.

IV. Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, Distric t staff concludes that District Rule 4681

satisfies RACT for rubber tire manufacturing. It is important to mention that there are no existing rubber tire manufacturing facilitie s currently operating in the District. A new rubber tire manufacturing facility that w ould like to operate in the District will be

evaluated for Best Available Control Tec hnology and emission offset requirements pursuant to District Rule 2201 (New and Modifi ed Stationary Source Review Rule). Based on the above discussion, District staff deems that District Rule 4681 satisfies

RACT.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-338



### Rule 4682 – Polystyrene, Polyethyl ene, and Polypropylene Products Manufacturing

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 0.128 0.143 0.154 0.157 0.165 0.175 0.185 0.194

VOC 0.32 0.35 0.37 0. 39 0.43 0.46 0.49 1.39
(Source: District 2007 Ozone Plan)

District Rule 4682 Description:

The purpose of this rule is to limit emi ssions of VOC and trichl orofluoromethane (CFC11) and dichlorofluoromethane (CFC-12) from manufacturing and processing of products composed of polystyrene, polyethylene, or polypropylene and from the storage of VOC blowing agents. The pr ovisions of this rule shall apply to any manufacturing, processing, and storage of products com posed of polystyrene, polyethylene, or polypropylene. The provisions of this rule shall not apply to manufacturing and processing operations using polymeric materials containing less than 1 percent volatile organic compounds by weight, and not using a blowing agent in their process.

District Rule 4682 requires that no facilit y shall operate controllable VOC emission sources at a polystyrene foam , polyethylene, or polypro pylene manufacturing or processing operation unless one of the follo wing VOC emission reduction methods is provided:

• A blowing agent other t han a VOC or trichlorofl uoromethane (CFC-11) or dichlorodifluoromethane (CFC-12) is exclusively used; or

• A system designed to achieve at least 90 percent VOC capture efficiency, and a thermal oxidizer which abates captured VO C emissions by at least 95 percent by weight; or

• VOC emissions are controlled by a method which achieves an emission reduction equivalent to Section 5.1. 2 and which does not include the use of trichlorofluoromethane (CFC -11) or dichlorodifluor omethane (CFC-12), and is approved by the APCO.

On September 20, 2010, operations shall not conduct any manufacturing operations, as defined in Section 3.0, unless one of the fo llowing emission reduction methods is met:

• The operator demonstrates, to the satisfac tion of the APCO, that the total product emissions do not exceed 2.4 pounds of VO C per 100 pounds of total material processed, calculated ov er a monthly period.

• A blowing agent other t han a VOC or trichlorofl uoromethane (CFC-11) or dichlorofluoromethane (CFC-12) is exclusively used.

• An approved emission control system is installed and operating with manufacturing emissions vented only to the approved emission control system;San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-339 and emissions from the final manufactur ed product are to be vented only to the approved emission control system. The rule requires that the control device shall have a capture and control efficiency of 93%. This is greater than the previous emission control system requirements of 90% capture and 95% control (85.5% capture and control efficiency).

• The operator demonstrates to the satisfaction of the APCO that the manufacturing emissions are no greater t han the facility emissions which would

occur under Section as calculated accordin g to Section 5.5, and which does not

include the use of trichl orofluoromethane (CFC-11) or dichlorodifluoromethane (CFC-12).

How does District Rule 4682 compare wi th federal rules and regulations?

1. EPA – Control Technique Guidelines (CTG)

EPA-450/3-83-006 Control of Vola tile Organic Compound Emissions from Manufacture of High-Density Polyethylene, Po lypropylene, and Polystyrene Resins.

The CTG applies to equipment in process units operated to produce one or more of the synthetic organic chemicals listed in A ppendix E of the pr oposed standards of performance for SOCMI (46 FR 1136, January 5, 1981) ,methyl tert-butyl ether (MTBE), polyethylene, polypropylene, and polystyrene . District Rule 4682 applies to the manufacturing, processing, and storage of products composed of polystyrene, polyethylene, or polypropylene. Sinc e the CTG applies to the manufacturing of polyethylene, polypropylene, and polystyrene , and District Rule 4682 applies to the manufacturing of products made with polyethylene, polyp ropylene, and polystyrene, these two regulations are not regulating the same equipment. Therefore, this CTG and District Rule 4682 will not be compared.

EPA-450/3-83-008 Control of Vola tile Organic Compound Emissions from Manufacture of High-Density Polyethylene, Po lypropylene, and Polystyrene Resins.

This CTG covers the polymers and resins in dustry. The polymers and resins industry includes operations that c onvert monomer or chemical in termediate materials obtained from the basic petrochemical industr y and the synthetic organic chemicals manufacturing industry into polymer products. Such products include plastic materials, synthetic resins, synthetic rubbers, and organic fibers.

This CTG states that the following emissi on reductions or limitations are considered representative of RACT:

• For polypropylene plants using liquid phase processes: a 98 weight percent reduction or reduction to 20 ppm of continuous VOC emissions from the polymerization reaction section (i.e., reacto r vents), the material recovery section (i.e., decanter vents, neutralizer vent s, by-product and diluent recovery operations vents), and the product finish ing section (i.e., dryer vents and extrusion and pelletizing vents).San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-340 • For high-density polyethylene plants usi ng liquid phase slurry processes: a 98 weight percent reduction or reduction to 20 ppm of continuous VOC emissions from the material recovery section (i.e ., ethylene recycle treater vents) and the product finishing section (i.e., dryer v ents and continuous mixer vents).

• For polystyrene plants using continuous proc esses: an emission limit of 0.12 kg VOC/1,000 kg product from the material recovery section (i.e., product devolatilizer system).

District Rule 4682 requires that the operators use a blowing agent that does not contain VOCs or use a control system that has a co mparable capture and control efficiency that

is discussed as RACT in this CTG. Ther efore, District Rule 4682 and this CTG have equivalent emission lim iting requirements.

2. EPA – Alternative Control Technology (ACT)

EPA-450/3-90-020 Control of VOC Emissions From Polystyrene Foam Manufacturing.

The purpose of this study was to conduct a survey of the polystyrene foam manufacturing industry to characterize the industry, define the nature and scope of volatile organic compound (VOC) emissions from this source category, identify potential controls for reducing VOC emissions, and dev elop cost estimates for VOC capture and control technologies.

This ACT lists the following major findi ngs concerning VOC emission controls: Incineration and carbon adsorpt ion have been demonstrated as readily available add-on control technology for reducing VOC emissi ons, and the use of alternative blowing agents in place of CFC and hydrocarbon blo wing agents has been implemented. Since District Rule 4682 requires that the facility either exclusively uses a blowing agent that is not a VOC, CFC-11 or CFC-12, or installs an approved control device to control VOC emission, the requirements of District Rule 4682 are equivalent to the ACT.

3. Standards of Performance for New Stationary Sources (NSPS)

Subpart DDD — Standards of Performance for Volatile Organic Compound (VOC) Emissions from the Polyme r Manufacturing Industry.

The provisions of this subpart apply to affect ed facilities involved in the manufacture of polypropylene, polyethylene, polystyrene, or poly (ethylene terephthalate). The affected facilities designated below for polypropyl ene and polyethylene are inclusive of all equipment used in the manufac ture of these polymers, beginning with raw materials preparation and ending with product storage, and cover all emissions emanating from such equipment.

This subpart requires the following actions be taken from various different types ofSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-341 operations:

Polypropylene, low density polyethylene, and high density poly ethylene Continuous

Emissions: Operations shall reduce emissions of total organic compounds (minus methane and ethane) (TOC) by 98 weight percent, or to a concentration of 20 parts per million by volume (ppmv) on a dry basis, whichever is less stringent. In addition, the facility may control VOC emissions by combusting the ex haust in a boiler or steam generator with a heat input greater than 150 MMBtu /hr or combust in a flare.

Polypropylene, low density polyethylene, and high density polyethylene Intermittent

Emissions: Operations shall control VOC emissions by combusting the exhaust in a boiler or steam generator or combust in a flare.

Polystyrene: Operators shall show not a llow continuous TOC emissions to be greater than 0.0036 kg TOC/Mg (0.0072 lb TOC/ton) product; or allo w the outlet gas stream temperature from

each final condenser in the material recovery section to exceed

− 25 °C (

− 13 °F).

Polyethylene: Each owner or operator of a PET process line using a dimethyl terephthalate process

shall limit the continuous TOC emissions fr om the material reco very section (i.e., methanol recovery) or limit the continuous TO C emissions and, if st eam-jet ejectors are used to provide vacuum to the polymer ization reactors, the ethylene glycol concentration from the polym erization reaction secti on by complying with the appropriate standard set forth below.

Each owner or operator of a PET process li ne using a terephthalic acid process shall

not allow the continuous TOC emissions fr om the esterification vessels in the raw materials preparation section to be greater than 0.04 kg TOC/Mg (0.08 lb TOC/ton) product or shall limit the contin uous TOC emissions and, if steam-jet ejectors are used to provide vaccum to the polymerization reacto rs, the ethylene glycol concentration from the polymerization reaction section by comp lying with the appropria te standard set forth

below.

District Rule 4682 requires that no facility shall operate controllable VOC emission sources at a polystyrene foam, polyethylene, or polypropylene manufacturing or processing operation unless one of the following VOC emissi on reduction methods is provided:

• A blowing agent other than a VOC or trichlorofluoromet hane (CFC-11) or dichlorodifluoromethane (CFC-12) is exclusively used; or

• A system designed to achieve at least 90 percent VOC capture efficiency, and a thermal oxidizer which abates captured VO C emissions by at least 95 percent by weight; orSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-342 • VOC emissions are controlled by a method which achieves an emission reduction equivalent to Section 5.1. 2 and which does not include the use of trichlorofluoromethane (CFC -11) or dichlorodifluor omethane (CFC-12), and is approved by the APCO.

On and after September 20, 2010, the require ments to meet comp liance with District Rule 4682 will become more stringent. The curr ent requirements are as stringent as the requirements of Subpart DDD, therefore the increase in the stringen cy of the rule will assure that District Rule 4682 remains as stringent as Subpart DDD.

Subpart DDD requires the following monitoring requirements:

• Whenever a particular item of monitoring eq uipment is specified in this section to be installed, the owner or operator sha ll install, calibrate, maintain, and operate according to manufacturer's specifications.

• The owner or operator shall install, as applicable, the monitoring equipment for the control means used to comply with §60.562–1, except §60.562–1(a)(1)(i)(D).

• Owners or operators of contro l devices used to comply wit h the provisions of this subpart, except §60.562–1(a)(1)(i)(D), shall monitor these control devices to ensure that they are operated and mainta ined in conformance with their designs.

• An owner or operator complying with the standards specified under §60.562–1, except §60.562–1(a)(1)(i)(D), with control devices other than an incinerator, boiler, process heater, flare, absorber, c ondenser, or carbon adsorber or by any other means shall provide to the Admi nistrator information describing the operation of the control device and t he process parameter(s) which would indicate proper operation and maintenance of the device. The Administrator may request further information and will specif y appropriate monitoring procedures or requirements.

District Rule 4682 requires monitoring requi rements and recordkeeping requirements that are as stringent as S ubpart DDD. Therefore the requi rements of District Rule 4862 are as stringent as Subpart DDD.

How does District Rule 4682 compare to rules in other air districts?

District staff compared VOC lim its, optional control require ments, and work practice standards in District Rule 4682 to comparable requirements in rule s from the following

California nonattainment areas:

• South Coast AQMD Rule 1175, as amended September 7, 2007

• Bay Area AQMD Regulation 8 Rule 52, as adopted July 7, 1999

• Sacramento Metro AQMD does not have a spec ific prohibitory rule for this source category.

• Ventura County APCD does not have a specif ic prohibitory rule for this source category.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-343 1. South Coast AQMD Rule 1175

South Coast AQMD Rule 1175 (Control of Emissions From the Manufacture of Polymeric Cellular (Foam) Products) applies to polymeric cellular products manufacturing operations including but not limited to expandable polystyrene, polystyrene foam extrusion, polyurethane, isocyanurate and phenolic foam operations. All steps of the manufacturi ng operation and the storage of the final product for a maximum of 48 hours. District Rule 4682 is applic ation to the same types of operations.

SCAQMD Rule 1175 defines an approved emi ssion control system as a system that captures 90% of the manuf acturing and storage emissions , and reduces 95% of the emissions captured. District Rule 4682 has t he same definition for an approve emission control system.

SCAQMD Rule 1175 requires that manuf acturing operations excluding expandable polystyrene mold operations discontinue the us e of CFCs, VOCs, or methylene chloride

and to reduce their annual emissions from th eir 1988 emissions baseline by 100% by 1994. SCAQMD Rule 1175 also require s that expandable polystyrene molding operations demonstrate that the manufacturing emissi ons and post-manufacturing

emissions are less than 2.4 lbs/ 100 lbs of raw material processed. District Rule 4682 states that starting September 20, 2010, the facility shall show compliance with the rule by either demonstrating t hat the manufacturing emi ssions and post-manufacturing

emissions are less than 2.4 lb s/100 lbs of raw material pr ocessed, a blowing agent

other than a VOC or CF C is exclusively used or an approved emission control system is installed and operating, District Rule 4682 has equivale nt requirements to the requirements of SCAQMD Rule 1175 ther efore these two rules have equivalent emissions requirements.

In addition, the monitoring and testing r equirements of SCAQ MD Rule 1175 are equivalent to that of District Rule 4682.

2. Bay Area AQMD Regulation 8 Rule 52

Bay Area AQMD Regulation 8 Rule 52 (Pol ystyrene, Polypropylene, and Polyethylene Foam Product Manufacturing Operations) applies to the manufacturing of foam products composed of polystyrene, polyethylene or polypropylene. District Rule 4682 is application to the same types of operations.

BAAQMD Reg 8 Rule 52 states that polystyr ene foam product manufacturing operations shall not manufacture polystyrene foam products within the District unless, for each 100 pounds of raw material processed, VOC emis sions, which include emissions from the product manufacturing operation and residual blowing agent in the finished foam product, do not at any time exceed:

• 2.8 pounds for expandable polystyrene cup molding product manufacturing operations; orSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-344 • 2.7 pounds for expandable polystyr ene shape and block molding product manufacturing operations; or

• 2.4 pounds for loose fill product manufacturing operations; or

• 2.4 pounds for extruded polystyr ene foam board and sheet product manufacturing operations.

District Rule 4682 states that starting Sept ember 20, 2010, the facility shall show compliance with the rule by either demonstr ating that the manufacturing emissions and post-manufacturing emissions are less than 2.4 lbs/100 lbs of raw material processed.

Since this is the lowest limit listed by BAAQMD Reg 8 Rule 52, the emission requirements of District Rule 4682 is as stringent as the BAAQMD rule.

BAAQMD Reg 8 Rule 52 states that a pers on shall not manufacture polyethylene or polypropylene foam products wit hin the District unless at l east 85% by weight of the VOC emissions from the product manufactu ring operation are captured and vented to an abatement device with a control efficiency of at least 98% by weight at all times. District Rule 4682 states that an approved em ission control system is a system that captures 90% of the manuf acturing and storage emissions, and reduces 95% of the emissions captured. Theref ore, the emission control syst em requirements of District Rule 4682 are equivalent to that of BAAQMD Reg 8 Rule 52.

BAAQMD Reg 8 Rule 52 requires that the facili ty maintain the type of resin(s) and blowing agent(s) used in product manufactu ring operations, the amount of polymerized styrene, ethylene, propylene, and blowing agent in each resin formulation used in percent by weight as indicat ed by the specifications of the foam product manufacturer, and the manufacturer or supplier of the raw polymeric materi al. In addition, monthly records of the amount of each raw polymeric material processed, the amount of each finished foam product manufactured, the am ount of each VOC blowing agent used, and the hours of operation shall be maintained. Since District Rule 4682 has similar monitoring and recordkeeping requirements, it can be considered equivalent to BAAQMD Reg 8 Rule 52.

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, Distric t staff concludes that District Rule 4682 satisfies RACT for polystyrene, polyet hylene, and polypropylene manufacturing operations.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-345 

### Rule 4684 – Polyester Resin Operations

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 0.02 0.02 0.02 0. 02 0.03 0.03 0.03 0.03

VOC 0.35 0.38 0.40 0. 40 0.47 0.49 0.52 0.72
(Source: District 2007 Ozone Plan)

District Rule Description:

This rule includes commercial and industrial polyester resin operations, organic solvent cleaning, and the storage and disposal of all solvents and waste solvent materials associated with such operations. The polye ster resin users typically are making composite materials, meaning mixing the resin with glass fiber to make a product. This rule also covers manufacturers of boats and ya chts as well as those making fiberglass shower units. Polyester resin operations that used less than 20 ga llons per month are exempt from the requirem ents of this rule.

This rule requires polyester resin operations to use low-VOC polye ster resins with the following monomer content: Low VOC resins, ex cept for specialty resins and gel coats, contain no more than 35% monomer by wei ght. Low VOC pigmented gel coats contain no more than 45% monomer by weight. Low VO C specialty resins and clear gel coats, contain no more than 50% monomer by we ight; or use resin containing a vapor suppressant, such that the weight loss fr om the VOC emissions does not exceed 60 grams per square meter of exposed surface during resin polymerization; or use a closed-mold system; or install and oper ate a VOC emissions control system.

How does District Rule 4684 compare wi th federal rules and regulations?

1. EPA – Control Technique Guidelines (CTG)

EPA-450/3-83-006 Control of Vola tile Organic Compound Emissions from Manufacture of High-Density Polyethylene, Po lypropylene, and Polystyrene Resins.

The CTG applies to equipment in process units operated to produce one or more of the synthetic organic chemicals listed in Appendix E of the proposed standards of performance for SOCMI (46 FR 1136, January 5, 1981), meth yl tertiary-butyl ether (MTBE), polyethylene, polypropylene, and polyst yrene. District Rule 4684 applies to commercial and industrial polyester resin operations, organic solvent cleaning, and the storage and disposal of all solvents and waste solvent materials associated with such operations. Since the CTG applies to the ma nufacturing of polyethylene, polypropylene, and polystyrene, and District Rule 4684 applies to the manufacturing of products madeSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-346 with polyester resin, these two regulations are not regul ating the same equipment. Therefore, this CTG and District Rule 4684 will not be compared.

EPA-450/3-83-008 Control of Vola tile Organic Compound Emissions from Manufacture of High-Density Polyethylene, Po lypropylene, and Polystyrene Resins.

This CTG covers the polymer and resin i ndustry. The polymer and resin industry includes operations that c onvert monomer or chemical in termediate materials obtained from the basic petrochemical industr y and the synthetic organic chemicals manufacturing industry into polymer products. Such products include plastic materials, synthetic resins, synthetic rubbers, and or ganic fibers. This CTG only addresses the control of emissions from high-densit y polyethylene, polypropylene, and polystyrene resin operations. District Rule 4684 only ad dresses emissions from polyester resin operations. Therefore these tw o regulations are not applicab le to the same equipment and will not be compared.

EPA-453/R-08-004 Control Technique for Fibergl ass Boat Manufacturing Materials

This CTG provides control recommendatio ns for reducing VOC emissions from the use of gel coats, resins, and materi als used to clean application equipment in fiberglass boat manufacturing operations.

The CTG lists the available controls opti ons for resin and gel coal as follows:

• Low monomer VOC resins and gel coats.

• Vapor suppressed resins and gel coats.

• Non-atomizing resin applications.

• Closed Molding.

• Add on control systems.

The CTG requires the following in order to meet the recommended open molding resin and gel coat limits: (1) achieve the indivi dual monomer VOC cont ent limit through the use of low-monomer VOC materials, either by using only low monomer VOC materials within a covered operation, or by averaging the monomer VOC contents for all materials used within an operation on a weight-adjusted basis; (2) meet the

numerical monomer VOC emission rate limits, which woul d enable a facility to average emissions among different operations usi ng equations to esti mate monomer VOC emission rates from each oper ation based on the material and application method; or (3) use add-on controls to achieve a numeric al monomer VOC emission rate that is determined for each facility based on the mix of application methods and materials used at that facility.

The CTG’s limitations for open molding operations are listed in the table below. These

are also the same limitations found in 40 CFR 63 Subpart VVVV.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-347 Organic HAP Content Requirements

Operation Type Application Method Organic HAP content (weight percent) requirement
Production Resin Operations Atomized 28 Production Resin Operations Nonatomized 25 Pigmented Gel Coat Operations Any method 33

Clear Gel Coat Any method 48 Tooling Resin Operations Atomized 30 Tooling Resin Operations Nonatomized 39 Tooling Gel Coat Operations Any Method 40

District Rule 4684 contains requirements that would require a polyester resin operation to either use resins and gel coats that m eet monomer content lim its or install an add on

emission control device. As shown in the table above, the monomer content limits of the CTG are more stringent than those of District Rule 4684. The add on emission control device requirements are equi valent for both regulations.

2. EPA – Alternative Control Technology (ACT)

There is no ACT for this source category.

3. Standards of Performance for New Stationary Sources (NSPS)

There is no NSPS for this source category.

4. National Emission Standards for Ha zardous Air Pollutants (NESHAPs) and Maximum Achievable Control Technologies (MACTs)

Subpart VVVV—National Emission Standards for Hazardous Air Pollutants for Boat Manufacturing

This subpart establishes nat ional emission standards for hazardous air pollutants (HAP) for new and existing boat manufacturing fac ilities with resin and gel coat operations, carpet and fabric adhesive oper ations, or aluminum recreat ional boat surface coating operations. This subpart also establishes requirements to demonstrate initial and continuous compliance with the emission standards. The applicability of this subpart is equivalent to that of District Rule 4684.

Subpart VVVV states that you may show comp liance with the subpart by using one of the following options for the resins and gel coats used in open molding operations at your facility:

(a) Maximum achievable control technology (MACT) model point value averaging (emissions averaging) option

. (1) Demonstrate that emissions from the open molding resin and gel coat operations that you average meet the emission limitSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-348 in §63.5698 using the procedures descri bed in §63.5710. Compliance with this option is based on a 12-m onth rolling average. (2) Those operations and materials not included in the emissions average must comply with either paragraph (b) or (c) of this section.

(b) Compliant materials option

. Demonstrate compliance by using resins and gel coats that meet the organic HAP content requirements in Table 2 to this subpart. Compliance with this option is bas ed on a 12-month rolling average.

(c) Add-on control option. Use an enclosure and add-on control device, and

demonstrate that the result ing emissions meet the emission limit in §63.5698. Compliance with this option is based on control device performance testing and control device monitoring.

This Subpart’s limitations for open molding oper ations are listed in the table below.

Organic HAP Content Requirements

Operation Type Application Method Organic HAP content (weight percent) requirement
Production Resin Operations Atomized 28 Production Resin Operations Nonatomized 25 Pigmented Gel Coat Operations Any method 33

Clear Gel Coat Any method 48 Tooling Resin Operations Atomized 30 Tooling Resin Operations Nonatomized 39 Tooling Gel Coat Operations Any Method 40

District Rule 4684 contains requirements that would require a polyester resin operation to either use resins and gel coats that m eet monomer content lim its or install an add on

emission control device. As shown in the table above, the monomer content limits of Subpart VVVV are more stri ngent than those of Distric t Rule 4684. The add on emission control device requirements ar e equivalent for both regulations.

Subpart VVVV requires that m onthly records of the resin and gel coats used be maintained. District Rule 4684 requires t hat these records be maintained on a daily basis. District Rule 4684 has more stringent recordkeeping requirements than Subpart

VVVV.

How does District Rule 4684 compare to rules in other air districts?

District staff compared VOC lim its, optional control require ments, and work practice standards in District Rule 4684 to comparable requirements in rule s from the following

California nonattainment areas:

• South Coast AQMD Rule 1162, as amended July 2005

• Bay Area AQMD Regulation 8 Ru le 50, as adopted November 1996San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-349 • Sacramento Metro AQMD Rule 465, as amended September 2008

• Ventura County APCD Rule 74. 14, as amended April 2005.

1. South Coast AQMD Rule 1162

South Coast AQMD Rule 1162 (Polyester Re sin Operations) applies to all polyester resin operations that fabricate, rework, r epair, or touch-up produc ts for commercial, military, or industrial use including, but not limited to, boats, tubs, pools, shower enclosures, spas, bathroom fixtures, jigs, t ools, molds, building panels, air pollution control equipment, sewage treatment equipmen t, storage tanks, transportation parts, automotive, aircraft, and aerospace com ponents, and other industrial and consumer products. District Rule 4684 is applicable to the same types of operations, however District Rule 4684 also contains an exempt ion for facilities which use less than 20 gallons of polyester resin per month. The a pplicability of these two rules are equivalent.

South Coast AQMD Rule 1162 and District Rule 4684 have the same application method requirements: airless, air assisted airless, high-volume, low-pressure (HVLP) spray equipment, or electrostatic spray equi pment. The application methods for these two rules are equivalent.

South Coast AQMD Rule 1162 requires that the polyester resin material in an open molding system shall not exceed the fo llowing monomer percent age by weight as applied: clear gel coat for marb le resins (40%), clear gel c oat for other resins (44%), pigmented gel coat white and o ff white (30%), pigmented gel coat non-white (37%), pigmented gel coat primer ( 28%), specialty gel coat (48%), general purpose marble resin (10%), general purpose solid surface resin (17%), general purpose tub/shower resin (24%), lamination resin (32%), other general purpose resin (35% ). District Rule 4684 requires that clear gel coats contai n no more than 50% monomer by weight, pigmented gel coats contain no more than 45% monomer by weight, and general purpose resins contain no more than 35% m onomer by weight. Since District Rule 4684 has a higher monomer percentage by weig ht limit than SCAQMD Rule 1162, the resin monomer percentage by wei ght limits of District Rule 4684 are not as stringent as
SCAQMD Rule 1162.

SCAQMD Rule 1162 has a more stringent vapor suppressed resin requirement when compared to District Rule 4684. SCAQMD Ru le 1162 requires additives to reduce VOC evaporation loss to less than 50 g/m 2 of surface area, while District Rule 4684 requires additives to reduce VOC evaporat ion loss to less than 60 g/m 2 of surface area

SCAQMD Rule 1162 has a more stringent control equipment requirement when compared to District Rule 4684. SCAQMD Rule 1162 requires an emission control system to have an overall capture and contro l efficiency of 90 percent or more on a mass basis, while District Rule 4684 requires an emission control system to have an overall capture and control efficiency of 85 percent or more on a mass basis.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-350 SCAQMD Rule 1162 and District Rule 4684 have equivalent recordkeeping, monitoring, and testing requirements.

2. Bay Area AQMD Re gulation 8 Rule 50

BAAQMD Regulation 8 Rule 50 (Polyester Resin Operations) applies to all facilities that manufacture products using polyester resins . District Rule 4684 is applicable to the same types of operations, however District Rule 4684 also contains an exemption for facilities which use less than 20 gallons of pol yester resin per month. The applicability of these two rules are equivalent.

BAAQMD Regulation 8 Rule 50 requires an operation to use one or more of the following emission reducing methods: 1) Use polyester resin material with a monomer content of no greater than 35 percent by weight. 2) Use a resin containing vapor suppressant, such that wei ght loss from VOC emission s do not exceed 60 grams per square meter of exposed surface area during resin polymerization. 3) Use a closedmold system. District Rule 4684 has equiva lent requirements for options 2 and 3, however it has a higher limit for the monomer content of pol yester resin used. District Rule 4684 it is not as stringent as BAAQMD Regulation 8 Rule 50.

BAAQMD Regulation 8 Rule 50 and District Ru le 4684 have the same spray application method requirements: airless, air assisted airless, high-volume, low-pressure (HVLP) spray equipment, or electrostatic spray equi pment. The application methods for these two rules are equivalent.

BAAQMD Regulation 8 Rule 50 and District Ru le 4684 both require an emission control system to have an overall capture and contro l efficiency of 85 percent or more on a

mass basis.

BAAQMD Regulation 8 Rule 50 limits the cleani ng materials used by the polyester resin operation to less than 200 g-VOC/ L. District Rule 4684 limit s the VOC content of clean up solvents to 25 g-VOC/L. District Rule 4684 has more stringent surface preparation and clean-up solvent requirements than BAAQMD Regulation 8 Rule 50.

BAAQMD Regulation 8 Rule 50 and District Rule 4684 have equivalent recordkeeping, monitoring, and testing requirements.

3. Sacramento Metro AQMD Rule 465

Sacramento Metro AQMD Rule 465 (Polyester Resin Operations) applies to all facilities that operate polyester resins operations exc ept for facilities that use less than 20 gallons of resin per month. District Rule 4684 is applicable to the same types of operations and has the same exemption. The applicability of these two rules are equivalent.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-351 The process and control requirements of Sacr amento Metro AQMD Rule 465 are almost equivalent to the requirement s of District Rule 4684. The one difference is that Sacramento Metro AQMD Rule 465 requires that the VOC contro l system provide an overall system efficiency of 90% compared to 85% which is required by District Rule 4684. The control efficiency of District Ru le 4684 it is not as stringent as that of
Sacramento Metro AQMD Rule 465.

Sacramento Metro AQMD Rule 465 and District Rule 4684 have the same spray application method requirement s: airless, air assisted airless, high-volume, lowpressure (HVLP) spray equipment, or electr ostatic spray equipment. The application methods for these two rules are equivalent.

The cleaning material requirements of Sacr amento Metro AQMD Rule 465 states that on September 25, 2009, all cleaning materi als shall have VOC contents of 0.21 pounds of VOC per gallon (25 g/l) as applied, or less. District Rule 4684 currently requires cleaning materials to have VOC contents of 0.21 pounds of VOC per gallon (25 g/l) as applied, or less. District Rule 4684 has mo re stringent cleaning ma terial requirements
than Sacramento Metro AQMD Rule 465.

Sacramento Metro AQMD Rule 465 requires that monthly record s of the resin and cleaning materials be maintained for operat ions with VOC emissions greater than 5 tons-VOC/year and annual records be maintai ned for operations with VOC emissions with less than 5 ton-VOC/year . District Rule 4684 requires that these records be maintained on a daily basis. District Ru le 4684 has more stringent recordkeeping requirements than Sacramento Metro AQMD Rule 465.

4. Ventura County APCD Rule 74.14

Ventura County APCD Rule 74.14 (Polyester Resin Material Operations) applies to all facilities that operate polyester resins operations except for facilities that use less than 20 gallons of resin per month. District Rule 4684 is applicable to the same types of operations and has the same exemption. The applicability of these two rules are equivalent.

Ventura County APCD Rule 74.14 requires that the polyester resin material in an open molding system shall not exceed the fo llowing monomer percent age by weight as applied: clear gel coat for marb le resins (40%), clear gel c oat for other resins (44%), pigmented gel coat white and o ff white (30%), pigmented gel coat non-white (37%), pigmented gel coat primer ( 28%), specialty gel coat (48%), general purpose marble resin (10%), general purpose solid surface resin (17%), general purpose tub/shower resin (24%), lamination resin (32%), other general purpose resin (35% ). District Rule 4684 requires that clear gel coats contain no more than 50% monomer by weight, pigmented gel coats contain no more than 45% monomer by weight, and general purpose resins contain no more than 35% m onomer by weight. Since District Rule 4684 has a higher monomer percentage by we ight limit than Ventura County APCDSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-352 Rule 74.14, the resin monomer percentage by weight limits of District Rule 4684 are not as stringent as Ventura County APCD Rule 74.14.

Ventura County APCD Rule 74.14 and Distr ict Rule 4684 have the same spray application method requirement s: airless, air assisted airless, high-volume, lowpressure (HVLP) spray equipment, or electr ostatic spray equipment. The application methods for these two rules are equivalent.

The cleaning material requirements of Vent ura County APCD Rule 74.14 states that all cleaning materials shall be either a Clean Air Solvent or shall not exceed 25 grams ROC per liter of material as applied. District Rule 46 84 currently requires cleaning materials to have VOC contents of 0.21 pounds of VOC per gallon (25 g/ l) as applied, or less. The cleaning material requirement s for these two rules are equivalent.

Ventura County APCD Rule 74.14 requires that the VOC control system provide an overall system efficiency of 90% compared to 85% which is required by District Rule 4684. The control efficiency of District Rule 4684 it is not as stringent as that of Ventura County APCD Rule 74.14.

Ventura County APCD Rule 74.14 requires th at monthly records of the resin and cleaning materials be maintained. Distric t Rule 4684 requires that these records be maintained on a daily basis. District Ru le 4684 has more stringent recordkeeping requirements than Ventura County APCD Rule 74.14.

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, District staff concludes that the recently adopted CTG has several requirements that are mo re stringent than those in Rule 4684 for polyester resin operations. Although Rule 4684 limits are not as stringent as some of

those contained within other district’s ru les, those rules hav e been recently amended and some of their limits are considered bey ond RACT, since those requirements are more stringent than the CTG requirements. Since the CTG was recently adopted (2008), EPA would have conducted a thorough analys is for determining the reasonably available control to apply to the source category. Therefore, although RACT is inherently a “moving target”, a recently adopted CTG can be assumed as defining RACT. As discussed in Section 4.2 and Table 4-3 below, the rule is on a schedule for addressing the differences between its curre nt requirements versus the CTG and the other rule requirements.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-353 

### Rule 4691 – Vegetable Oil Processing Operations

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

VOC 0.36 0.37 0.40 0. 40 0.44 0.46 0.48 0.48
(Source: District 2007 Ozone Plan)

District Rule 4691 Description

This rule controls VOC emissions from facilit ies that extract oil from vegetable sources

like cottonseeds and corn.

How does District Rule 4691 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

There is no CTG for this source category.

B. EPA – Alternative Control Technology (ACT)

There is no ACT for this source category.

C. Standards of Performance fo r New Stationary Sources (NSPS)

There is no NSPS for this source category.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

There are no NESHAPs for this source category.

How does District Rule 4691 compare to rules in other air districts?

District staff compared VOC lim its, optional control require ments, and work practice standards in District Rule 4691 to comparable requirements in rule s from the following

California nonattainment areas:

• South Coast AQMD does not have a specif ic prohibitory rule for this source category.

• Bay Area AQMD Regulation 8 Ru le 41, as adopted December 1986.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-354 • Sacramento Metro AQMD does not have a spec ific prohibitory rule for this source category.

• Ventura County APCD does not have a specif ic prohibitory rule for this source category.

Bay Area AQMD Regul ation 8 Rule 41

Bay Area AQMD Regulation 8 Rule 41 (V egetable Oil Manufacturing Operations) applies to vegetable oil solvent extraction operations. Equipment that is used exclusively for research, laboratory analysis or determination of production is exempt

from the emission co ntrol requirements of this rule.

District Rule 4691 is applicable to all vegetable oil plants.

Both BAAQMD Regulation 8 Rule 41 and District Rule 4691 have identical requirements

for the control of emissions from both an extractor, desolventizer-toaster, and a desolventizer-toaster conveyor, cooler or tumb ler. In addition, bot h rules have identical monitoring and recordkeeping requirements.

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, Distric t staff concludes that District Rule 4691 satisfies RACT for vegetable oil plants.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-355 

### Rule 4692 – Commercial Charbroiling

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 0 0 0 0 0 0 0 0

VOC 0.442 0.461 0.484 0.491 0.526 0.547 0.569 0.613
(Source: District 2007 Ozone Plan)

District Rule 4692 Description

This source category includes charbroiling equipment located in restaurants, including hospitals, educational institutions, military, and government facilities. The rule applies to commercial cooking operations utilizing chai n-driven (conveyorized) charbroilers that grill at least 875 pounds of meat per week. O perators with units that emit less than one pound of pollutant per day of cr iteria pollutant are exempt.

How does District Rule 4692 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

There is no CTG for this source category.

B. EPA – Alternative Control Technology (ACT)

There is no ACT for this source category.

C. Standards of Performance fo r New Stationary Sources (NSPS)

There is no NSPS for this source category.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

There is no NESHAP or MACT for this source category.

How does District Rule 4692 compare to rules in other air districts?

District staff compared VOC lim its, optional control require ments, and work practice standards in District Rule 4692 to comparable requirements in rule s from the following

California nonattainment areas:San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-356 • South Coast AQMD Rule 1138, as adopted November 1997

• Bay Area AQMD Regulation 6 Ru le 2, as adopted December 2007

• Ventura County APCD Rule 74.25, as adopted October 2004

• Sacramento Metro AQMD has no prohibito ry rule for this source category.

A. South Coast AQMD Rule 1138

South Coast AQMD Rule 1138 (Commercial Char broiling) requires that a chain-driven charbroiler be operated with either a certified catalytic oxidizer or other control device.

The alternative control device must be as or mo re effective than the catalytic oxidizer in reducing particulate matter (PM) and VOC em issions. The rule does not specify a particular PM or VOC emission rate or a c ontrol efficiency for t he charbroiler/control device combination. The minimum requirement for certification is contained in the test protocol. The catalytic oxidizer must reduc e emissions of VOC an PM by at least 83%. District Rule 4692 essentially mirrors the S outh Coast AQMD rule by requiring a South Coast AQMD certified catalytic oxidizer.

B. Bay Area AQMD Re gulation 6 Rule 2

Bay Area AQMD Regulation 6 Rule 2 (Comme rcial Cooking Equipment) was adopted in December 2007. The rule applies to both ch ain-driven charbroilers and to under-fired charbroilers. There are exemptions for fac ilities that buy less than a certain amount of meat per week and for facilities that grill less than a certain amount per week.

For chain-driven charbroilers, there are both PM and VOC emission ra te limits. Since PM is not an ozone precursor, the allowable PM emission rate is not part of this RACT analysis. The VOC emission rate for chai n-driven charbroilers represents an 83% reduction over Bay Area AQMD’s uncontrolled em ission factor for the grilling of beef.

This mirrors the criteria for South Coas t AQMD certification. For under-fired charbroilers, there are PM emission rate limit s, but no VOC emission rate limits, so the rule does not define applicable RACT for under-f ired charbroilers. The Bay Area AQMD rule is equivalent to District Rule 4692 for chain-driven charbroilers.

C. Ventura County APCD Rule 74.25

Ventura County APCD Rule 74.25 applies to c onveyorized (chain-driven) charbroilers. There is one exemption that applies only to chai n-driven charbroilers placed in service before October 12, 2005. If these units grill less than 875 pound of meat or less per week, they are exempt from the control r equirements. Catalyti c oxidizers or other control device is required for these units. The control device must be certified as reducing PM and reactive organic compound em issions by at least 83% when tested according to South Coast AQMD’s test protocol. The VOC emission reduction requirement represents the minimum emission reduction required for certification under the South Coast AQMD test protocol for cata lytic oxidizers. District Rule 4692 requires South Coast AQMD-certified catalytic oxidizer for chain-driven charbroilers. Since theSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-357 83% reduction is the minimum reduction for cert ification, the contro l requirements in

District Rule 4692 and Ventura Count y APCD Rule 74.25 are equivalent.

Conclusion

There are no federal rules or regulations cove ring emissions from this source category. After careful evaluation of prohibitory ru les in other California nonattainment areas,

District staff concludes that District Ru le 4692 satisfies RACT for commercial

charbroilers.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-358 

### Rule 4693 – Bakery Ovens

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

VOC 0.52 0.54 0.56 0. 57 0.61 0.63 0.66 0.66
(Source: District 2007 Ozone Plan)

District Rule 4693 Description

This rule includes all bakery ovens at Ma jor Sources that are used for the baking of yeast leavened products.

How does District Rule 4693 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

There is no CTG for this source category.

B. EPA – Alternative Control Technology (ACT)

EPA-453/R-92-017 Alternative Control Tec hnology Document for Bakery Oven

Emissions

This document outlines the available c ontrol techniques for bakery ovens. The document lists no specific VOC emission limit, although it does suggest estimated percent VOC reduction from uncontrolled levels . In not having a specific VOC limit for any of the bakery ovens, the document does not define RACT for bakery ovens.

C. Standards of Performance fo r New Stationary Sources (NSPS)

There is no NSPS for this source category.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

There is no NESHAP for this source category.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-359 How does District Rule 4693 compare to rules in other air districts?

District staff compared VOC lim its, optional control require ments, and work practice standards in District Rule 4693 to comparable requirements in rule s from the following

California nonattainment areas:

• South Coast AQMD Rule 1153, as amended January 1995

• Bay Area AQMD Regulation 8 Rule 42, as adopted June 1994

• Sacramento Metro AQMD Rule 458, as amended September 1996

• Ventura County APCD does not have a specif ic prohibitory rule for this source category.

A. South Coast AQMD Rule 1153

South Coast AQMD Rule 1153 (Commercial Bakery Ovens) only applies to units with a burner rating greater than 2.0 MMBtu/hrand VOC emissions greater than 50 lbVOC/day. This rule also requires the fac ility to reduce the amount of VOC emission emitted by: 70% by weight if the oven has a daily average of 50 lbs -100 lbs of VOC emitted, 95% by weight if the oven has a daily average greater than 100 lbs of VOC emitted, and 95% by weight for new ovens that have a daily average greater than 50 lbs

of VOC emitted.

District Rule 4693 is applicable to all bakery ov ens at major sources. Based on South Coast AQMD Rule 1153, bakeries with VO C emissions less than 50 lb/day (18,250 lb/year) are exempt from the requirements of the rule. Si nce facilities in the SJVAPCD with emissions of 18,250 lb-VOC/year ar e not considered major sources; the applicability of District Rule 4693 is not as stringent as South Coast AQMD Rule 1153.
South Coast AQMD Rule 1153 also states that bakeries with VO C emissions between 50 lb/day (18,250 lb/year) and 100 lb/day (36, 500 lb/year) must reduce their emissions by 70% by weight.

However, upon EPA approval of the Districts re vised NSR rule (which is expected to be adopted by the District’s Board in December 2008), the Major Source threshold for VOC emissions will be lowered to 20,000 lb-VOC/y ear. The lowering of the Major Source threshold will make the requirements of Dis trict Rule 4693 applicable to previously exempt bakeries. The applicable bakeries will be required to collect emissions from the bakery ovens vent them to a control device wit h at least a 95% control efficiency. In comparison, South Coast AQMD Rule 1153, states that bakeries with VOC emissions between 50 lb/day (18,250 lb/year) and 100 lb/ day (36,500 lb/year) must reduce their emissions by 70% by weight. Therefore, District Rule 4693 will have more stringent VOC emission control requirements t hat are than South Coast Rule 1153.

B. Bay Area AQMD Re gulation 8 Rule 42

Bay Area AQMD Regulation 8 Rule 42 (Large Commercial Bread Bakeries) applies to bread bakeries with an average daily producti on of greater than 100,000 lb/bread.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-360 Bakeries with daily VOC emissions less t han 150 lb/day (54,750 lb/year) are considered low emitting ovens and are exem pt from the emission control requirements of this rule. New and modified bakery ovens that meet the applicability of this rule are required to vent all emissions to a control system capable of reducing emissions by 90%.

District Rule 4693 is applicable to all bakery ovens at major sources. Based on BAAQMD Regulation 8 Rule 42, bakeries wi th VOC emissions less than 150 lb/day (54,750 lb/year) are exempt from the requirem ents of the rule. Since facilities in the

SJVAPCD with emissions of 54,750 lb-VOC/year are considered major sources, the applicability requirements of District Rule 4693 are more stri ngent than those of BAAQMD Regulation 8 Rule 42. District Rule 4693 also states that collected emissions from all bakery ovens are required to be vent ed to a control device with at least a 95% control efficiency. District Rule 4354 has VO C emission control re quirements that are more stringent than BAAQMD Regulation 8 Rule 42.

C. Sacramento Metro AQMD Rule 458

Sacramento Metro AQMD Rule 458 (Lar ge Commercial Bread Bakeries) applies to bread bakeries which produce equal to or mo re than 100 lb-VOC/day. All bakery ovens that meet the applicability of this rule are required to vent all emissions to a control device with a control efficiency of 95% on a mass basis.

District Rule 4693 is applicable to all bakery ovens at major sources. Based on Sacramento Metro AQMD Rule 458, bakerie s with VOC emissions less than 36,500 lb/year are exempt from the requirements of the rule. Si nce facilities in the SJVAPCD with emissions of 36,500 lb-VOC/year ar e not considered major sources; the applicability of District Rule 4693 is not as stringent as Sa cramento Metro AQMD Rule 458. However, upon EPA approval of the Distric ts revised NSR rule (which is expected to be adopted by the District’s Board in Dece mber 2008), the Major Source threshold for VOC emissions will be lowered to 20,000 lb -VOC/year. This lowering of the Major Source threshold will result in the applicab ility of the District Rule 4693 more stringent
than Sacramento Metro AQMD Rule 458. Dist rict Rule 4693 also states that collected emissions from all bakery ovens are requir ed to be vented to a control device with at least a 95% control efficiency. Therefor e, District Rule 4354 and Sacramento Metro AQMD Rule 458 have at least equivalent if not more stringent (when the District’s major source threshold is lowered) VOC emission control requirements.

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in other California nonattainment areas, Distric t staff concludes that District Rule 4693 satisfies RACT for bakery ovens.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-361 

### Rule 4694 – Wine Fermentation and Storage Tanks

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

VOC 3.6 3.7 3.8 3. 8 3.9 4.0 4.1 4.1
(Source: District 2007 Ozone Plan)

District Rule 4694 Description

The purpose of this rule is to reduce em issions of volatile organic compounds (VOC)

from the fermentation and bulk storage of wine, or achieve equivalent reductions from

alternative emission sources.

The rule requires facilities to reduce the VOC emissions from fermentation by 35% of their baseline emissions annually. Tanks ov er 5,000 gallons in volume must be equipped with pressure/vacuum relief valv es operating within 10% of the maximum allowable working pressure of the tank, and the temperature of stored wine must be maintained at or below 75 degrees Fahrenheit.

The rule exempts storage tanks constructed primarily of c oncrete or wood and wineries

that emit less than 10 t ons of VOC per year.

How does District Rule 4694 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

There is no CTG for this source category.

B. EPA – Alternative Control Technology (ACT)

There is no ACT for this source category.

C. Standards of Performance fo r New Stationary Sources (NSPS)

There is no NSPS for this source category.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

There is no NESHAP or MACT for this source category.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-363 

### Rule 4702 – Internal Combustion Engines – Phase 2

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 31.80 31.58 29.77 29.12 27.72 25.52 23.18 20.69

VOC 5.29 5.25 5.19 5. 17 5.15 5.15 5.17 5.21
(Source: District 2007 Ozone Plan)

District Rule 4702 Description

Rule 4702, recently amended on January 18, 2007, limits NO X , CO, and VOC emissions from internal combustion engine s. The main rule requirem ent is the limitation of NO X , CO, and VOC emissions. These limitations are shown in the tables below.

Rule 4702 Emission Limits – Spark Ignited Engines

Engine Type NO
x Emission Limit (ppmv @

15% O 2 , dry) CO Emission Limit (ppmv @

15% O 2 , dry) VOC Emission Limit (ppmv @

15% O 2 , dry)

1. a. Rich Burn, Waste Gas Fueled 50 or 90%

reduction 2,000 250

1. b. Rich Burn, Cyclic Loaded,

Field Gas Fueled 50 2,000 250

1. c. Rich Burn, All Other Engine 25 or 96%

reduction 2,000 250

2. a. Lean Burn 2-Stroke, Gaseous Fueled, < 100 hp 75 or 85%

reduction 2,000 750

2. b. Lean Burn, All Other Engines 65 or 90%

reduction 2,000 750

3. a. Rich-Burn Engines Used Exclusively in Ag Operations, Comply by 1/1/2009 of if the owner has an agreement to electrify comply by 1/1/2010 90 ppmv or 80%

reduction 2000 ppmv 250 ppmv

4. a. Lean-Burn Engines Used Exclusively in Ag Operations, Comply by 1/1/2009 of if the owner has an agreement to electrify comply by 1/1/2010 150 ppmv or 70%

reduction 2000 ppmv 750 ppmv

5. a. Certified Spark-Ignited Engine Used Exclusively in AO and installed on or before June 16, 2005, Comply by 6/1/2006 Meet Certified Spark-Ignit ed Engine Standard of HC + NO X < 0.6 g/bhp-hrSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-364 Rule 4702 Emission Limits – Compression Ignited Engines

Engine Type Emission Limit / Standard Compliance Date

1. a. Non-Certified CompressionIgnited Engine, Greater than 50 bhp but not more that 500 EPA Tier 3 or Tier 4 1/1/2010

1. b. Non-Certified CompressionIgnited Engine, Greater than 500 bhp but not more than 750 bhp and less than 1000 annual operating hours EPA Tier 3 1/1/2010

1. c. Non-Certified CompressionIgnited Engine, Greater than 750 bhp and less than 1000 annual operating hours EPA Tier 4 7/1/2011

1. d. Non-Certified CompressionIgnited Engine, Greater than 500 bhp and greater than or equal to 1000 annual operating hours 80 ppm NO X , 2,000 ppm CO,
750 ppm VOC 1/1/2008 or, if owner has an agreement to electrify, comply by 1/1/2010

2. a. Certified Compression-Ignited Engine, EPA Certified Tier 1 or Tier 2 Engine EPA Tier 4 1/1/2015 or 12 years after installation date,

whichever is later

2. b. Certified Compression-Ignited Engine, EPA Certified Tier 3 or Tier 4 Engine Meet Certified Compression-Ignited Engine Standard in effect at time of

installation At time of

installation

On January 10, 2008 EPA took direct final action to approve revisions to the San Joaquin Valley Unified Air Pollution Control District portion of the California State Implementation Plan. These revisions included approval of District Rule 4702. EPA, in evaluating and approving Rule 47 02 included the following:

“We believe these rules are consistent with the relevant policy and guidance regarding enforceability, RACT, BACM, and SIP relaxations.” ( CFR Volume 72,

Number 103 )

Since Rule 4702 was recently approved by EPA as meeting RACT requirements, the District did not pursue a det ailed RACT analysis.

How does District Rule 4702 compare wi th federal rules and regulations?

The District did not conduct a detailed analysis of federal rules and regulations for Rule

4702.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-365 How does District Rule 4702 compare to rules in other air districts?

The District did not conduct a detailed comparison to rules in other air districts for Rule

4702.

Conclusion

District staff concludes that District Rule 4702 satisfies RACT for internal combustion engines.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-366 

### Rule 4703 – Stationary Gas Turbines

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 8.4 4.8 5.0 5.1 5.2 5.3 5.6 5.7

VOC 0.64 0.67 0.68 0. 68 0.68 0.71 0.74 0.76

I. District Rule Description:

Rule 4703, recently amended on September 20, 2007, limits NO X and VOC emissions from stationary gas turbines with a ratings equal to or greater t han of 0.3 MW or a maximum heat input of more than 3.0 MMBtu/h r. The main rule requirement is the

limitation of NO X emissions. Laboratory units used in research and testing for the advancement of gas turbine technology, units limited by permit condition to be operated exclusively for firefighting and/or flood control, and emergen cy standby units limited by permit condition to operate less than 100 hours per calendar year for maintenance and testing purposes are not subject to the em ission requirements of this rule. These

limitations are shown in the tables below.

Rule 4703 Emission Limits – Tier 2

NO X Compliance Limit (ppmv @ 15% O 2 ) Turbine Classification Rating Compliance Option Gas Fuel Liquid Fuel

a) Less than 2.0 MW Solar Saturn, driving a centrifugal compressor Standard 50 50

b) No greater than 10 MW, if a DLN System is commercially available for the specific unit, as of April 30,

2003. Standard 25 65

c) No greater than 10 MW, if a DLN System is not commercially available for the specific unit, as of April 30, 2003. Standard 35 65

Standard 5 25 d) Greater than 10 MW, Combined cycle. Enhanced 3 25

Standard 5 25 e) Greater than 10 MW, Simple cycle, and permit condition for greater than 877 hrs/yr operation. Enhanced 3 25

Standard 25 42 f) Greater than 10 MW, Simple cycle, and permit condition for no greater than 877 hrs/yr operation. Enhanced 5 25San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-367 Rule 4703 Emission Limits – Tier 3

NO X Compliance Limit (ppmv @ 15% O 2 ) Turbine Classification Rating

Gas Fuel Liquid Fuel

a) Less than 3 MW. 9 25

b) 3 MW to 10 MW pipeline gas

turbine. 8 during steady

state and 12 during non-steady

state 25

c) 3 MW to 10 MW and permit condition for less than 877 hrs/yr operation and not listed above. 9 25

d) 3 MW to 10 MW and permit condition for 877 hrs/yr operation or greater and not listed above. 5 25

e) Greater than 10 MW, Simple cycle, and permit condition for greater than 200 hrs/yr operation, except as provided in Section

5.1.3.3. 25 42

f) Greater than 10 MW, Simple cycle, and permit condition for greater than 200 hrs/yr operation but no greater than 877 hrs/yr operation. 5 25

II. How does District Rule 4703 compar e to rules in other air districts?

District staff compared VOC lim its, optional control require ments, and work practice standards in District Rule 4703 to comparable requirements in rule s from the following

California nonattainment areas:

• South Coast AQMD Rule 1134, as amended August 1997

• Bay Area AQMD Regulation 9 Rule 9, as amended December 2006

• Sacramento Metro AQMD Rule 413, as amended March 2005

• Ventura County APCD Rule 74.23, as amended January 2002

1. South Coast AQMD Rule 1134

South Coast AQMD Rule 1134 (Emission of Oxides of Nitrogen From Stationary Gas Turbines) applies to all existi ng stationary gas turbine, 0. 3 megawatt MW and larger.

The NO X emissions limits for different rated turb ines are shown in the table below.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-368 SCAQMD Rule 1134 Emission Limits

Type of Unit NO X Limit ppmv @ 15% O 2 District Rule 4703 NO X Limit ppmv @ 15% O 2 0.3 to Less Than 2.9 MW 25 9

2.9 to Less Than 10.0 MW 9 8 during steady state 12 during non-steady state

2.9 to Less Than 10.0 MW No SCR 15 9

10.0 MW and Over 9 25

10.0 MW and Over No SCR 12 25 60 MW and Over Combined Cycle No

SCR 9 5

60 MW and Over Combined Cycle 9 5
2.9 to Less Than 10.0 MW Utilizing Fuel Containing a Minimum of 60% Sewage Digester Gas by Volume on a Daily Average 25 5

As shown in the table above, the NO X emission limits for District Rule 4703 are equivalent the NO X emission requirements for SCAQMD Rule 1134 for most types of units. There are more stringent NO X emission limits in District Rule 4703 for the types of units that are not as stringent as SCAQMD Rule 1134, however the units they apply to have a more descriptive description than the SCAQMD Rule. Therefore, if there were

two NO X emission limits in District Rule 4703 t hat could apply to the type of units described in SCAQMD Rule 1134, the higher of the two limits was c hosen. District Rule 4703 has comparable NO X emission limits when compared to SCAQMD Rule 1134.

Therefore the emission limitations of Dis trict Rule 4703 are comparable to those of
SCAQMD Rule 1134.

Since the emission limits of District Rule 4703 are comparable to SCAQMD Rule 1134, District Rule 4703 meets RACT for stationary gas turbines.

2. Bay Area AQMD Regulation 9 Rule 9

Bay Area AQMD Regulation 9 Rule 9 (Nitr ogen Oxides from Stationary Gas Turbines) applies to stationary gas turbines with a heat input greater than 5 MMBtu/hr. Turbines used solely for the testing of aircraft engines for flight certification and turbines used solely for the firefighting and/or flood control are not subject to the requirements of this

rule.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-369 BAAQMD Reg 9 Rule 9 Emission Limits (Effective January 1, 2010)

NO X Limit ppmv @ 15% O 2 Type of Unit Natural

Gas Refinery Fuel Gas,

Waste Gas or LPG District Rule 4703

NO X Limit 5 to 50 MMBtu/hr (< 3 MW) 42 50 9

>50 to 150 MMBtu/hr (No retrofit available) (3 to 10 MW) 42 50 8 during steady state 12 during non-steady

state

>50 to 150 MMBtu/hr (WI/SI enhancement available) (3 to 10 MW) 35 50 8 during steady state 12 during non-steady

state >50 to 150 MMBtu/hr (DLN technology available) (10 to 19 MW) 25 50 5

>150 to 250 MMBtu/hr (10 to 19 MW) 15 15 5 >250 to 500 MMBtu/hr (19 to 40 MW) 9 9 5 >500 MMBtu/hr (40+ MW) 5 9 5

Until January 1, 2010, a per son may operate a stationary gas turbine for up to 877

hours in any 12-month period ( not counting hours of emergen cy use) without complying

with the emission limits Section 9-9-301 as long as nitrogen oxides (NOx) emission concentrations, do not exceed 42 ppmv @ 15% O 2 when firing with natural gas.

After January 1, 2010, a person may operate a stationary gas turbine rated at 50 MMBtu/hr or greater for up to 877 hours in any 12-month period (not counting hours of emergency use) without complyi ng with the emission limits set forth in Section 9-9-301 as long as nitrogen oxides (NOx ) emissions are less than either of the of the alternative

limits listed below for the turbine’s heat input rating and the type of fuel burned.

BAAQMD Reg 9 Rule 9 Emission Limits

NO X Limit ppmv @ 15% O 2 Type of Unit Natural

Gas Refinery Fuel Gas,

Waste Gas or LPG District Rule

4703 NO X Limit >50 to 150 MMBtu/hr (3 to 10 MW) 42 N/A 9 >150 to 250 MMBtu/hr (10 to 19 MW) 42 N/A 5 >250 to 500 MMBtu/hr (19 to 40 MW) 25 N/A 5 >500 MMBtu/hr (40+ MW) 25 N/A 5

As shown in the tables above, District Rule 4703 has lower emission limits for NO X than BAAQMD Reg 9 Rule 9 for all types of units . Therefore the emission limitations of District Rule 4703 are as stringent as BAAQMD Reg 9 Rule 9.

Since the emission limits of District Rule 470 3 are as stringent as BAAQMD Reg 9 Rule 9, District Rule 4703 meets RACT for stationary gas turbines.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-370 3. Sacramento Metro AQMD Rule 413

Sacramento Metro AQMD Rule 413 (Stationar y Gas Turbines) applies to all stationary gas turbines with ratings equal to or gr eater than 0.3 megawa tt (MW) output, or 3 MMBTU/hr input and operated on gaseous and/or liquid fuel. The emission requirements of this rule shall not apply to the operation of gas turbines used to provide emergency electrical power, emergency water pum ping for flood control or fire fighting, emergency potable water pumping, or emergency sewage pumpi ng. Only the gaseous

fuel fired limits from th is rule will be compared to District Rule 4703.

Sacramento Metro AQMD Rule 413 Emission Limits

Time of Operation Type of Unit NO X Limit ppmv @ 15% O 2 District Rule 4703 NO X Limit ppmv @ 15% O 2

Any (RACT) ≥ 0.3 MW 42.0 Exempt Any (BARCT) ≥ 0.3 to 2.9 MW 42.0 9 < 877 (BARCT) ≥ 2.9 MW 42.0 9

≥ 877 (BARCT) ≥ 2.9 to <10 MW 25.0 5

≥ 877 (BARCT) ≥ 10.0 (no SCR) 15.0 5

≥ 877 (BARCT) ≥ 10.0 (w/ SCR) 9.0 5

As shown in the tables above, District Rule 4703 has lower emission limits for NO X than Sacramento Metro Rule 413 for all types of uni ts. Therefore the emission limitations of District Rule 4703 are as stringent as Sacramento Metro Rule 413.

Since the emission limits of District Rule 4703 are as stringent as Sacramento Metro Rule 413, District Rule 4703 meets RACT for stationary gas turbines.

4. Ventura County APCD Rule 74.23

Ventura County APCD Rule 74.23 (Stationary Gas Turbines) applies to stationary gas turbines rated at 0.3 MW or greater operat ed on gaseous or liquid fuel. Turbines used for research and testing for the advancement of gas turbine technology , for fire fighting or floor control, less than 200 hour per y ear, and turbines used as emergency standby engines limited to maintenance operation le ss than 104 hours per year are not subject to the emission requirements of this rule. Only the gaseous fuel fired limits from this rule will be compared to District Rule 4703.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-371 VCAPCD Rule 74.23 Emission Limits

Type of Unit NO X Limit ppmv @ 15% O 2 District Rule 4703 NO X Limit ppmv @ 15% O 2 0.3 to < 2.9 MW 42 9

2.9 to < 10.0 MW 25 x E/25 8 during steady state 12 during non-steady state 10.0 MW and up, w/ SCR 9 x E/25 5
10.0 MW and up, w/o SCR 15 x E/25 5
4.0 MW and up, less than 877 hours per calendar year 42 9

E = (MRE [Continuous] at LHV) (LHV) ÷ (HHV)

Where LHV = the lower heat ing value of the fuel HHV = the higher hearing value of the fuel

MRE = manufacturer’s ra ted thermal efficiency

According to AP-42, 3.1-1 (4/ 00), the typical efficiency for a stationary gas turbine is 38% to 60%. Assuming the highest efficiency of 60%, the NO X emission limits from

District Rule 4703 are still lower than that of VCAPCD Rule 74.23 for all types of units.

Therefore the emission limitations of Dis trict Rule 4703 are as stringent as VCAPCD

Rule 74.23.

Since the emission limits of District Rule 4703 are as stringent as VCAPCD Rule 74.23, District Rule 4703 meets RACT for stationary gas turbines.

III. Conclusion

After careful evaluation of prohibitory ru les in other California nonattainment areas,

District staff concludes that District Rule 4703 satisfies RACT for stationary gas

turbines.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-372 

### Rule 4902 – Residential Water Heaters

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 1.37 1.27 1.30 1. 31 1.33 1.36 1.39 1.42

VOC 0.10 0.11 0.11 0. 11 0.111 0.11 0.12 0.12
(Source: District 2007 Ozone Plan)

District Rule 4902 Description:

Units in this source category are water heat ers located in privat e residences with heat input of 75,000 British thermal units per hour (Btu/hr) or le ss. The following units are exempt: water heaters using fuels other t han natural gas, natural gas-fired heaters used exclusively to heat swimming pools or hot tubs, and water heaters used exclusively in recreational vehicles.

How does District Rule 4902 compare wi th federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

There is no CTG for this source category.

B. EPA – Alternative Control Technology (ACT)

There is no ACT for this source category.

C. Standards of Performance fo r New Stationary Sources (NSPS)

There is no NSPS for this source category.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and

Maximum Achievable Contro l Technologies (MACTs)

There is no NESHAP or MACT for this source category.

How does District Rule 4902 compare to rules in other air districts?

District staff compared NOx limits and optiona l control requirements in District Rule 4902 to comparable requirements in rules from the following California nonattainment

areas:San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-373 • South Coast AQMD Rule 1121, as amended September 2004

• Bay Area AQMD Regulation 9 Rule 6, as amended November 2007

• Sacramento Metropolitan AQMD Ru le 414, as adopted August 1996

• Ventura County APCD Rule 74. 11. as amended December 1986

A. South Coast AQMD Rule 1121

South Coast AQMD Rule 1121 (Control of NOx from Residential Type Natural GasFired Water Heaters) applies to manufacturers , distributors, retailers, and installers of natural gas-fired water heaters, with heat input rates less than 75,000 Btu per hour.

Water heaters in recreational vehicles are exem pt from control requi rements. For water heaters not in mobile homes, has two NOx limits for resi dential water heaters that are considered equivalent – one based on heat i nput to the unit and the other based on heat output from the unit. The emission lim its are no more than 10 nanograms of NOx per joule of heat output (23 pounds per billion Btu (lb/billion Btu) of heat output) or 15 parts per million by volume at 3% oxygen, dry (17. 5 lb/billion Btu of heat input). Water

heaters in mobile homes have a different NOx limit - no more than 40 nanograms of NOx per joule of heat output ( 93 lb/billion Btu of heat output ) or 55 parts per million by volume (ppmv) at 3% oxygen, dry ( 71 lb/billion Btu of heat input).

These limits were phased in over three year s beginning in 2006; meaning that the limits have not been fully implemented until this year. From this perspective, the lower limits in South Coast AQMD Rule 1121 represent RA CT for future rule-making and not for current analysis of District Rule 4902. District Rule 4902 is undergoing rule development as part of the District’s 8-hour ozone attainment strategy. District staff anticipates incorporating t he South Coast AQMD limits fo r this source category. Adoption of the rule amendments is ex pected in the first quarter of 2009.

B. Bay Area AQMD Re gulation 9 Rule 6

Bay Area Regulation 9 Rule 6 (Nitrogen Ox ides Emissions from Boilers and Water Heaters) is an umbrella rule that covers boilers and wate r heaters up to two million Btu per hour. The rule applies to all units regar dless of whether the units are residential, commercial, industrial, or institutional us e. Units with heat i nput of not more than 75,000 Btu per hour are generally considered resi dential units, so the portion of the rule that applies to units of this size will be used for the analysis. This rule was amended recently. The current require ments for residential-type units is certified units with

emissions of not more than 40 nanograms NOx (calculated as NO2) per joule of heat input. Beginning in 2009 and phasing in over the next three years, the NOx limit will be 10 nanograms NOx per joule of h eat input. The new units would need to be certified to this lower limit. The 10 nanogram s per joule limit mirrors the South Coast rule for this source category, however to date, the rule has not been fully impl emented. From this perspective, the lower limits in the Bay Area AQMD rule repr esent RACT for future rulemaking and not for current analysis of Distric t Rule 4902. District Rule 4902 is undergoing rule development as part of the District’s 8-hour ozone attainment strategy.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-374 District staff anticipates incorporating the lowe r limits for this source category. Adoption of the rule amendments is expect ed in the first quarter of 2009.

C. Sacramento Metropolitan AQMD Rule 414

Sacramento Metropolitan AQMD Ru le 414 (Natural Gas-Fired Water Heaters) applies to any person who manufactures, distributes, offers for sale, sells, or installs any natural gas-fired water heater with a rated heat input capacit y less than 75,000 Btu/hr. Exempted units include water heaters in re creational vehicles, water heaters in swimming pools and hot tubs and water heaters t hat use fuel other than natural gas. The rule requires that certif ied units be used. For water heaters used in mobile homes, the rule limits NOx emissions to 50 nanogram s of NOx per joule of heat output (116

lb/billion Btu of heat ou tput). All other subject units are limited to NOx emission of no more than 40 nanograms NOx per j oule of heat output (93 lb/b illion Btu of heat output).

Both NOx limits are calculated as NO2. T he NOx limits in current District Rule 4902 are at least as stringent as the Sacr amento Metropolitan AQMD Rule 414.

D. Ventura County APCD Rule 74.11

Ventura County APCD Rule 74. 11 (Natural Gas-fired Re sidential Water Heaters – Control of NOx) applies to any person selling, offering for sale, or installing natural gasfired residential water heaters in Ventura Count y. The units subject to the rule have a rated heat input of less than 75,000 Btu/hour . Water heaters used in recreational

vehicles and water heaters installed in mobile homes are exempt. The rule requires a

certified unit that emits no more than 40 nanograms of NOx (calculated as NO2) per joule of heat output (93 pounds NO x per billion Btu of heat output). The NOx limits in current District Rule 4902 match the require ments of the Ventur a County APCD rule.

Conclusion

There are no federal rules for regulations covering air emissions for this source category. After careful evaluation of prohibi tory rules in other California nonattainment areas, District staff concludes that current District Rule 4902 satisfies RACT for

residential water heaters.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-375 

### Rule 4905 – Natural Gas-Fired, Fan- Type Residential Central Furnaces

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 4.21 4.12 4.03 4. 00 3.93 3.81 3.67 3.5

VOC 0.21 0.20 0.20 0. 20 0.19 0.19 0.18 0.17
(Source: District 2007 Ozone Plan)

District Rule 4905 Description

Rule 4905, recently adopted on October 20, 2005, limits NOx emissi ons from residential central furnaces. The main rule requirement is written, as follows: No person shall supply, sell, offer for sale, install, or solicitthe installation of any natural gas-fired fantype residential central furnace for use wit hin the District unle ss it has certified emissions of oxides of nitrogen less than or equal to 0.093 pounds of oxides of nitrogen per million BTU heat output or 55 ppm NOx at 3.00% O 2 stack gas by volume (dry).

Since Rule 4905 was recently approved by EPA, and the source category does not include any major sources, the District did not pursue a detailed RACT analysis.

How does District Rule 4905 compare wi th federal rules and regulations?

The District did not conduct a detailed analysis of federal rules and regulations for Rule

4905.

How does District Rule 4905 compare to rules in other air districts?

The District did not conduct a detailed comparison to rules in other air districts for Rule

4905.

Conclusion

District staff concludes that District Rule 4905 is exempt from RACT requirements because the Natural Gas-Fired, Fan-type, Residential Central Furnaces source category contains no major sources.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-376 4.2 RULES ON A SCHEDULE TO IM PLEMENT RACT/CTG REQUIREMENTS

After a careful and wide-ranging ex amination of individual rule s against multiple federal rules, regulations, and technology guidelines as well as evaluating District rules against comparable rules from Californi a’s most technologically progr essive air districts, staff has identified a few rules which will requir e amendments to fully implement RACT or CTG requirements.

4.2.1 Rules Implementing RACT Requirements

Out of the 55 rules evaluated in this report, only two rules (Rule 4311 - Flares and Rule 4684 - Polyester Resin Operations) have been i dentified as potentially needing revision to fully address RACT requirements. As outlined in Table 4-3 below, Rule 4311 is currently undergoing a rule amendment and will be heard for adoption by the Governing

Board in June 2009.

With respect to Rule 4684, as discussed in C hapter 1 of this report, RACT is inherently a “moving target” and technology/emission limits considered to meet RACT at the time of SIP-approval is generally rendered obsolete by more e ffective technology that is introduced at a later date. The last significa nt modification made to Rule 4684 was in

late 2001 15 , whereas the other district rules which were used for comparison were modified in 2005 (SCAQMD and VCAPCD) and as recently as September 2008 (SMAQMD). It should be noted that the BAAQMD Rule which has not been modified since 1996, is less stringent than Rule 4684; fu rther enforcing the concept of RACT as a moving target. Table 4-3 outlines the ru le schedule for addressing the discrepancies

between Rule 4684 and the other rules.

4.2.2 Rules Implemen ting CTG Requirements

In September 2008, EPA finalized and publis hed four CTGs for air districts to implement, since according to Section 182(b)(2 )(A), states must revise their SIPs to include RACT for each category of volat ile organic compounds (VOC) sources covered by Control Techniques Guidelines (C TG) documents between No vember 15, 1990 and

the date of attainment. EPA guidance requires that rules implement CTG requirements within one year of the date the CTGs are finalized. Tw o District rules (Rule 4603 and Rule 4653) need revisions to incorporate the new CTG requirements. Table 4-3 outlines the rule schedule for addressing t he discrepancies between the rules and the

CTGs.

15 Although Rule 4684 was modified in September 2007, the changes made only addressed the solvent cleaning portions of the rule and did not modify any other emission limits within the rule.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-377 

### Table 4-3 Schedule for Distri ct Rules Needing Amendment

Rule # Rule Title Last

Amended Scheduled Adoption

Date Reason

4311 Flares 6/15/2006 June 2009 RACT

4603 Surface Coating of Metal Parts

and Products 10/16/2008 September 2009 CTG

4653 Adhesives 9/20/2007 September 2009 CTG

4684 Polyester Resin Operations 9/20/2007 September 2009 CTGSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-378 This page intentionally blank.RACT Demonstration for Ozone SIP 

## Appendix A

COMMENTS AND RESPONSESRACT Demonstration for Ozone SIP This page intentionally blank.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Appendix A: Comments and Responses

RACT Demonstration for Ozone SIP A-1 

## Appendix A: Comments and Responses

A.1 EPA COMMENTS

1. COMMENT: SJ 4306 – Boilers, Steam Gener ators and Process Heaters, > 5
MMBtu/hr: The October 16, 2008 version of this rule, referred to in the RACT analysis, has not been submitted for SIP approval. The District should submit

the rule.

RESPONSE: As mentioned above the rule was approved by the District’s Governing Board on October 16, 2008 and wa s subsequently transmitted to ARB in December 2008. According to t he ARB website, the rule package was forwarded to the EPA on March 17, 2009.

2. COMMENT: SJ 4307 – Boilers, Steam Generat ors and Process Heaters, 2 – 5
MMBtu/hr: The October 16, 2008 version of this rule, referred to in the RACT analysis, has not been submitted for SIP approval. The District should submit

the rule.

RESPONSE: See response to Comment #1.

3. COMMENT: SJ 4311 – Flares: The conclusion on page 4-58 states that the District is amending the rule to incorpor ate flare minimizati on plans (FMPs) and expects to submit the amendm ents to its Board in the second quarter of 2009. Incorporation of an FMP requirement will help demonstrate implementation of
RACT.

RESPONSE: Based on EPA comments, Chapt er 4 of the report has been revised to include new Section 4.2 (R ules On A Schedule to Implement RACT/CTG Requirements) and Table 4- 3 to identify the rules which need
amendments to fulfill RACT or CT G requirements and their corresponding

schedules. As described above Rule 4311 is on a schedule to fulfill RACT requirements.

4. COMMENT: SJ 4352 – Solid Fuel Boilers, Steam Generators and Process

Heaters: Page 4-68 states that a 40 ppm NOx emission limit is technologically

infeasible for solid fuel fired units. The District should include or reference documentation to support this conclusion.

RESPONSE: The District has conducted sour ce tests on all biomass units applicable to Rule 4352 and none have ac hieved 40ppm NOx. In addition, District staff is unaware of any biomass fi red units that are capable of achieving 40ppm NOx. A feasibility study is current ly underway for this source category,San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Appendix A: Comments and Responses

RACT Demonstration for Ozone SIP A-2 and the District will consider amending Rule 4352 if lower NOx limits are determined to be technologically feasible.

5. COMMENT: SJ 4354 – Glass Melting Furnaces: On page 4-71, the District

states that the limits in Rule 4354 are more stringent than all other analogous limits except flat glass in the BAAQMD rule, and that there are no flat glass
furnaces in the BAAQMD. The District s hould document that there are no such units in the BAAQMD, at least with re ference to communication with BAAQMD

staff.

RESPONSE: Revisions to the report to re ference communication with BAAQMD staff has been included as suggested.

6. COMMENT: SJ 4402, Crude Oil Production Sumps: EarthJustice has

commented that this rule has more ex emptions than other Districts and that

SJVAPCD’s 

### 8-hour ozone attainment plan identif ied the inventory as 3-60 tons of VOC per day. SJVAPCD’s current analysis estimates the inventory at 0.4 tpd VOC and explains why 1 st stage tanks are not necessa rily better than sumps. The analysis further explains that other ex emptions are not cost effective or have negligible emission differences. We re commend the analysis also clarify how the original 3-60 tpd inventory was in error.

RESPONSE: Revisions to the report to clarif y how the original inventory of 60 tpd was calculated and how the revised inve ntory of 3 tpd, has been included as suggested.

7. COMMENT: SJ 4570 – Confined Animal Facilities: In light of the nature of the industry, the limited regulat ory history and the additional information expected in the near term, the District’s draft RACT analysis may be appropriate for many CAF activities. However, additional analysis seems appropriate for those activities with relatively large emissions and potentially smaller variability, such as avian CAFs. Specifically, we re commend closer analysis of the avian CAF menus provided in the rule to see if specific menu options can be required because they are widely available, ec onomically feasible and effective at reducing emissions.

RESPONSE: Based on EPA comments, Chapt er 4 of the report has been revised to include language on Poultry oper ations. In addition, a poultry BACT analysis has also been attached which out lines the requirement s of Rule 4570 being required as BACT. Since these measures have been considered to be BACT for poultry operations, Rule 4570 exceeds the RACT requirements

8. COMMENT: SJ 4602/4612 – Motor Vehicle and Mobile Equipment Coating Operations: We recommend the District include a brief discussion of CARB’s Suggested Control Measure for auto-refi nishing in the RACT analysis.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Appendix A: Comments and Responses

RACT Demonstration for Ozone SIP A-3 RESPONSE: Revisions to the report to address CARB’s Suggested Control Measure (SCM) has been included as suggested.

9. COMMENT: SJ 4603 – Surface Coating of Metal Parts and Products: Page 4- 174 notes several areas where the 2008 CTG is more stringent than Rule 4603 (e.g., VOC limits for baked extr eme performance and repair and touch up coatings, and work practice standards for miscellaneous metal parts and products). Rules meeting the 2008 CTGs are required withi n one year of the date the CTGs are finalized (i.e ., September 30, 2009).

RESPONSE: Revisions to the report further cl arifying how Rule 4603 is, overall, as stringent as the CTG, has been included. In addition, as described in Table 4- 3 of the report, Rule 4603 is on a sc hedule to fulfill CTG requirements.

10. COMMENT: SJ 4605 – Aerospace Assembly and Component Coating Operations: The analysis states that EPA approved Rule 4605 on May 30, 2007. However, we believe that EPA last appr oved Rule 4605 on December 20, 2001
and that more detailed RACT disc ussion is therefore appropriate.

RESPONSE: A more detailed RACT analysi s for Rule 4605 has been included as suggested.

11. COMMENT: SJ 4606 - Wood Products: Rule 4606 exempts refinishing, replacement and custom replica furnitur e coating operations, while the CTG and

rules from other Districts do not. More detailed discussion of this exemption in the RACT analysis seems appropriate.

RESPONSE: Revisions to the report further clarifying how the two permitted facilities which refinish are exempt fr om the requirements of the CTG, has been

included as recommended. In addition, in a follow- up email from EPA, they further stated “Sorry about the confusi on, but we now realize that the Wood Furniture Manufacturing Operations CTG does not apply to refinishing or replacement operations.”

12. COMMENT: SJ 4641 - Cutback, Slow Cure and Emulsified Asphalt Paving and Maintenance Operations: Please explain why the ex emption for medium cure asphalt for ambient temperature less than 50 degrees F is allowed.

RESPONSE: Revisions to the report to expl ain why the exemption for medium cure asphalt for ambient temperature less than 50 degrees F is allowed, has been included as suggested.

13. COMMENT: SJ 4651 - Soil Decont amination Operations: Please change “Municipal Waste Disposal Sites” to “So il Decontamination O perations” in the

conclusion.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Appendix A: Comments and Responses

RACT Demonstration for Ozone SIP A-4 RESPONSE: Revisions to the report has been included as suggested.

14. COMMENT: SJ 4653 – Adhesives: Page 4-294 states t hat the District will evaluate the September 2008 CTG for incl usion into District rules within one year. We note that submittal (not just evaluation) of rules (or negative declarations) meeting the 2008 CTGs are due by September 2009. We also note

SJVAPCD’s determination that Rule 4653 is less stringent than some other

District adhesive limits and that more detaile d evaluation of RACT during the next amendment to the rule is appropriate.

RESPONSE: As described in Table 4-3 of the report, Rule 4603 is on a schedule to fulfill CTG requirements and during the next rule amendment process will address discrepanc ies between Rule 4653 and ot her District’s limits.

15. COMMENT: SJ 4682 – Polystyrene Foam, Po lyethylene, and Polypropylene Manufacturing: Additional information would be useful justifying the 93% capture/control efficiency option and 30-day averaging.

RESPONSE: District Rule 4682 requires that the control device shall have a capture and control efficiency of 93%. This is greater than the previous emission control system requirements of 90% c apture and 95% control (85.5% capture and control efficiency). The District Rule 4682 evaluation in Chapter 4 of the

RACT Demonstration for Ozone SIP will be updated with this information.

Additional information for the monthly averaging period of emissions in District

Rule 4682 can be found in the Final Staff Report for Revised Proposed Amendments to Rule 4682, dated Sept ember 20, 2007, and sent to EPA through ARB on March 7, 2008.

16. COMMENT: SJ 4684 – Polyester Resin Operations: Page 4-338 concludes that Rule 4684 does not satisfy RACT. We appr eciate the District’s analysis, and are available to review proposed changes to the rule.

RESPONSE: As discussed in Chapter 1, RACT is inherently a “moving target” and technology/emission limits considered to meet RACT at the time of SIPapproval is generally rendered obsolete by more effective technology that is introduced at a later date. The last signi ficant modification made to Rule 4684

was in late 2001 1 , whereas the other district rules which were used for comparison were modified in 2005 (SCA QMD and VCAPCD) and as recently as September 2008 (SMAQMD). It should be noted that the BAAQMD Rule which has not been modified since 1996, is less stringent than Rule 4684; further enforcing the concept of RACT as a moving target. Although Rule 4684 limits are not as stringent as some of those contained wit hin other district’s rules, their limits may be considered beyond RACT, es pecially since their requirements are

1 Although Rule 4684 was modified in September 2007, the changes made only addressed the solvent cleaning portions of the rule and did not modify any other emission limits within the rule.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Appendix A: Comments and Responses

RACT Demonstration for Ozone SIP A-5 more stringent than the CTG requirements. Since the CTG was recently adopted (2008), EPA would have conducted a thorough analysis for determining the reasonably available control to apply to the source category. Therefore, although RACT is inherently a “moving target”, a recently adopted CTG can be assumed as establishing RACT. Table 4-3 outli nes the rule schedule for addressing the discrepancies between Rule 4684 versus the CTG and the other rules.

17. COMMENT: SJ 4694 – Wine Fermentation and Storage Tanks: The brief discussion starting on page 4-347 provides some support for the District’s finding that this rule implements RACT. We not e that it does not address the extensive cost-effectiveness analysis previously perfo rmed by the District or the alternative compliance options identified as concer ns by EPA on October 24, 2005, and in subsequent correspondence.

RESPONSE: Revisions to the report further clarifying how Rule 4694 is at a minimum RACT, if not goes bey ond RACT, has been included.

18. COMMENT: SJ 4702 – IC Engines, Phase 2: The District states that they did not pursue a thorough RACT analysis because EPA approved the rule into the SIP on May 30, 2007. We believe the co rrect date is January 10, 2008.

RESPONSE: Revisions to the report has been included as suggested.

19. COMMENT: SJ 4703 – Stationary Gas Turbines: Page 4-353 states that a detailed RACT analysis is not needed because EPA approved the rule on May 30, 2007. We believe the last ve rsion approved was amended in 2002 approved by EPA in 2004, and the RACT analysis should be revised appropriately.

RESPONSE: Based on this comment from EPA, the District has performed an evaluation comparing the NO x emission limit requirements of District Rule 4703

to rules from select air districts withi n California nonattainment areas (South Coast AQMD, Bay Area AQMD, Sacrament o Metro AQMD, and Ventura County APCD). Revisions to the District Rule 4703 RACT evaluation in Chapter 4 has been included as suggested..

A.2 ARB COMMENTS

No comments were received.

A.3 PUBLIC COMMENTS

No comments were received.San Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Appendix A: Comments and Responses

RACT Demonstration for Ozone SIP A-6 This page intentionally blank.RACT Demonstration for Ozone SIP 

## Appendix B

Rule 4570 BACT AnalysisRACT Demonstration for Ozone SIP This page intentionally blank.B- 1 

## Appendix B: Rule 4570 BACT Analysis

TOP-DOWN BACT ANALYSIS

POULTRY BROILER HOUSES

Facility Name: Foster Farms, El Dorado Ranch Date: September 19, 2005

P.O. Box 831

Attn: Environmental Affairs Livingston CA, 95334 Reviewing Engineer: Ramon Norman Mailing Address:

Lead Engineer: Martin Keast

Contact Person: Dave Duke

Telephone: (209) 394-5343

Application #: C-5439-1-1

Project #: C-1051505

Deemed Complete: September 2, 2005

I. PROPOSAL:

The primary business of Foster Farms, El Dorado Ranch is the pr oduction of broiler chickens to provide meat for human consumpt ion. Foster Farms, El Dorado Ranch has requested Authority to Construct (ATC) permits for the addition of 12 new mechanically

ventilated broiler houses fo r 397,440 birds (33,120 birds/hous e) and one diesel-fired emergency IC engine at 1324 South El Dorado Ave. in Tranquility, CA.

Foster Farms, El Dorado Ranch is an agricul tural operation that raises fowl for human consumption. Pursuant to Senat e Bill (SB) 700, all agricul ture operations, including

Confined Animal Facilities (CAF), with emissions greater than 1⁄2 the major source

emissions threshold levels (12.5 ton/year of NO X or VOC), are required to obtain a District permit. The existing 1,280,000 bird broiler oper ation has emissions exceeding the 12.5 ton-VOC/year threshold and is classified as a large CAF by the California Air Resources Board (ARB). The facility received a District permit for the existing operation on April 28,

2005.

Since the broiler operation is subject to per mitting requirements and t he addition of the new mechanically ventilated broiler ho uses will result in VOC and NH 3 emissions exceeding the Best Available Control Technology (BACT) thre shold of 2.0 lb/day for each house, BACT is required for VOC and NH 3 emissions from the new houses.

II. PROCESS DESCRIPTION:

Broilers are produced to meet specific require ments of the customer, which can be a retail grocery store, fast-food chain, or an institutional buyer. T he process of raising broilerB- 2 chickens in the proposed houses is similar to t he practices at modern broiler ranches. The production cycle of broilers is divided into two phases: brooding and grow-out. The brooding phase begins when freshly hatched chi cks from local hatcheries are delivered by truck and placed in a heated section of a bro iler house known as the brood chamber. The

brood chamber of the house is maintained above 90 ° F for newly hatched chicks. At this site, about 33,120 chicks will be released into each house at the beginning of each grow-out period. The chicks will be placed on fresh litter in the front half of t he house opposite the tunnel-ventilation fans for 10 days. During t he birds’ first few weeks of growth, the temperature is gradually decreased. Once the birds need floor space, the remaining half of the house is opened and the chicks are fed out to market wei ght. After completion of the grow-out phase the broilers are transported by truck to a nearby processing plant. Typically, all of the houses within a ranc h complex will be populated with chicks, and depopulated with mature birds within the same few days.

All broiler chickens in the house are the same age and will be removed from the house at the same time. Typically, about 4.5 to 5 percent of the broilers in a house will die (mortality) during the grow-out cycle. Mort ality must be removed from each house at least daily during the grow-out cycle to prevent the spread of disease. The l ength of the grow-out phase for the broiler chickens is approximately 45 days, re sulting in an average we ight of 4.5 to 5.5 pounds. Broiler houses will be empty of chickens for approximately 10 days between flocks to allow for cleaning and maintenance. This results in a cycle time of about 55 days per flock. Typically, six flocks per year are grown in each broiler house.

Broiler Housing

Broilers are raised in either totally or parti ally enclosed housing with a compacted soil floor covered with dry bedding. The broiler houses at this site will be constructed with earthen floors, wood framing, and corrugat ed metal roofing and siding. The ceiling and walls will be insulated. Each house will be 460 feet long and 54 feet wide. As stated above, about 33,120 chicks will be released into each house at the beginning of each grow-out period.

The birds will be able to move a bout freely in the heated front se ction of the house. As the birds grow and require less heat, the other half of the house is opened to allow them to have more space. Water and feed will be provided to the birds throughout the grow-out period. Propane heaters and evaporative coo ling pads are utilized to cont rol temperature within the

broiler houses.

In poultry houses, ventilation is used to re move moisture and ammonia from the houses during the winter season and to remove exce ss heat and ammonia from the houses during the summer season. Partially enclosed housing structures hav e open sidewalls with curtains that are opened and closed to control the hous e ventilation rate. At this site, all of the houses will be totally enclosed. In totally enclosed housing, mechanical ventilation is

used. Mechanical ventilation is typically provided by an induced draft or negative-pressure system. An induced draft system pulls fresh air into the house from one end and exhausts on the other. A negative-pressu re system draws fresh air in to the house from side vents and out through the exhaust fan. Totally enclosed mechanically ventilated housing is known as tunnel-type housing or environmental housing.B- 3 The proposed houses will have an advanced env ironmental control system that uses thermostats, sensors, and timers to more effectively control their exhaust fans. Environmental conditions (e.g. temperature, humidity, ventilation, lighting) within the proposed houses will be cont rolled by a computer system. T he ranch staff will also monitor the conditions within the houses at least twice daily.

Broiler Manure Management

All broiler chickens are raised unconfi ned within the houses on dry bedding (litter). Litter can be sawdust, wood shavings, rice hulls, chopped straw, peanut hulls, or other products, depending on availability and cost. Foster Farms, El Dorado Ranch typically uses rice hulls

for litter. Manure that is ex creted by birds has a high water content. The main function of

the litter is to absorb the mois ture excreted by the birds.

A typical broiler house with a capacity for 22,000 bi rds at a time will produce 120 tons of litter per year (NCC, 1999). Since the proposed houses are 50% larger, cont aining 33,120 birds, each house would be expected to produce 180.7 tons of litter per year. Two kinds of manure

are removed from broiler houses: litter and cake. Litter is a mi xture of bedding and manure. Cake is a compacted and concentrated mixture of manure and litter that usually builds up on

the surface of the litte r around waterers and feeders, where much of the manure is deposited.

Moisture from manure and waterers binds the mixture of litter and manure together forming

cake. Broiler houses are partially cleaned between eac h flock to remove cake. The remaining litter may be “top dressed” with an in ch or so of new bedding material.

Typically, the litter (bedding and manure) is only completely cleaned from broiler houses every one to three years after at least 6 flo cks, with a trend towards performing complete clean-outs less than annually. Litter in the proposed houses will be completely cleaned out twice a year after only 3 flocks have been raised on the litter. At Foster Farms, El Dorado Ranch used litter is completely cleaned out of the brood chamber and moved to the other half of the house before chicks are placed. In the proposed houses, chicks will always be placed on fresh litter in the brood chamber. After complete clean-outs and brood chamber clean-outs, the removed litter is replaced wit h fresh litter. When the broiler house is completely cleaned out, the litter is typically removed with a front-end loader. When the house is cleaned, the equipment (i ncluding slats) is removed from the house to allow a front-end loader to push all of the manure to the center sect ion of the house. Then the front-end loader places the mixt ure of manure and litter into a spreader for land application. A thorough cleaning after each flock removes pathogens that could be transferred to the

next flock. After removal of all organic matter, the house is disinfected.

Broiler Manure Storage

After complete cleanout of the litter after eac h flock, the litter is trucked off site. Traditionally, cake from broiler production fa cilities has been stored in uncovered stockpiles until conditions permitted land app lication. However, water quality concerns have led to the increased use of storage structur es known as litter sheds for cake storage. Litter sheds typically are partially enclosed pole type struct ures. Water quality concerns also have led to

the recommendation that cake no t stored in litter sheds be placed in well-drained areas andSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-362 How does District Rule 4694 compare to rules in other air districts?

District staff compared emission limits, opti onal control requirements, and work practice standards in District Rule 4694 to comparable requirements in rules from the following

California nonattainment areas:

• South Coast AQMD (no rule for this source category)

• Bay Area AQMD (no rule fo r this source category)

• Ventura County APCD (no rule for this source category)

• Sacramento Metro AQMD (no rule for this source category)

Conclusion

During the rule development process of adopting Rule 4694, sta ff performed extensive research to determine what types of contro ls that could be applied to this source category. The staff repor t for the rule states:

“The US EPA maintains a database on case-specific information on the "Best Available" air pollution technologies that have been required to reduce the emission of air pollutants from stationary sources (e.g ., power plants, steel mills, chemical plants, etc.). The US EPA

database contains no ex amples of controlling wine fermentation emissions. Additional literature searches produced no examples of fermentation emission control being implemented anywhere in the world. The Distri ct is the first district in t he nation, perhaps the world, to propose controlling VOC emissions from wine fermentation tanks.”

In addition, District staff work with industry stakeholders to perform an extensive costeffectiveness analysis for the proposed cont rol technologies proposed for the rule.

Since there are no federal regulations or prohibitory rules in other California nonattainment areas, District staff concludes that District Rule 4694 at a minimum satisfies RACT, if not goes beyond RACT for Wine Fermentation and Storage Tanks.B- 4 be covered to prevent contaminated runoff and l eaching. However, covering of stockpiles of

cake is rare.

Emissions from Broiler Litter

The principal pollutants emitt ed from broiler houses are Volatile Organic Compounds (VOC) and ammonia (NH 3 ). A small amount of particulate matte r (PM) is also emitted through the ventilation system. Factors that affect emissi ons from broiler houses include the moisture content of the litter; the pH; t he ventilation rate; the temperat ure; and the amount of manure and length of the time t he manure is present in the broiler house.

Manure as excreted by the birds has a high water content, most of which evaporates, emitting

ammonia as the manure dries out . Ideally, litter in the broile r houses should contain no more
than 20-25% moisture. 1 High moisture content in the litter will lead to the development of anaerobic conditions and the production of hy drogen sulfide and other reduced sulfur compounds. High moisture content in the litte r will also lead to greater production of VOCs

and methane and will facilitate t he further conversion of organic nitrogen to ammonia. Additionally, the greater the moisture content the more fa vorable the environment for microbes responsible for emissions of ammonia and volati le organic compounds (VOC), which increases

the likelihood that these com pounds will be emitted. Moisture inside the broiler houses is controlled by adequate ventilation and regular main tenance of waterers to ensure that there

are no leaks.

The ventilation rate affects t he amount of ammonia, VOC, and particulate matter carried out of the broiler house. During t he growth of the flock, cont inuous airflow removes ammonia and other gases and reduces the moisture of c ontent freshly excreted manure. The constant

volatilization and removal of ammonia from t he broiler houses results in lower nitrogen

content of the litter.

The potential to emit ammonia and VOCs incr eases with greater manur e storage time and greater manure accumulation in the houses. The amount of manure and length of the time the manure is present in the br oiler house is determined by t he number of flocks that are raised on the litter before a complete cleanou t. Fresh litter will have negligible emissions.

Litter that has been reused for several flocks may have considerable emissions because of the accumulation of manure. As stated above, broiler houses are typically completely

cleaned out after at least 6 flocks have been ra ised but the litter in t he proposed houses will be completely cleaned after only 3 flocks have been raised.

VOC Emissions

Volatile organic compounds are formed as in termediate metabolites in the degradation of organic matter in manure. Under aerobic condi tions, any VOC formed are rapidly oxidized

to carbon dioxide and water. Under anaerobic conditions, complex organic compounds are microbially decomposed to volatile organic acids and other volatile organic compounds,

1 Lesson 11: Using Dietary and Management Strategies to Re duce the Nutrient Excretion of Poultry; Paul PattersonB- 5 which in turn are mostly converted to methane and carbon dioxide by methanogenic bacteria. When the activity of the methanogenic bacteria is not i nhibited, virtually all of the VOC are metabolized to simpler compounds, and the potential for VOC emissions is minimized. However, the inhibi tion of methane formation results in a buildup of VOCs in the litter and ultimately to volatili zation to the air. VOC emis sions will vary with temperature because the rate of VOC formation, reduction to methane, and volatilization varies with temperature. 2

Control of VOC Emissions

In comparison to the research on ammonia em issions from broiler houses, little research has been performed on the methods to reduce VO C emissions from broiler houses. Most of the research to this point has focused specif ically on odor reduction. However, since VOC

and ammonia emissions are the result of a sim ilar microbial process, some of the methods that have been proven to reduc e ammonia emissions are also expected to reduce VOC

emissions. In addition to t hermal incineration and carbon adsorption, other possible controls include biofiltration; di et manipulation; the use of acidifying litter amendments such as Alum (aluminum sulfate), Poultry Litter Trea tment (PLT, sodium bisulfate), Poultry Guard (clay material containing sulfuric acid), phosphoric acid, etc.; litter management practices and broiler house construction; and the use of certain probiotics.

A biofilter is a device for removing contaminants from a gas in which the gas is passed through a media that supports the microbial activity by which the pollutant is degraded. One type of biofilter involves a porous medium (typically soil, compost or wood chips - green waste) that contains large populations of microbes. This ty pe of biofilter system can be used to control the

VOC emissions in the exhaus t of the broiler house.

Nutritional management of broiler feed is routinely practiced to improve meat production and bird health. The potential for VOC emission s can be reduced by reducing the quantity of undigested nutrients in the litter. The majority of VOCs orig inate from the decomposition of undigested protein from which ammonia is also a byproduct. 3 The level of microbial action in the litter corresponds to the level of organic nitrogen content in the litter; the lower the level of nitrogen the lower the level of microbial acti on and the lower the produ ction of ammonia and

VOC.

A diet that is formulated to feed proper amounts of protein will result in improved nitrogen utilization by the animal and corresponding reducti on in uric acid, organic nitrogen content of litter, and VOC and ammonia production. Nit rogen excretion can be reduced by replacing crude protein in broiler diets with the specific am ino acids required. It is possible to reduce crude protein levels by 3-4%, which will resu lt in reductions of 13-22% in nitrogen without detriment to bird performance. 4 Enzymes and feed additives are also commonly used in conjunction with certain feeds to increase nu trient digestibility and nitrogen retention. 4 Studies on the digestibility of protein and amino acids in broiler ch ickens fed a corn and soybean diet

2 Emissions From Animal Feedi ng Operations – Draft, pg. 2-10

3 PJ Hobbs et al

4 Lesson 11: Using Dietary and Management Strategies to Re duce the Nutrient Excretion of Poultry; Paul PattersonB- 6 showed the supplementation of the enzyme phytase resulted in increased weight gain and digestibility of most amino acids. 5 The latest National Research Council (NRC) guidelines for the selection of an optimal poultry diet should be followed to the maximum extent possible. The diet recommendations made in this publicat ion seek to achieve the maximum uptake of protein by the bird and the minimum ca rryover of nitrogen into the litter.

Acidifying litter amendments such as Alum (alumi num sulfate), Poultry Litter Treatment (PLT, sodium bisulfate), Poultry Guard (clay material containing sulfur ic acid), phosphoric acid, etc. are commonly used in poultry hou ses to reduce ammonia concentrations in the house during the critical first few weeks of bird developmen t. Acidifying litter amendments are available in both granular and solution form, depending on t he needs of the grower. Preliminary studies

indicate that these amendments also result in lower VOC emissions. The reduction in VOC emissions is likely to be related to the inhibi tion of the growth of microbes responsible for decomposition of nutrients in the litter. It has been demonstrated that sufficient application of acidifying litter amendments to floor of a poultry house can reduce the total bacterial count by
more than 99.99%. 6 The application of PLT to litter result ed in significant reductions of total bacterial count for 21 days as compared to control. 7 At an application rate of 100 lb per 1,000

ft 2 of broiler house floor space, granulated sulfuric acid and sodium bisulfate reduced bacterial pathogen levels. There have been several studies t hat show that acidif ying litter amendments such as alum reduce the levels of bacterial pathogens, such as Salmonella and Campylobacter in the litter and on bird carcasses. 8 Since bacteria are responsible for VOC and ammonia production, this inhibition of micr obial action translates into a reduction in VOC

and ammonia emissions. More information about acidifying litter amendments is given under ammonia control options.

Broiler house construction and management pr actices are another method to reduce VOC emissions. The proposed houses are completely enclosed environmentally controlled houses in which the relative humidity is monitored to ensure that excessive moisture does not contact the litter. There is some research indicating that mechanically vent ilated houses have less ammonia emissions than naturally ventilated houses. 9 Since there is correlation between VOC and ammonia emissions in poultry houses 10 , there may also be VOC reductions from mechanically ventilated houses in comparison to naturally ventilated ho uses. The computer

controlled ventilation fans are more effectiv e at reducing moisture inside the houses than natural (curtain) ventilation. The use of ev aporative cooling pads as opposed to misting systems also reduces the chances that excessi ve moisture will contact the litter. House insulation and the use of mixing fans inside the house will help create great er uniformity in the temperature and relative humidity in the houses. This will minimize condensation inside the

house caused when warmer air contacts cooler su rfaces. Total cleanout of the houses twice per year will reduce the amount of organic material in the litter and the amount of time that this material is present, thereby decreasing the potential to emit VOCs and ammonia.

5 Sebastian et al.

6 “Litter Amendments as a Tool for Optimizing Poultry House Clean Out”, Avian Advice, Summer 2003, Vol.5, No. 2

7 Dr. Richard Chin, California Veterinary Diagnostic Laborato ry, Fresno - Final Bacteriological Results July 31, 1995

8 Dr. Philip Moore, Jr., USDA/ARS, Fayetteville, Arkansas

9 Ammonia Monitoring in Northern Ireland – comparison of ammoni a concentrations downward of two types of broiler houses in

Northern Ireland (March 2005), SNIFFER

10 PJ Hobbs et alB- 7 Probiotics are microorganisms wi th beneficial characteristics. These microorganisms are usually the viable microbial cultures or thei r fermentation products. Most probiotics work through competitive exclusion, m eaning that they cause a shift in the bacterial population from less desirable species to more desirable specie s. Probiotics have many of the advantages of

antibiotics without the drawback of possibly creating antibiotic resistant pathogens. Bacterial enzymes in probiotics also promote the diges tion of protein, lipids, and carbohydrates 11 , which

will cause less of these nutrients to be excreted. Probiotics are used extensively in the poultry industry to promote animal health. The introducti on of certain probiotics to poultry feed and litter has potential to reduce VOC and ammonia emissions. Recently, they have been used in Taiwan's animal farming industry to address c oncerns about the environmental impact of the animal farming. In one experim ent, the introduction of Ecozym e©, a lactobacilli containing probiotic, to broiler feed reduced the pH and mo isture content of the litter and resulted in greater than 90% reductions in malodorous VOC compounds. 12 The results of the study were confirmed by the Malaysian Animal Research In stitute. The use of probiotics to control emissions is a developing area and more re search is needed to quantify all potential reductions. Non-pathogenic bacteria can also be intr oduced into the litter in order to speed the

oxidation of ammonia to nitrate and nitrite. 13

Ammonia Emissions

Ammonia in the presence of sulfur dioxide and nitrogen oxides is a precursor for the secondary formation of PM 2.5 in the atmosphere. Ammonia r eacts with sulfuric and nitric acids, which are produced from su lfur dioxide and nitrogen oxides in the ambient air, to form ammonium sulfate, ammonium ni trate, and other fine particulates. 14 Exposure to high levels of ammonia can cause irritation to the skin, throat, lungs, and eyes.

Ammonia volatilization is the result of the microbial decomposition of nitrogenous compounds in poultry litter. T he primary nitrogenous compound in poultry litter is uric acid, but nitrogenous compounds also occur in the fo rm of undigested organi c nitrogen in poultry

feces. Whenever uric acid comes in contac t with the enzyme urease, which is excreted in animal feces, the uric acid wi ll hydrolyze rapidly to form ammonia and this ammonia will be

emitted soon after. The formati on of ammonia will continue mo re slowly (over a period of months or years) with t he microbial breakdown of organic nitr ogen in the litter. The rate of ammonia volatilization is influenced by a number of factors including the concentrations of nitrogenous compounds in the litter, temperature, air velocity, surface area, and moisture.

Several researchers have attempted to quantif y ammonia emissions from broiler houses. However, there is great variability in the es timates to quantify ammonia emissions from broiler houses. Wheeler (2003) r eported that overall ammonia emissions for birds from 1 to 23 days old housed in eleven broiler houses in Kentucky and Pennsylvania during the winter months varied from 0.2 – 0.92 g day -1 bird -1 on used litter and 0.0 – 0.92 g day -1 bird -1

11 Larbier and Leclercq, 1994

12 M. H. Chang and T. C. Chen, International Journal of Poultr y Science 2 (5): 313-317, 2003

13 “Litter Treatment”, Martine Bou lianne, University of Montreal

14 Workshop Review Draft for EPA Regional Priority AFO Science Qu estion Synthesis Document - Air Emission Characterization and

Management, pg. 2B- 8 on fresh litter. Gates et al. (2004) reported that overall ammonia emissions from twelve broiler houses in Kentucky and Pennsylvania duri ng the winter months varied from 0.0 – 1.5 g day -1 bird -1 . Lacey et al. (2003) reported ammoni a emissions ranging from 0.05 – 1.90 g day -1 bird -1 for broilers raised in central Texas over a 49 day grow- out period. Groot Koerkamp et al. (1998) reported amm onia emissions ranging from 8.9 mg hr -1 bird -1 (0.21 g day -1 bird -1 ; 0.17 lb year -1 bird -1 ) to 19.8 mg hr -1 bird -1 (0.48 g day -1 bird -1 ; 0.38 lb year -1 bird 1 ). An average ammonia emissi on factor of 0.22 lb year -1 bird -1 (0.28 g day -1 bird -1 ) was reported in the EPA Regional Priority AFO Science Q uestion Synthesis Document - Air Emission Characterization and Management (Tab le 2-6, Poultry Emission Factors). A recent

California Air Resources Board st udy at a Foster Farms broiler house resulted in an ammonia emission factor of 0.0958 lb year -1 bird -1 (approximately 0.121 g day -1 bird -1 ). Variations in temperature, humidity, litter managemen t, feed formulation, stocking density, and measurement methodology may all contribute to the wide variation in ammonia emission

estimates from broiler houses.

Control of Ammonia Emissions

Many of the VOC control strategies ment ioned above are also effective in controlling ammonia emissions. Of these strategies much research has confirmed the ability of acidifying litter amendments such as Alum (a luminum sulfate), Poul try Litter Treatment (PLT, sodium bisulfate), Poultr y Guard (clay material containi ng sulfuric acid), phosphoric acid, etc. to reduce am monia volatilization.

Ammonia emissions are greatly influenced by li tter pH. Once formed, the ammonia will be in

one of two forms: as the unc harged form of ammonia (NH 3 ) or the ammonium ion (NH 4 +),

which is nonvolatile. Ammonia is also less so luble in water than the ammonium ion. Under acidic conditions (pH values of less than 7.0) ammonium is the pred ominate species, and

ammonia volatilization occurs at a lower rate than at higher pH values. However, some

ammonia volatilization occurs even under moderat ely acidic conditions. Volatilization of ammonia increases with increasing pH. Uric ac id decomposition occurs most rapidly under alkaline (pH>7) conditions. Uricase, the enzym e that catalyzes uric acid breakdown, has maximum activity at a pH of 9. One principal ureolytic bacterium, Bacillus pasteurii, cannot grow at neutral pH, but thrives in litter above pH 8.5. 15 The litter pH in a broiler house can range between 8.5 and 10.0, which results in fa irly rapid ammonia volatilization.

15 Alabama Cooperative Extension, ANR-1199 April 2001B- 9 All acidifying litter amendments work in a sim ilar manner. The free hy drogen ions (H+) that

exist under acidic conditions react with amm onia to form nonvolatile ammonium ions. The

ammonium then reacts with sulfate i ons to form ammonium sulfate ((NH 4 ) 2 SO 4 ), a watersoluble fertilizer. Because of these reactions, t he amount of ammonia em itted from the litter will be reduced and the nitrogen (N ) content of the litter will increase, which may make it

more valuable as a fertilizer.

Acidifying litter amendments are generally most effective t he first three weeks after application. Since poultry manur e is alkali, the continual additi on of more manure to the litter will counteract the acidifying affect of the amendments, eventually raising the pH above neutral. Although these products ar e typically only applied at the beginning of the grow-out cycle, it is possible to reapply some acidif ying litter amendments such as PLT (a non-toxic product) to reduce pH and prov ide further ammonia control after the birds have been placed. Dry alum activates more quickly if suffi cient moisture is present (>18%). Because of this more growers are currently using liquid alum (which does n't need moisture to activate) than dry alum. 16

Research has shown that alum can be us ed to reduce ammonia emissions by 70%. 16 A flux chamber study by Moore, USDA (1997b) demons trated the use of alum reduced ammonia emissions by 97% during the 1 st four weeks of grow-out and 75% during for the full 6 weeks. These results were confirmed by Brewer in 1998 (1999 Poultry Science Journal 78:692- 698). McWard and Taylor found that all ac idifying litter treatments worked to reduce ammonia emissions for up to four weeks and f ound little difference in the effectiveness of the treatments that they tested (alum, sodium bisulfate, and acidified clay) (2001 Journal of Applied Poultry Research Vol. 9, No. 4). A study by Moore, Daniel, Edwards, and Miller on

the “Effect of Chemical Am endments on Ammonia Volatilizatio n from Poultry Litter” showed that alum reduced ammonia volatilization by up to 99% vs. untreated litter (American

16 Dr. Philip Moore, Jr., USDA/ARS, Fayetteville, ArkansasB- 10 Society of Agronomy, Mar/Apr 1995 v. 24(2) pg. 293-300). Terzich (1998) reported that sodium bisulfate significantly redu ced litter pH and ammonia emissions.

Operating Schedule:

The typical operating schedule for the facilit y is 24 hours per day, 7 days per week, and 12 months per year.

III. EQUIPMENT LISTING:

12 new mechanically ventilated broiler houses for 397,440 birds (33,120 birds/house) (177 total combined hp)

Each House

One 460 ' L X 54 ' W mechanically ventilated broiler house with capacity for 33,120 birds

Ten 52” tunnel ventilation exh aust fans (1 hp each)

One 48” exhaust fan (1 hp)

One 36” exhaust fan (3⁄4 hp)

Six 24” circulating fans (1⁄2 hp each) 14.75 total electric hp

Proposed Modification :

C-5439-1-1: MODIFICATION OF 1,280,000 BROILER HEN RANCH, CONSISTING 48 NATURALLY/MECHANICALLY VENTILATED BROILER HOUSES,

INCLUDING ELECTRIC FANS TOTALI NG 480 HP: ADD 397,440 BROILERS

AND 12 MECHANICALLY VENTILATED BROILER HOUSES

Post Project Equipment Description :

C-5439-1-1: 1,677,4400 BROILER HEN RANCH, CONSISTING 60 NATURALLY/MECHANICALLY VENTILATED BROILER HOUSES,

INCLUDING ELECTRIC FANS TOTALING 657 HP

VI. EMISSION CONTROL TECHNOLOGY EVALUATION

A. BACT Applicability

Pursuant to District Rule 2201, Sections 4. 1.1 and 4.1.2, BACT shall be applied to a new, relocated, or modified emissions unit if the ne w or relocated unit has a Potential to Emit (PE) exceeding two pounds in any one day or the modified emissions unit results in an Adjusted Increase in Permitted Emissi ons (AIPE) exceeding 2 lb/day for NO X , SO X , PM 10 , CO, VOC, or NH 3 . For CO emissions, the CO Post-pro ject Stationary Sour ce Potential to Emit (SSPE2) must also exceed 200,000 lb/year to trigger BACT.B- 11 As shown in section VII.C.1 of the engineer ing evaluation and the t able below, each of the proposed new broiler houses will result in a PE of 2.3 lb/day for VOC and 8.7 lb/day for NH 3

. Therefore, BACT is triggered for VOC and NH 3 emissions.

Post Project Potential to Emit (PE2) (lb/day)

NO X SO X PM 10 CO VOC NH 3 New Broiler House for 33,120 birds 0 0 1.8 0 2.3 8.7

BACT triggered? No No No No Yes Yes

B. BACT Policy

Per District Policy BACT APR 1305-1, Sect ion IX, “A top-down BACT analysis shall be performed as a part of the Application Revi ew for each application subject to the BACT requirements pursuant to the District’s NSR Rule.” For source categories or classes covered in the BACT Clearingho use, relevant information under each of the steps may be simply cited from the Cleari nghouse without further analysis.

C. Achieved in Practice Determination

The U.S. Environmental Protection Agen cy (USEPA) RACT/BACT/LAER Clearinghouse,

the California Air Pollution Control Officers Associati on (CAPCOA) BACT Clearinghouse, the San Joaquin Valley Unified Air Polluti on Control District (SJVUAPCD) BACT Clearinghouse, the Bay Area Air Quality Management District (BAAQMD), and the South Coast Air Quality Management District (SCA QMD) BACT Guidelines were reviewed to determine potential control technol ogies for this class and cat egory of operation. No BACT guidelines were found for this cl ass and category of source. No prohibitory rules specifically regulating this category of source were identified for any Calif ornia air district.

D. Best Available Control Technology (BAC T) Analysis for Permit Unit C-5439-1-1

BACT Analysis for VOC Emissions:

Step 1 - Identify All Possible Control Technologies

The control technology options include:

Option 1. Emissions from Broiler House controlled by Carbon Adsorption Option 2. Emissions from Broiler H ouse controlled by Thermal Incineration Option 3. Emissions from Broiler House controlled by Catalytic Incineration Option 4. Emissions from Broiler House cont rolled by a Biofilter capable of achieving

80% control Option 5. Total house cleanout after two flocks (3 times per year) Option 6. Total house cleanout after one flock (6 times per year) Option 7. Animals fed in accordance with National Research Counsel (NRC) or other District accepted guidelines ut ilizing routine nutritional analysis for

rationsB- 12 Option 8. Broiler House Construction and Management Practices 1. Insulated & mechanically ventilated poultry house + 2. Mortality removed twice per day + 3. Evaporative cooling pads to regulate house temperature + 4. Mixing Fans Option 9. Usage of probiotics

Step 2 – Eliminate Options

Option 5 (Total house cleanout after two flo cks (3 times per year)) and Option 6 (Total cleanout after one flock) will be eliminated from consider ation at this time. Although more frequent removal of litter from the bro iler houses would result in less emissions from the house, it is likely that these emissions would mere ly be shifted to litter storage areas. Unless the litter storage areas were controlled, there would be no emission reductions. Additionally, as a particulate ma tter control, the facility’s Conservation Management Practice (CMP) plan requires that the litter be used for at least two flocks. More frequent cleanouts would caus e a greater amount of direct PM 10 emissions to the atmosphere.

Option 9 (use of probiotics) will be eliminat ed from consideration at this time. Although this method shows some promise, more research is needed to verify the emission

reductions. Probiotics are livin g organisms and their ability to inhibit emissions is likely to be affected by many variables. These variables have not yet been identified to an

extant that would insure t hat emissions would be decreased in cases in which probiotics

are used.

Step 3 – Rank Remaining Control Tech nologies by Control Effectiveness

Control technologies for VOC:

VOC Emission Control Technology Rankings

Rank Control Efficiency Status

1) Thermal Incineration 98% 17 Technologically Feasible 2) Catalytic Incineration 95% 18 Technologically Feasible 3) Carbon Adsorption 95% 19 Technologically Feasible 4) Biofiltration 80% 20 Technologically Feasible

17 OAQPS Control Cost Manual, 4th Edition, EPA 450/3-90-006, January 1990, page 3-8.

18 EPA-456/R-95-003, Survey of Control Technologies for Low Concentration Organic Vapor Gas Streams , Control Technology Center,

May 1995, section 2.1, Catalytic Inciner ation, pages 13-16. The 95% value used is based upon EPA permit No. 23GS-93-OT-1 for 3M Company in St. Paul for an ARI, Econ-Abator catalytic oxidizer, Emission Point No. 2.

19 EPA-456/R-95-003, Survey of Control Technologies for Low Concentration Organic Vapor Gas Streams , Control Technology Center,

May 1995, Section 3, Adsorption, pages 45 - 46.

20 According to the SCAQMD Rule 1133.2 final staff report (page 18) “Technology Assessment Report states a well designed, well operated, and well-maintained biofilter is capable of achieving 80% destruction efficiency for VOC and NH 3 .”B- 13 VOC Emission Control Technology Rankings

Rank Control Efficiency Status

5) Broiler House Construction and Foster Farms Management Practices 15% 21 Achieved in Practice

6) Acidifying Litter Amendments 15% 22 Technologically Feasible 7) Animals fed in accordance with National Research Counsel (NRC) or other District accepted guidelines utilizing routine nutritional analysis for rations 9% 23 Achieved in Practice

Step 4 - Cost Effectiveness Analysis

Thermal & Catalytic Incineration:

The following cost analysis demonstrates that the cost of natural gas alone, not including any capital costs, causes catalytic incineration to exceed t he District VOC cost effective threshold. The temperature required for catalytic incineration is 600 ° F. The temperature required for t hermal incineration is 1,400 ° F. Since the fuel requirements

and fuel cost for thermal inci neration are greater than cataly tic incineration, the following analysis also demonstrates t hat thermal incinerat ion would not be cost effective.

Broiler House Air Flow Rate

In order to effectively calculat e the costs of this control opt ion, the broiler house airflow rate must be determined. According to the a pplicant, the broiler house airflow rate can range from 2,700 cfm (new ch icks on a cold night) to 212,000 cfm (mature birds on a hot day). Typical flow rates are 70,000 cfm in the spring and fall, 100,000 cfm in the summer, and 40,000 cfm in the winter. For mo re conservative calculations, an average airflow rate of 40,000 cfm will be assumed for the broiler houses.

Fuel Requirement:

The gas leaving the broiler house is principally air, with a volumetric specific heat of

0.0194 Btu/scf - ° F under standard conditions.

Natural Gas Requirement = (flow)(Cp Air )( Δ T)(1-HEF)

Where:

21 Estimate based on the ability of the computer-controlled, enclosed, mechanically ventilated broiler house to maintain lower li tter moisture, which inhibits microbial action leading to VOC emissions.

22 Conservative estimate based on the ability of lower pH to inhibit microbial action leading to VOC emissions

23 Assuming that undigested protein in bird excrement, which emits VOCs during decomposition, can be reduced 15% by feeding with NRC guidelines and that 60% of VOC emissions are from decomposit ion of excrement in the litter (CARB emissions report states th at propane and vinyl acetate emissions, which compose 28.9% of total VOC emissions, are likely from propane heaters, feed and supplements, and off-gassing from house materials. Some emissions are also from fermentation of the feed.)B- 14 Flow (Q) = exhaust flow rate of VOC broiler house exhaust: 40,000 ft 3 /hr

Cp Air = specific heat of air: 0.0194 Btu/scf - ° F

Δ T = increase in the temperat ure of the contaminat ed air stream required for catalytic oxidation to occur (It will be assumed t hat the air stream would increase in temperature from 100 ° F to 600 ° F.)

HEF = heat exchanger factor: 0.7

Natural Gas Requirement = ( 40,000 scf/hr)(0.0194 Btu/scf - ° F)(600 ° F - 100 ° F) (1-0.7)

= 116,400 Btu/hr

Fuel Cost for Incinerator:

The cost for natural gas shall be bas ed upon on an average taken from February 2005 to August 2005 from the Oil Energy website: http://www.oilnergy.com/1gnymex.htm#year

Cost for gas = $7.34/MMBtu

The oxidizer is assumed to operate 24 hours per day and 300 days per year.

The fuel costs to operate the inci nerator are calculated as follows:

116,400 Btu/hr x 1 MMBtu/10 6 Btu x 24 hr/day x 300 da y/year x $7.34/MMBtu = = $6,152/house-year

VOC Emission Reductions

The California Air Resources Board (CARB) has performed a source test on the Foster Farms Broiler operation that result ed in a VOC emission factor of 0.0248 lb-VOC/birdyear. Foster Farms is constructing enclos ed computer-controlled broiler houses. Both humidity and water usage are monitored in the houses. Since the moisture control exceeds the industry standard, the emissi on factor is considered 15% lower than industry standard and must be increased to industry standard for cost analysis

purposes.

VOC emissions = (0.0248 lb-VOC/bird-y ear) (1/0.85) (33,120 bird/house) = 947 lb-VOC/house-year

Cost of VOC Emission Reductions

Cost of reductions = ($6,152/year- house)/((947 lb-VOC/year)(1 ton/2000 lb))

= $12,993/ton of VOC reduced

As shown above, the natural gas cost alone for thermal or catalytic incineration would

cause the cost of the VOC reductions to be greater than the $ 5,000 /ton costB- 15 effectiveness threshold of the District BACT po licy. The equipment is therefore not cost effective and is being removed from consideration at this time.

Carbon Adsorption:

Carbon adsorption occurs when air that co ntains contaminants is blown through a carbon unit and the pollutants are adsorbed ont o the surface in the variously sized pours in the activated carbon unit.

Two main areas of cost are the cost of the device itsel f, and the operating cost of the carbon adsorption system.

The following cost analysis demonstrates that the cost of activated carbon alone, not including any other costs, causes carbon adsor ption to exceed the Dist rict cost effective

threshold. Treated activated carbon c an control both VOC and ammonia emissions. Although, this technology can control both pollu tants, a cost effective threshold has not been established for ammonia. Therefore, on ly achieved-in-practice options will be

considered for ammonia at this time and a multi-pollutant cost effective analysis for VOC and ammonia will not be performed.

VOC Emission Reductions

VOCs controlled = 0.0248 lb-VOC/bir d-year x 33,120 bird/house x 0.95

= 780.3 lb-VOC/house-year

Adjusted to industry standard = 780.3 lb-VOC/house-year x (1/0.85)

= 918 lb-VOC/house-year

Amount of Activated Carbon Required for VOC Control

Carbon can adsorb 20 % of it's weight in VOCs. 24

Carbon required = ( 918 lb-VOC/year ) x 1 lb-Carbon/0.2 lb-VOC

= 4,590 lb-carbon/year

Cost for Activated Carbon for VOC Control:

Assuming a price for carbon of $ 1.00 /lb*

*Note: from GEAR 12 - Motor Vehicle and Mobile E quipment Coating Operations: Actual cost estimate was $2.00/lb. An amount of $1.00/lb was assumed to be conservative.

Carbon cost = 4,590 lb-carbon/yr x $ 1.00 /lb = $4,590/house-year

Cost of VOC Emission Reductions

24 District GEAR 9 - Soil Remediation Project Utilizing an Activated Carbon SystemB- 16 Cost of reductions = ( $4,590/house-year )/((918 lb-VOC/yr )(1 ton/2000 lb))

= $10,000/ton of VOC reduced

As shown above, the cost of the activated carbon alone for carbon adsorption would

cause the cost of the VOC reductions to be greater than the $ 5,000 /ton cost effectiveness threshold of the District BACT po licy. Therefore, this option is not cost effective and is being removed from consideration at this time.

Biofiltration:

Biofiltration is a method of reducing pollu tants in which exhaust air that contains

contaminants is blown through a media (e.g., soil, compos t, wood chips) that supports a microbial population. The microbes utilize the pollutants such as VOCs and ammonia as nutrients and oxidize the compounds as they pass through the filter.

The following cost analysis demonstrates that the cost of biof iltration exceeds the

District cost effective threshold. Bio filtration can control both VOC and ammonia emissions. Although, this technology can c ontrol both pollutants, a cost effective

threshold has not been established for ammoni a. Therefore, only achieved-in-practice options will be considered for ammonia at this time and a multi-pollutant cost effective analysis for VOC and ammoni a will not be performed.

Costs

The cost estimate for a biof iltration system is taken from the Univ ersity of Minnesota

Extension Service Biosystems and Agricultural Engineer ing Update “Biofilter Design Information” (March 2004). The cost is largely dependent on the airflow rate that the

filter must handle. The University of Minnesota publicat ion states “ Biofilters used to treat ventilating air exhausted from a livestock bu ilding should be sized to treat the maximum ventilation rate, which is typically the warm weather rate, of the building.” According to the applicant, the broiler house airflow rate can range from 2,700 cfm (new chicks on a cold night) to 212,000 cfm (mature birds on a hot day). The maximum airflow rate for

the house is calculated as follows:

Maximum Airflow Rate

10 fans @ 26,800 cfm = 268,000 cfm 1 fan @ 18,300 cfm = 18,300 cfm 1 fan @ 9,000 cfm = 9,000 cfm Total = 295,300 cfm

As shown above, the maximum airflow rate for each house is about 295,300 cfm. However, for more conservative calculatio ns a maximum airflow rate of 212,000 will be assumed for this cost analysis.

Capital CostB- 17 The cost of the biofilter includes the costs of t he fans, media, ductwork, plenum, and labor. The University of Minnesota publication gives a capital cost between $150 and $250 per 1,000 cfm. An average cost of $200 per 1,000 cfm will be assumed for this cost analysis.

The capital cost of the biofil ter is calculated as follows:

$200/1,000 cfm x 212,000 cfm = $42,400

Pursuant to District Policy APR 1305, secti on X (11/09/99), the cost for the purchase of the biofilter will be spread over the expected lif e of the system using the capital recovery equation. Although, t he biofilter media (e.g., soil, compost, wood chips) must be replaced after 3-5 years, this does not cons titute a significant cost of the system. Therefore, t he expected life of the system ( fans, media, ductwork, plenum , etc) is estimated at 10 years. A 10% interest rate is assumed in the equation and the assumption will be made that the equipment has no salvage value at the end of the tenyear cycle.

A = [P x i(I+1) n ]/[(I+1) n -1]

Where: A = Annual Cost

P = Present Value I = Interest Rate (10%) N = Equipment Life (10 years)

A = [$42,400 x 0.1(1.1) 10 ]/[(1.1) 10 -1] = $6,900/year

VOC Emission Reductions

VOCs controlled = 0.0248 lb-VOC/bir d-year x 33,120 bird/house x 0.80

= 657.1 lb-VOC/house-year

Adjusted to industry standard = 657.1 lb-VOC/house-year x (1/0.85)

= 773 lb-VOC/house-year

Cost of VOC Emission Reductions

Cost of reductions = ( $6,900/house-year )/((773 lb-VOC/yr )(1 ton/2000 lb))

= $17,852/ton of VOC reduced

As shown above, the capital cost alone for a biofilter would cause the cost of the VOC

reductions to be greater than the $ 5,000 /ton cost effectiveness threshold of the District BACT policy. Therefore, this option is not cost effective and is being removed from

consideration at this time.B- 18 The facility is proposing completely enclosed mechanically ventilated broiler housing with evaporative cooling pads, mixing fans , and a computer control system using thermostats, sensors, and time rs to control environmental conditions (e.g. temperature, humidity, ventilation) within the houses. The facility is also proposing to feed all birds in

accordance with National Research Couns el (NRC) or other District-approved guidelines and to remove all mortality from houses twice per day. Since there is not a more effective control option, no fu rther cost analysis is required.

Step 5 - Select BACT

BACT for VOC for this operation is determi ned to be completely enclosed mechanically ventilated broiler housing with evaporativ e cooling pads, mixing fans, and a computer control system using thermostats, sensor s, and timers to control environmental conditions (e.g. temperature, humidity, ventila tion) within the houses; feeding all birds in

accordance with National Research Couns el (NRC) or other District-approved guidelines; and removal of all mort ality from houses twice per day. 25

BACT Analysis for NH 3 Emissions:

Step 1 - Identify All Possible Control Technologies

The control technology options include:

Option 1. Emissions from Broiler House controlled by Carbon Adsorption Option 2. Emissions from Broiler H ouse controlled by Thermal Incineration Option 3. Emissions from Broiler House controlled by Catalytic Incineration Option 4. Emissions from Broiler House cont rolled by a Biofilter capable of achieving

80% control Option 5. Total house cleanout after two flocks (3 times per year) Option 6. Total house cleanout after one flock (6 times per year) Option 7. Animals fed in accordance with National Research Counsel (NRC) or other District accepted guidelines ut ilizing routine nutritional analysis for

rations Option 8. Broiler House Construction and Management Practices 1. Insulated & mechanically ventilated poultry house + 2. Mortality removed twice per day + 3. Evaporative cooling pads to regulate house temperature + 4. Mixing Fans

Step 2 – Eliminate Options

Option 1 (Emissions from Broiler House c ontrolled by Carbon Adsorption) will be

eliminated from cons ideration at this time. Although this option is technologically feasible, no uses of carbon adsorption to control broiler house ammonia emissions were

identified. Since a cost effective threshold has not been established for ammonia, only achieved-in-practice options will be c onsidered for ammonia at this time.

25 Total control efficiency of management practices and feeding with NRC guidelines=1-[(1-0.15) x (1-0.09)] =22.7%B- 19 Option 2 (Emissions from Broiler House cont rolled by Thermal In cineration) and Option 3 (Emissions from Broiler House controlled by Catalytic Incineration) will be eliminated from consideration at this time. Although t hese options are technologically feasible, no uses of thermal or catalytic incineration to control broiler house ammonia emissions

were identified. Since a cost effective threshold has not been established for ammonia, only achieved-in-practice options will be consi dered for ammonia at th is time. It should

also be noted that incineration is an oxidatio n process. The most likely by product of

the oxidation of ammonia would be NO X . The following equation demonstrates the likely reaction:

NH 3 + 2.5O 2 

### → NO 2 + 3H 2 O

The molecular weights of NH 3 and NO 2 are 17 and 46, respectively; therefore, for every pound of ammonia elimi nated 2.7 pounds of NO X (a precursor for ozone, and according to modeling results, a more significant precursor of PM 10 and PM 2.5 than NH 3 ) could be generated. This is an additional reason to eliminate incineration as a control for

ammonia.

Option 4 (Emissions from Broiler House contro lled by a Biofilter) wi ll be eliminated from

consideration at this time. Biofiltration is wi dely used to control emissions from enclosed buildings where pigs are raised and have be en used in Minnesota to control emissions from enclosed cow housing area s and composting facilities. At West Virginia University in 2003, a bench scale biofilter for 33 birds was evaluated for removal of ammonia from poultry house exhaust. The biofilter prov ided 95% control of ammonia emissions. 26
However, biofilters have not yet been used for poultry facilities on a large scale and although this option is technologic ally feasible, no uses of bi ofiltration to control broiler

house ammonia emissions were identified. Since a cost effective threshold has not been established for ammonia, only achieved-i n-practice options will be considered for

ammonia at this time.

Option 5 (Total house cleanout after two flo cks (3 times per year)) and Option 6 (Total cleanout after one flock) will be eliminated from consider ation at this time. Although more frequent removal of litter from the bro iler houses would result in less emissions from the house, it is likely that these emissions would mere ly be shifted to litter storage areas. Unless the litter storage areas were controlled, there would be no emission reductions. Additionally, one of the major reasons for regulating ammonia is that it is a precursor for PM 10 and PM 2.5 . As a particulate matter contro l, the facility’s Conservation Management Practice (CMP) plan requires that the litter be used for at least two flocks. More frequent cleanouts would caus e a greater amount of direct PM 10 emissions to the atmosphere.

Step 3 – Rank Remaining Control Tech nologies by Control Effectiveness

26 http://www.ncbi.nlm.nih.gov/entrez/query.fcgi?cmd =Retrieve&db=PubMed&list_uids=12602826&dopt=AbstractB- 20 Control technologies for NH 3 :

Acidifying Litter Amendments

The ammonia emission reductions caus ed by the usage of acidifying litter amendments are usually reported in term s ppmv inside the broiler house. Although these litter amendments have consistently shown significant reductions in ppmv levels in the house (50% reductions in av erage ppmv level over the grow-out period), it may not be possible to directly correla te these reductions to pounds of ammonia

emitted since the house ventila tion rate constantly changes.

Arkansas research has shown that alum application rates of 130-260 lb per ton of

litter reduced ammonia-N emissions from 28 lb per ton of litter to less than 1 lb per ton of litter over the grow- out period (96.4% control). 27 However, this may be the result of an atypica lly high application rate. 26

Brewer (1988) estimated that the total nitr ogen release over the gr ow-out period from a poultry house with 20,000 broilers was 296 kg (as NH 3 ) for an untreated house and 131 kg (as NH 3 ) for an alum-treated house (55.7% contro l). It is estimated that there are about 6.7 grow-out cycles per year (used to develop CA RB emission factor). The resulting emission factor for an alum-t reated house is calculated as follows:

(131 kg-NH 3 /growout-house) x (2.2 lb/kg) x (6 .7 growout/year) ÷ (20,000 bird/house)

= 0.0965 lb-NH 3 /bird-year

Moore states that a typica l poultry house will lose about two tons of nitrogen each year as ammonia but an alum-treated house will only lose about 1,000 lb of nitrogen as ammonia (75% control). 28 The resulting emission factor for an alum-treated house

is calculated as follows:

(1,000 lb-NH 3 /house-year) ÷ (20,000 bird/house) = 0.05 lb-NH 3 /bird-year

Mcward and Taylor found similar ammoni a emission reductions when comparing acidic, granular litter amendments such as sodium bisulfate, alum, and Poultry

Guard. 29

The emission reductions for acidifying litter amendments will be conservatively

estimated at 0.0965 lb-NH 3 /bird-year and 50% control

Broiler House Construction and Foster Farms Management Practice

27 Alabama Cooperative Extension, Agronomy Series – Alum in Poultry Litter (May, 2005)

28 U.S. Water News Online – Aluminum Sulfate found to re duce ammonia, phosphorus in Poultry litter (February 2002)

29 McWard, G. W. and D. R. Taylor, Acidified Clay Litter Amendment, Journal of Applied Poultry Research (2000)B- 21 The California Air Resources Board (CARB) has performed a source test on the Foster Farms Broiler operation that resulted in an ammonia emission factor of 0.0958 lbNH 3 /bird-year. This emission factor falls wi thin the range of emission factor estimates when acidifying litter amendments are used. Therefore, the two options will be considered equivalent.

NH 3 Emission Control Technology Rankings

Rank Control Efficiency Status

3) Acidifying Litter Amendments 50% Achieved in Practice 4) Broiler House Construction and Foster Farms Management Practices 50% Achieved in Practice

5) Animals fed in accordance with National Research Counsel (NRC) or other District accepted guidelines utilizing routine nutritional analysis for rations 17% 30 Achieved in Practice

Step 4 - Cost Effectiveness Analysis

All of the above options are achieved-in-pract ice; therefore a co st analysis is not required.

The facility is proposing completely enclosed mechanically ventilated broiler housing with evaporative cooling pads, mixing fans , and a computer control system using thermostats, sensors, and time rs to control environmental conditions (e.g. temperature, humidity, ventilation) within the houses. The facility is also proposing to feed all birds in

accordance with National Research Couns el (NRC) or other District-approved guidelines and to remove all mortality from houses twice per day. Since there is not a more effective control option, no fu rther cost analysis is required.

Step 5 - Select BACT

BACT for NH 3 for this operation is determined to be completely enclosed mechanically ventilated broiler housing with evaporativ e cooling pads, mixing fans, and a computer control system using thermostats, sensor s, and timers to control environmental conditions (e.g. temperature, humidity, ventila tion) within the houses; feeding all birds in

accordance with National Research Couns el (NRC) or other District-approved guidelines; and removal of all mort ality from houses twice per day. 31

30 Assuming that nitrogen excretion, which leads to ammonia volatization, can be reduced by 15% by feeding with NRC guidelines

31 Total control efficiency of management practices and feeding with NRC guidelines=1-[(1-0.50) x (1-0.17)] =58.5%

### San Joaquin Valley Unified Air Pollution Control District

Best Available Control Tec hnology (BACT) Guideline X-XX *

Emission Unit: Broiler House Equipment Rating: 33,120 birds/house Industry Type: Agriculture (poultry)

Determination Date:

Pollutant Achieved in Practice or contained in
SIP Technologically

Feasible Alternate

Basic Equipment

VOC 1. 22.7% control ( completely enclosed mechanically ventilated broiler housing with evaporative cooling pads, mixing fans, and a computer control system using thermostats, sensors, and timers to control environmental conditions; all birds fed in accordance with NRC or other District-approved guidelines; and all mortality removed from houses twice
per day )

2. 22.7% control ( acidifying litter amendments; all birds fed in accordance with NRC or other District-approved guidelines; and all mortality removed from houses twice per day ) 1. 98% control (Capture

and Thermal Incineration)

2. 95% control (Capture and Catalytic Incineration)

3. 95% control (Capture

and Carbon Adsorption)

4. 80% control (Capture and Biofiltration)

NH 3 1. 58.5% control ( completely enclosed mechanically ventilated broiler housing with evaporative cooling pads, mixing fans, and a computer control system using thermostats, sensors, and timers to control environmental conditions; all birds fed in accordance with NRC or other District-approved guidelines; and all mortality removed from houses twice per day )

2. 58.5% control ( acidifying litter amendments; all birds fed in accordance with NRC or other District-approved guidelines; and all mortality removed from houses twice per day ) 1. 80% control (Capture and Biofiltration)

BACT is the most stringent control technique for the emissions unit and class of source. Control techniques that are not achieved in practice or c ontained in a state implem entation plan must be cost effective as well as feasible. Economic analysis to demonstrate cost effectiveness is required for all determinations that are not achieved in practice or contained in an EPA appr oved State Implementation

Plan.

*This is a Summary Page for this Class of Sour ce - Permit Specific BACT Determinations on Next Page(s)DRAFT X-XX 3 rd Qtr. '05



### San Joaquin Valley

Unified Air Pollution Control District

Best Available Control Technol ogy (BACT) Guideline X-XXA

Emission Unit: Broiler House

Facility: Foster Farms, El Dorado Ranch

Location: 1324 South El Dorado Ave. Tranquility, CA. Equipment Rating: 250 ton-onion/day

References: ATC #: C-5439-1-1 Project #: C-1051505

Date of Determination:

Pollutant BACT Requirements

NO X
SO X

PM 10

CO

VOC 22.7% control ( completely enclosed mechanically ventilated broiler housing with evaporative cooling pads, mixing fans, and a computer control system using thermostats, sensors, and time rs to control environmental conditions; all birds fed in accordance with NRC or other District-appro ved guidelines; and all mortality removed from houses twice per day )
(Achieved in Practice)

NH 3 58.5% control ( completely enclosed mechanically ventilated broiler housing with evaporative cooling pads, mixing fans, and a computer control system using thermostats, sensors, and time rs to control environmental conditions; all birds fed in accordance with NRC or other District-appro ved guidelines; and all mortality removed from houses twice per day )

(Achieved in Practice)

BACT Status: X Achieved in practice Small Emitter T-BACT Technologically feasible BACT

At the time of this deter mination achieved in practice BACT was equivalent to technologically feasible BACT Contained in EPA approved SIP The following technologically feasible options were not cost effective: Alternate Basic Equipment The following alternate basic equipm ent was not cost effective:

3 rd Qtr. '05 X-XXA DRAFTMail to: CAPCOA BACT Clearinghouse Project

Assessment Branch

P.O. Box 2815 Sacramento, CA 95812 For CAPCOA use only Record No.: ;Form No.: ;BLIS District Code: Codes - EPA Source: ;SCAQMD: ;EPA ID No.: ARB Sc: ,Ctrl: ;BLIS Proc ess: ;AIRS Facility No.:

CAPCOA BACT DETERMINATION REPORTING FORM

Instructions: Complete this form when issuing an authorit y to construct. Please use on form per determination (i.e. pollutant). Please use one form per determination (i.e. pollutant) Section A need only be completed on one form in the case of a source with multipl e determinations. See the reverse side for descriptions of the fiel d identifiers used below. Please attach a copy of the permi t or permit conditions if practical. Please call (916)327- 5601 for clarification of any questions. (1/5/94)

SECTION A. Source Information

Company and Project Name: Harris Fresh, LLC

Facility Address: PO Box 497 21960 S. Fresno-Coalinga Hwy. SIC Code: 723 Coalinga, CA 93210 Authority to Authority to Application No.: C-1044198 ; Construct No.: C-6188-1-0 Construct Issue Date: June ?, 2005

District: SJVUAPCD ; District Contact: David Warner; Phone No.: (559) 230-5900

Est. Startup Date: June 2005 ; Today's Date: June 1, 2005 Permit Unit Status: New

Basic Equip./Process (include make and model): Fresh Onion grading and packing

Rated Capacity: 250 ton-onion/day ; Output: N/A ; SCC Code:

Fuel Type: n/a ; Backup Fuel(s): N/A ; Project Cost: $

SECTION B. Control Data Pollutant: PM10

Control Equip. none

Emissions: Uncontrolled: 150 lbm/day Controlled Limit: 4.5 lbm/day

Enforceable Permit Emissions Limit(s): 250 ton-onion/ day, 0.018 lb-PM10/ton

Emission Type: point; Cost of Control E quipment: $5,000 for filter assembly

Regulatory Requirement: District-Defined BACT Distri ct-Defined LAER Other: N/A

BACT/LAER Specification: Reference or Basis: SJVUAPCD

Mass Emission Rate: ; Destruction efficiency (%): N/A

Normalized Mass Emission Rate: N/A lbm/MMBtu; N/A g/bhp-hr; 0.018 lbm per ton input

Emission Concentration: 0.005 gr/dscf at 9,240 scfm

Other: N/A

Method of Compliance Verification: recordkeeping

Other Relevant Permit Limits: Time of Operation: N/A

Fuel use: N/A Percent Capacity/Use: Seasonal Throughput: N/A

Other: N/A

Remarks:San Joaquin Valley Unified Air Polluti on Control District April 16, 2009



## APPENDIX A Foster Farms Management PracticesSan Joaquin Valley Unified Air Polluti on Control District April 16, 2009



## APPENDIX B Chemistry of Some Commercially Available Litter Amendments