5e° S7%

— UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX

I 75 Hawthorne Street

San Francisco, CA 94105

June 4, 2014

Mr. Errol Villegas

Planning Manager

San Joaquin Valley Air Pollution Control District

1990 E. Gettysburg Ave.

Fresno, CA 93726

Re: 2014 Reasonably Available Control Technology (RACT) Demonstration for the 8-Hour Ozone

State Implementation Plan (SIP) — May 12, 2014 draft

Dear Mr. Villegas:

Thank you for the opportunity to comment on SJVAPCD’s draft 2014 RACT SIP demonstration for the

2008 8-hour ozone standard. We appreciate the District’s efforts to update its evaluation ofRACT rules,

and we recognize that many of SJVAPCD’s requirements represent innovative control measures and that

EPA approved SJVAPCD’s 2009 RACT SIP demonstration in 2012. The 2014 RACT SIP

demonstration does not appear, however, to adequately address VOC emission sources subject to ozone

RACT under Clean Air Act section 182(b)(2). According to section 2.2 of the staffreport, “...the

District’s VOC rules will not be evaluated as part of this 2014 RACT SIP, each regulation was evaluated

in depth for the 2009 RACT SIP.” We recognize that EPA’s June 6, 2013 proposed rule for

implementation of the 2008 National Ambient Air Quality Standards for Ozone requested comment on a

more flexible approach to RACT for VOC sources in certain areas (78 FR 34178, 34193), but this

approach is not final and provides no basis for concluding summarily that VOC RACT determinations

for a prior ozone standard suffice for the 2008 ozone standard. Under CAA section 1 82(b)(2),

California remains obligated to demonstrate that both VOC and NOx emission sources in the Valley are

subject to SIP-approved requirements that represent current RACT for the 2008 8-hour ozone standard.

In developing an analysis of RACT for VOC and NOx sources for the 2008 8-hour ozone standard, the

District may rely as appropriate on the analyses contained in its 2013 Planfor the Revoked 1-Hour

Ozone Standard, provided it updates these analyses to account for more recent technical information —

e.g., source category-specific information in the BACT/LAER Clearinghouse and in the “Menu of

Control Measures” for CTG sources and major non-CTG sources. We have also enclosed comments on

a few specific rules, including where we are aware of new information since the 2009 RACT SIP that

may justify updating previous RACT determinations.

Please feel free to contact me (415-947-4115) or Stanley Tong (415-947-4122), if you would like to

discuss these issues further.

Sincerely,

Andrew Steckel,

Chief, Rules Office
NOx Rules

4103 Open Burning

We recommend updating the RACT SIP evaluation ofthis category to, at a minimum, include citation to

the District’s October 12, 2012 letter: Update on SJV Citrus Orchard Material Burning Restrictions

which cites to a May 2012 reevaluation ofthe economic feasibility of alternatives to burning —2012

Update: Recommendations on Agricultural Burning. In addition, in 2015 as committed to in the

District’s 2012 PM 2.5 Plan and required under Rule 4103 Sections 6.3 and 5.5.2, we anticipate the

District will continue to monitor this emissions source and will conduct a comprehensive re-evaluation

ofthe technical and economic feasibility of burn alternatives for each ofthe remaining categories of

agricultural waste for which open burning prohibition under California Health and Safety Code Section

41855.5 has been postponed.

4311 Flares

The District’s 2013 Plan for the Revoked 1-Hour Ozone Standard’ committed to evaluate the submitted

Flare Management Plans (FMP) and flare reports by the end of 2013. EPA has not seen the results of

the evaluation. The RACT SIP should discuss the results ofthe evaluation. EPA’s 2011 approval of Rule

4311 also listed several recommendations found in the Bay Area and South Coast flare rules. The

District should reconsider these recommendations after reviewing the submitted FMPs and flare reports.

4702 Internal Combustion Engines

We recognize that controls required by Rule 4702 significantly reduce NOx emissions from

uncontrolled agriculture engines. We believe the RACT SIP can be further improved by addressing the

following.

For rich burn (<4% 02 in exhaust) agricultural engines, the current limit which has a compliance date of

2009, is 90 ppm or 80% reduction. According to the staffreport 2for the June 16, 2005 version ofthe

rule submitted to EPA on October 20, 2005, the likely emission control technology for the existing limit

is pre-stratified charge controls. These are the same controls predicted to be used on waste gas fueled

units which have a lower emission limit. The District should explain why lower limits are not feasible.

For lean burn (>4% 02 in exhaust) agricultural engines, the current limit is 150 ppm or 70% reduction.

According to the staffreport 3for the June 16, 2005 version ofthe rule submitted to EPA on October 20,

2005, likely emission control technology for the existing limit is retrofitting with low-emission

combustion controls, ignition system modification or engine de-rating. These are the same controls

predicted to be used four-stroke spark-ignited lean burn engines and two-stroke spark-ignited engines

rated at 100 bhp or above which have a lower emission limit. The District should explain why lower

limits are not feasible.

1 http://wwwva1levairori/Air Quality Pians/OzoneOneHourPlan20 I 3/O3Chapter3ControiStrategyO8 1613 pdf 2 Information obtained from page 14 ofthe Final Staff Report for the June 16, 2005 version ofthe rule submitted to EPA on

10/20/05.

Information obtained from page 14 ofthe Final Staff Report for the June 16, 2005 version ofthe rule submitted to EPA on

10/20/05.
VOC rules

4402 Crude Oil Production Sumps

Our 2012 approval of the 2011 amendments recommended the District perform a more current inventory

(including parameters such as numbers, size, VOC content, and operator production rates) of oil

production ponds, sumps, and pits to determine ifthe current exemption thresholds for sumps with

specific size surface areas are appropriate. Some of this information may already be available in records

required for exemptions (Rule 4402 Section 6.1). We are interested in the District’s results ifsuch a

survey was completed after the rule was amended in 2011.

4566 Organic Material Composting Operations

The research report 4on solar-powered aeration and biofilter concluded it could be a viable method for

commercial-scale composting, reducing 98% reduction of non-methane, non-ethane organic compounds.

We encourage the District to describe in the RACT SIP any additional work to further develop the

project into commercial use, best management practices and/or RACT level controls in the future.

4624 Transfer of Organic Liquid

Rule 4624 specifies that organic liquid transfers 20,000 gallons per day shall not exceed 0.08 pounds

VOC per 1,000 gallons. Bay Area AQMD Rule 8-33 para 301.2 (amended 4/15/2009) specifies that

effective 1/10/2011, emissions of non-methane organic compounds from a vapor recovery system shall

not exceed 0.04 pounds per 1,000 gallons of organic liquid loaded for gasoline bulk terminals. The Bay

Area AQMD is designated as marginal non-attainment for the 2008 8-hour ozone standard. The District

should evaluate adoption of the Bay Area limit in its RACT SIP.

4653 Adhesives and Sealants

Our 2012 approval of the 2010 rule recommended the District reduce certain limits for adhesives which

are 2-3 times higher than those in South Coast Rule 1168 amended in 2005. We note that the South

Coast AQMD currently has a workgroup and preliminary draft rule to explore further reductions to the

VOC limits for adhesives and sealants.

5636—AQP/C— I 5636 ACP Final ReporLpf