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— 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 forthe opportunity to comment on SJVAPCD’s draft 2014 RACT SIP demonstration forthe 2008 8-hour ozone standard. We appreciate the District’s efforts to update its evaluation ofRACT rules, and we recognize that many ofSJVAPCD’ 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 AirAct section 182(b)(2). According to section 2.2 ofthe staffreport, “...the District’s VOC rules will notbe evaluated as part ofthis 2014 RACTSIP, each regulation was evaluated in depth forthe 2009 RACTSIP.” We recognize that EPA’s June 6, 2013 proposed rule for implementation ofthe 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 aprior ozone standard suffice for the 2008 ozone standard. Under CAA section 1 82(b)(2), Californiaremains obligated to demonstrate thatboth VOC andNOx emission sources in the Valley are subjectto SIP-approved requirements thatrepresent current RACT forthe 2008 8-hour ozone standard.

In developing an analysis ofRACT for VOC andNOx sources forthe 2008 8-hour ozone standard, the Districtmay rely as appropriate on the analyses contained in its 2013 Planforthe Revoked 1-Hour Ozone Standard, provided itupdates these analyses to account for more recenttechnical information

— e.g., source category-specific information in the BACT/LAERClearinghouse and in the “Menu of Control Measures” for CTG sources and majornon-CTG sources. We have also enclosed comments on a few specific rules, including where we are aware ofnew information since the 2009 RACT SIP that mayjustify updating previous RACT determinations.

Please feel free to contact me (415-947-4115) or Stanley Tong (415-947-4122), ifyou would like to discuss these issues further. Sincerely,

Andrew Steckel, Chief, Rules OfficeNOx Rules

4103 Open Burning We recommendupdating the RACT SIP evaluation ofthis category to, at a minimum, include citation to the District’s October 12, 2012 letter: Update on SJVCitrus OrchardMaterialBurning Restrictions which cites to a May 2012 reevaluation ofthe economic feasibility ofalternatives to burning —2012 Update: Recommendations onAgricultural Burning. In addition, in 2015 as committed to in the District’s 2012 PM 2.5 Plan and requiredunder Rule 4103 Sections 6.3 and 5.5.2, we anticipate the Districtwill continue to monitor this emissions source and will conduct a comprehensive re-evaluation ofthe technical and economic feasibility ofburn alternatives for each ofthe remaining categories of agricultural waste for which open burning prohibition under CaliforniaHealth and Safety Code Section 41855.5 has beenpostponed.

4311 Flares The District’s 2013 Plan forthe Revoked 1-Hour Ozone Standard’ committedto evaluate the submitted Flare Management Plans (FMP) and flare reports by the end of2013. EPA has not seenthe results of the evaluation. The RACT SIP should discuss the results ofthe evaluation. EPA’s 2011 approval ofRule 4311 also listed several recommendations found in the Bay Area and South Coast flare rules. The District should reconsiderthese recommendations afterreviewing 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 improvedby addressing the following.

Forrich burn (<4% 02 in exhaust) agricultural engines, the current limit whichhas a compliance date of 2009, is 90 ppm or 80% reduction. According to the staffreport 2 forthe June 16, 2005 version ofthe rule submitted to EPA on October 20, 2005, the likely emission control technology forthe 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 3 forthe June 16, 2005 version ofthe rule submitted to EPA on October 20, 2005, likely emission control technology forthe existing limit is retrofitting with low-emission combustion controls, ignition system modification or engine de-rating. These are the same controls predictedto 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/OzoneOneHourPlan20I 3/O3Chapter3ControiStrategyO81613 pdf 2 Information obtained from page 14 ofthe Final StaffReport forthe June 16, 2005 version ofthe rule submitted to EPA on 10/20/05. Information obtained from page 14 ofthe Final StaffReport forthe June 16, 2005 version ofthe rule submitted to EPA on 10/20/05.VOC rules

4402 Crude Oil Production Sumps Our 2012 approval ofthe 2011 amendments recommended the Districtperform amore current inventory (including parameters such as numbers, size, VOC content, and operatorproduction rates) ofoil productionponds, sumps, and pits to determine ifthe current exemptionthresholds for sumps with specific size surface areas are appropriate. Some ofthis 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 researchreport 4 on solar-powered aeration and biofilter concluded it could be aviable method for commercial-scale composting, reducing 98% reduction ofnon-methane, non-ethane organic compounds. We encourage the Districtto describe in the RACT SIP any additional workto further develop the project into commercial use, best managementpractices and/orRACT level controls in the future.

4624 Transfer ofOrganic 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 AreaAQMD Rule 8-33 para 301.2 (amended 4/15/2009) specifies that effective 1/10/2011, emissions ofnon-methane organic compounds from a vaporrecovery system shall not exceed 0.04 pounds per 1,000 gallons oforganic liquid loaded for gasoline bulk terminals. The Bay Area AQMD is designated as marginal non-attainment forthe 2008 8-hour ozone standard. The District should evaluate adoption ofthe Bay Area limit in its RACT SIP.

4653 Adhesives and Sealants Our 2012 approval ofthe 2010 rule recommended the Districtreduce certain limits for adhesives which
are 2-3 times higher than those in South Coast Rule 1168 amended in 2005. We note thatthe South Coast AQMD currently has a workgroup and preliminary draftrule to explore furtherreductions to the VOC limits for adhesives and sealants.

5636—AQP/C—I5636 ACP FinalReporLpf