# State of California

Staff Review

of the



# Supplemental Document for the San Joaquin 24

- Hour PM2.5 Standard State Implementation Plan

Release Date: September 22, 2014

Scheduled for Consideration: October 24, 2014 California Environmental Protection Agency



# AIR RESOURCES BOARDThis document has been reviewed by the staff of the California Air Resources Board and approved for publication. Approval does not signify that the contents necessarily reflect the views and policies of the Air Resources Board, nor does the mention of trade names or commercial products constitute endorsement or recommendation for use.

Electronic copies from this document are available for download from the Air Resources Board’s Internet site at: http://www.arb.ca.gov/planning/sip/planarea/sanjqnvllysip.htm

. In addition, written copies may be obtained from the Public Information Office, Air Resources Board, 1001 I Street, 1 st Floor, Visitors and Environmental Services Center, Sacramento, California 95814, (916) 322

- 2990.

For individuals with sensory disabilities, this document is available in Braille, large print, audiocassette or computer disk. Please contact ARB's Disabili ty Coordinator at (916) 323

- 4916 by voice or through the California Relay Services at 711, to place your request for disability services. If you are a person with limited English and would like to request interpreter services, please contact ARB's Bilingu al Manager at (916) 323

- 7053.

1Supplemental Document for the San Joaquin Valley

24

- hour PM2.5 Standard State Implementation Plan

This Report document s the Air Resources Board staff’s review of t he Supplemental Document: Clean Air Act Subpart 4: The 2012 PM2.5 Plan for the 2006 PM2.5 Standard and District Rule 2201 (New and Modified Stationary Source Review) (Supplement al
Document ) adopted by the San Joaquin Valley Air Pollut ion Control District (District). The Supplemental Document demonstrates compliance with the requirements under Subpart 4 of the Clean Air Act (Act) for the 24

- hour PM2.5 standard and provides the information U.S. Environmental Protection Agency (U.S. EPA) needs to approve the San Joaquin Valley 24

- hour PM2.5 SIP under Subpart 4 of the Act.

I. BACKGROUND

In December 2012, the District adopted a S tate Implementation Plan (S IP ) for the
35 μg/m 3 24

- hour PM2.5 standard ( 2012 PM2.5 Plan 1 ) . The 2012 PM2.5 Plan was
develo ped to meet re quirements of the U.S. EPA 2007 Fine Particle Implementation
Rule 2 (2007 Implementation Rule) based on Subpart 1 provisions of the Act

. In January 2013, the Air Resources Board (ARB or Board ) approved 3 the 2012 PM2.5
Plan

.

In the time between the 2012 PM2.5 Plan adoption by the District in December 2012 and the ARB hearing in January 2013 , the D.C. Circuit Court determined that U.S. EPA erred in solely developing its implementation rule for PM2.5 under the Subpart 1 general provisions of the Act without considering the more specific particulate matter pr ovisions in Subpart 4 . The Court remanded the rule back to U.S. EPA to address the Subpart 4 provisions

. During the January 2013 ARB hearing, the Board determined that it was appropriate to appro ve the 2012 PM2.5 Plan at that time and provide any necessary supplemental information once U.S. EPA provided guidance in response to the D.C. Circuit Court decision

.

In accordance with Subpart 4 provisions of the Act , in June 2014, U.S. EPA classified
the San Joaquin Valley (SJV) as a moderate nonattainment area 4 for the 35 μg/m 3

1 SJVUAPCD, 2012 PM2.5 Plan. http://www.valleyair.org/Air_Quality_Plans/PM25Plans2012.htm

2 U.S. EPA, Clean Air Fine Particle Implementation Rule; Final Rule. (20586

– 20667) April 25, 2007. http://www.epa.gov/fedrgstr/EPA

- AIR/2007/April/Day

- 25/a6347.pdf
3 ARB, San Joaquin Valley PM2.5 State Implementation Plan, Resolution 13

- 2 (January 21, 2013) http://www.arb.c a.gov/planning/sip/sjvpm25/FIN%20RESO%2013

- 2.pdf
4 U.S. EPA, Identification of Nonattainment Classification and Deadlines for Submission of State Implementation Plan Provisions for the 1997 Fine Particle (PM2.5) National Ambient Air Quality Standard (NAAQS ) and 2006 PM2.5 NAAQS, 79 FR 105, pp. 31566

- 31782 (June 2, 2014) http://www.gpo.gov/fdsys/pkg/FR

- 2014

- 06

- 02/pdf/2014

- 10395.pdf

224

- hour PM2.5 standard and directed the State to submit a SIP by the end of 2014 that meets the moderate area requirements. U.S. EPA directed states to use existing guidance f or PM10 implementation under Subpart 4 and apply the guidance to the
PM2.5 standard.

On Sep tember 18, 2014, the District adopted the Supplement al Document 5 . The Supplemental Document demonstrates that the existing 2012 PM2.5 Plan satisfie s Subpart 4 requirements for a moderate PM2.5 nonattainment area. T he Supplemental
Document also includes the District’s req uest that the S J V be classified as a serious PM2.5 nonattainment area under Subpart 4 consistent with the attainment
demonstration in the 2012 PM2.5 Plan

.

II. ADOPTED 2012 PM2.5 PLAN MEETS SUBPART 4 REQUIR E MENTS

The Supplemental Document includes a detailed comparison of PM 2.5 implementation requirements under Subpart 1 and Subpart 4. These requirements are summarized in Table 1. Focusing on the requirements that differ between S ubparts 4 and 1 , the Supplemental Document show s how the 2012 PM2.5 Plan adopted by ARB and the
District also satisfies the S ubpart 4 requirements.

• Attainment Date: Under Subpart 1, a non

- attainment area has an attainment date
of five years from the nonattainment designation, which is 2014, and up to 2019 if
earlier attainment is not practicable. In contrast, per the area classification requirements of Subpart 4, the moderate area attainment date is six years after designation or 2015

, and the serious attainment date is four years later or 2019.

The photochemical modeling and other technical analyses i n the 2012 PM2.5 Plan
demonstrated that 2019 is the most expedi tious date for reaching attainment throughout the SJV

. This mod eling was conducted c o nsistent with U.S EPA guidance. T he 2012 PM2.5 Plan attainment strategy includes emission reductions, to occur each year through 2019, from implementing a combination of ARB and District programs including reductions from the State mobile source program. The
District actions include further strengthening of its wood burning curtailment program and additional requirements on commercial cooking operations, to bring the entire SJV into attainment by 2019.

5 SJVAPCD, Supplemental Document: Clean Air Act Subpart 4: The 2012 PM2.5 Plan for the 2006 PM2.5 Standard and District Rule 2201 (New and Modified Stationary Source Review). September 18, 2014 http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2014/September/final/06.pdf

3Table 1. Subpart 1 and Subpart 4 Comparison of 35 ug/m3 24

- hour PM2.5 Standard Impleme ntation

SIP Component Subpart 1 Subpart 4

Classifications None Moderate Area Serious Area Attainment Dates • Five years from designation date ( December 2014)

• May be extended to up to ten years from designation date (December 2019) Moderate Area :

• By the end of the sixth year after designation (December 2015) Serious Area :

• By the end of the tenth year after designation ( December 2019)

• May extend up to five years (December 2024) SIP Submission Deadlines Three years after designation (December 2012) Moderate Area :

• 18 months after designation ( December 31, 2014) Serious Area :

• 18 months after r eclassification

Precursor Requirements • M ust address sources of directly emitted PM2.5, SOx, and NOx.

• A ddress ammonia or VOC if they significantly contribute to PM2.5 levels in the area. M ust address sources of all PM2.5 and PM2.5 precursors

.

Level of Emission Controls Reasonably Available Control Measures (RACM ) • Moderate Area: RACM

• Serious Area: Best Available Control Measures Reasonable Further Progress L inear progress towards attainment Quantitative milestones to be achieved every 3 years

Permitting Program Major Sources n ot required to control ammonia or VOC , unless de monstrated that they contribute significantly to PM 2.5 concentrations in the area.

Major source is over 100 tons per year (tpy). Major Sources m ust control all precursors of PM2.5, unles s demonstrated that such precursors do not contribute to levels which exceed the standard.

Moderate Area : Major source is over 100 tpy

. S erious Area : Major source is over 70 tpy

.

4U.S. EPA can re classify SJV from moderate to serious if it determine s that SJV cannot practicably attain by 2015 based on the attainment analysis in the 2012
PM2.5 Plan

. C lassify ing SJV as a serious area will maintain the current attainment date as implementation of the 2012 PM2.5 Plan moves from Subpart 1 to Subpart 4

.

• Precursors Requirements : Under S ubpart 1, only directly emitted PM2.5, sulfur oxides (SOx)

, and nitrogen oxides (NOx) were presumed significant plan precursors.
U nder Subpart 4 , states must address all precursors including ammonia and volatile organic compounds ( VOC )

. However, states may make a demonstration that a precursor is not significant if a significant reduction in emissions does not result in a significant decrease in PM2.5 concentrations.

T he role of ammonia and VOC in SJV PM2.5 concentrations is discussed in the
2012 PM2.5 Plan and summarized in the Supplemental Document. Based on the large body of published scientific evidence from research conducted through the
extensive California Regional Particulate Matter Air Quality Study (CRPAQS) and subsequent data analysis and modeling studies, as well as photochemical modeling conducted in support of the 2012 PM2.5 Plan, reductions in either ammonia or VOC would not significantly advance PM2.5 attainment in the Valley

.

In developing the 2012 PM2.5 Plan, a number of studies and analyses based on CRPA Q S were evaluated to understand the role of ammonia in the SJV. Measurements of chemically speciated PM2.5 show that ammonium nitrate (formed in the air from reactions of ammonia and NOx emissions) is a major component of
PM2.5. A mbient measurements of ammonia, nitric acid, and particulate ammonium
nitrate d emonstrate , however that due to the excess of ammonia relative to nitric acid (formed from NOx emissions) throughout the SJV, the amount of NOx
emissions limit the formation of ammonium nitrate.

The 2012 PM2.5 Plan also evaluated studies to understand the role of VOC in secondary organic aerosol and amm onium nitrate formation

, including a number of photochemical modeling exercises using CRPAQS data . These studies show secondary organic aerosols derived from anthropogenic VOC emissions acc ount for a very small po rtion of PM2.5 and indicate that in the SJV, NOx, rather than VOC, is the limiting precursor for nitric acid, and subsequent ammonium nitrate formation.

I n addition to these studies , photochemical modeling sensitivity analysis was also conducted as part of the 2012 PM2.5 Plan to determine the relative effectiveness of
emission reductions in PM2.5, NOx, SOx, ammonia , and VOCs

. This modeling
demonstrated i n the Bakersfield area, which measures the highest PM2.5 levels in

5the SJV, NOx and PM2.5 reductions are 10 and 40 times more effective tha n ammonia reductions on a per ton basis. The modeling also indicates that VOC
reductions have no benefit and may in some case cause a very slight increase in
PM2.5 concentrations

.

Accordingly, the 2012 PM2.5 Plan appropriately includes directly e mitted PM2.5, SOx and NOx as the significant PM2.5 precursors to control consistent with Su bpart 4 requirements.

• Reasonably Avai lable Control Measures (RACM): Under Subpart 1 and Subpart 4 for moderate areas, RACM is the required minimum control level. Per Subpart 4, RACM must be in place within four years of an ar ea’s nonattainment designation. The 2012 PM2.5 Plan includes a thorough analysis focused on PM2.5, NOx, and SOx of reasonably available measures adopted by the District and ARB
over emission sources operating in the SJV . ARB has adopted the most stringent
control measures in the nation for on

- road and off

- road mobile sources and the fuels that p ower them . The 2012 PM2.5 Plan RACM analysis compares District rules for
all stat ionary and area source with other rules in the country for those sources. The RACM analysis shows that the District is implementing RACM for stationary and

area sources , and many of the adopted rules go beyond RACM. If U.S. EPA classifies the SJV as a serious nonattainment area, the required control level will become best available control measures (BACM) and a subsequent BACM analysis and SIP submittal will be needed

.

• Reasonable Further Progress (RFP) : U nder S ubpart 1, the Plan must demonstrate generally linear progress to meet RFP requirements

. Under Subpart 4,
the Plan must include quantitative milestones to be achieved every three years until the area is redesigna ted to attainment and which demonstrate RFP

. T he 2012
PM2.5 Plan identifies RFP emission level milestones for 2014 and 2017 that show generally linear progress in emission reductio ns towards attainment in 2019. The se milestones in the 2012 PM2.5 Plan meet the requirements for q uantitative
milestones required under S ubpart 4.

• Contingency Requirements : Per Subpart 1, c ontingency measures provide
additional emission reductions in the event a nonattainment area fails to achieve either RFP targets or attain the PM2.5 st andard by its attainment date. These contingency measures are to take effect without any further ARB or District regulatory action. The Supplemental Document demonstrates that a larger amount
of emission reductions from ARB and Distric t regulations are being achieved than
those needed to meet RFP

. This difference in emission reductions is enough to

6meet the contingency requirements

. The 2012 PM2.5 Plan does not include contingency for 2015, the moderate area attainment date, because 2 015 was not a milestone year in a plan that shows attainment in 2019. The 2012 PM2.5 Plan does already include the contingency reduction s for 2019 which will be required under Subpart 4 if U.S. EPA classifies the region as a serious nonattainment area

.

• New Source Review (NSR) Program: U.S. EPA also set a deadline of
December 31, 2014 for the District to demonstrate their PM2.5 pe rmitting program complies with S ubpart 4 requirements. To meet the deadline, the Supplemental
Document describes how the District NSR Ru le 2201 satisfies these requirements.

S ubpart 4 requires the control of PM2.5 precurso rs at major stationary sources except when they do not contribute significantly to PM2.5 levels

. The 2012 PM2.5
Plan addresses NOx and SOx as PM2.5 precursors and demonstrates ammonia and VOC do not contribute significantly to PM2.5 levels . Consisten t with t h is assessment, Rule 2201 treats NOx and SOx as PM2.5 precursors for permitting requirements.

In addition, u nder Subpart 4 requiremen ts for moderate areas

, major sources of PM2.5 are defined as those sources with the potential to emit 100 tons per year (tpy) or more. Rule 2201 already includes this threshold for PM2.5

, plus appropriate thresholds for NOx and SOx.

III. STAFF RECOMMENDATION

The District Supplemental Document: Clean Air Act Subpart 4: The 2012 PM2.5 Plan for the 2006 PM2.5 Standard and District Rule 2201 (New and Modified Stationary Source Review) demonstrates that the S an Joaquin Valley 2012 PM2.5 Plan satisfie s requirements for a moderate PM2.5 nonattainment area under Subpart 4 o f the Act.
The Supplemental Document also discusses that a serious area classification aligned
with the attainment date in the 2012 PM2.5 Plan is appropriate

. Once submitted to U.S. EPA, t his Supplemental Document should enable U.S. EPA to approve the 2012 PM2.5
Plan as meeting the Subpart 4 moderate area requirements.

Staff recommends tha t the Board approve the District Supplemental Document: Clean
Air Act Subpart 4: The 2012 PM2.5 Plan for the 2006 PM2.5 Standard and District Rule 2201 (New and Modified Stationary Source Review) along with the District request to classify the SJV as a serious nonattainment area and submit to U.S. EPA as a revision
to th e Cali fornia SIP

.

7