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AIR QUALITY MANAGEMENT DISTRIC g ~~ 

For A enc~ 

To: Board of Directors 

Sacramento Metropolitan Air Quality Management District 

From: Larry Greene, Air Pollution Control Officer 

Sacramento Metropolitan Air Quality Management District 

Subject: Adoption of a Revision to the Ozone State Implementation Plan for Reasonably 

Available Control Technology 

Recommendations 

1. Conduct a public hearing; 

2. Determine that the adoption of the revision to the Ozone State Implementation 

Plan is exempt from the California Environmental Quality Act (CEQA); and 

3. Approve the attached resolution adopting the revision to the Ozone State 

Implementation Plan for Reasonably Available Control Technology. 

Executive Summary 

The federal Clean Air Act requires air districts that are in nonattainment areas for the federal 

ozone standard to implement Reasonably Available Control Technology (RACT) for the emissions 

of ozone precursors — volatile organic compounds (VOC) and oxides of nitrogen (NOx). The 

RACT requirements apply to all source categories for which the U.S. Environmental Protection 

Agency (EPA) has published a Control Technique Guideline (CTG) document as well as all major 

sources of VOC and NOx. 

The District was designated by EPA as a serious nonattainment area for the 8-hour ozone 

standard. Federal regulations promulgated by EPA require the District to submit a revision to the 

State Implementation Plan (SIP) that meets the federal Clean Air Act RACT requirements as they 

apply to the 8-hour ozone standard. 

StafF performed an analysis of District rules that implement RACT for all CTG categories and 

major source of VOC and NOx. As a result of this analysis, Staff has determined that the District 

has fulfilled the requirements of RACT, as applicable to the 8-hour ozone standard, for all CTG 

source categories and for all major sources of VOC and NOx, with the following exception. At the 

Kiefer Landfill, a major source of NOx, the emissions of NOx from the flare are not limited by a 

SIP-approved rule. 

Staff has prepared a revision to the Ozone SIP to satisfy the federal RACT requirements. The 

proposed SIP revision includes: 1) negative declarations for 13 CTG source categories for which 

the District has no sources, 2) certification that the District has met the RACT requirements for 

applicable CTG source categories and all major sources of VOC and NOx, and 3) portions of the 

existing permit for the flare at the Kiefer Landfill. (This action is equivalent to adopting a rule with 

the same requirements and including it in the SIP.) 

00000i 
., Board Memo 

Ozone SIP Revision for RACT 

October 26, 2006, Page 2 

Attachments 

The table below identifies the attachments to this memo: 

Item Attachment Pacie # 

Board Resolution for Ozone SIP Revision A 5 

Pro osed Ozone SIP Revision B 8 

Staff Re ort C 31 

Evidence of Public Notice D 149 

Background 

EPA published the final Phase 2 Rule to implement the 8-hour ozone air quality standard on 

November 29, 2005 (70 FR 71611). Among the requirements of the Phase 2 Rule, a new section 

was added to the Code of Federal Regulations (40 CFR 51.912) that requires the District to 

submit a revision to the SIP that meets the RACT requirements for VOC and NOx in accordance 

with Sections 182(b)(2) and 182(f) of the federal Clean Air Act. This requirement is known as the 

RACT SIP. 

EPA defines RACT (44 FR 53762) as "the lowest emission limitation that a particular source is 

capable of ineeting by the application of control technology that is reasonably available 

considering technological and economic feasibility " Sections 182(b)(2) and 182(f) of the Clean 

Air Act require the District to implement RACT for: 

• Each category of VOC sources that is covered by a Control Technique Guideline (CTG) 

document issued by EPA; and 

• AII major stationary sources of VOC and/or NOx. 

EPA's designations and classiflcations for the 8-hour ozone standard were published on April 30, 

2004 (69 FR 23857) and became effective on June 15, 2004. The Sacramento Metropolitan Area 

was classified as a serious nonattainment area, with a deadline of 2013 to aftain the standard. 

The major source emissions threshold for areas classified as serious is 50 tons per year of either 

VOC or NOx. 

RACT Analysis 

Staff's analysis is presented in the Staff Report (Aftachment C). The process Staff used to 

demonstrate compliance with federal RACT requirements consists of the following steps: 

• For CTG source categories for which the District has no applicable rule, verify that the 

District has no sources in these categories. 

• For CTG source categories for which the District has an applicable rule, perform a 

detailed comparison of the rule requirements with applicable CTG and other RACT 

guidance documents. 

000002 
Board Memo 

Ozone SIP Revision for RACT 

October 26, 2006, Page 3 

• For non-CTG source categories that are found at one or more major sources within the 

District, perform a detailed comparison of the rule requirements applicable to those 

source categories with relevant RACT guidance documents. 

• For major sources, determine the types of emission units at the facility and determine 

which District rules apply to these sources. The RACT requirement is satisfied for a 

major source when all units that emit VOC or NOx are subject to rules that have been 

determined to satisfy RACT. 

EPA Region 9 provided a list of CTG categories and documents in a letter from Andrew Steckel 

dated April 4, 2006. Staff reviewed the list, and determined which District rules are applicable to 

the CTG categories. For categories where the District has no applicable rule, Staff reviewed the 

database of permitted sources and the yellow pages to determine whether there are any 

sources in these categories. Staff determined that there are 13 CTG categories for which the 

District has no sources. Staff also determined there are no CTG categories for which the 

District has sources but no applicable rule. 

Staff reviewed the permitting records of sources within the District to compile a list of major 

sources of VOC and/or NOx. Because the District is classified as a serious nonattainment area 

for the 8-hour ozone standard, major sources are those for which the potential-to-emit exceeds 

50 tons per year of either VOC or NOx. 

Based on the analysis as presented in the Staff Report (Attachment C), Staff finds that the 

District has fulfilled the requirements of RACT, as applicable to the 8-hour ozone standard, for 

all CTG source categories and for all major sources of VOC and NOx, with the following 

exception. At the Kiefer Landfill, a major source of NOx, the emissions of NOx from the flare 

are not limited by a SIP-approved rule. 

The RACT deficiency will be remedied by submitting for inclusion in the SIP the portions of the 

permit that require a NOx limit of 0.06 Ib/mmBtu for the flare and the associated testing and 

recordkeeping requirements. 

Business Cost Impacts 

No costs to businesses will be incurred as a result of proposed SIP revision. 

District Impacts 

The proposed SIP revision will not result in an additional need for staff resources. 

Emission Impacts 

The proposed SIP revision will not have any effect on emissions. 

000003 
Board Memo 

Ozone SIP Revision for RACT 

October 26, 2006, Page 4 

Environmental Review and Compliance 

The proposed SIP revision will make the existing NOx emission limit for the Kiefer Landfill flare 

federally enforceable. The source already meets the emission limit. Therefore, Staff has 

determined that the adoption of the proposed SIP revision is exempt from the California 

Environmental Quality Act (CEQA) under Section 15061(b)(3) of the State CEQA Guidelines 

because it can be seen with certainty that there is no possibility that the activity in question may 

have a significant adverse effect on the environment. 

Public Outreach 

A public notice for the Board hearing to consider the adoption of the proposed SIP revision was 

published in the Sacramento Bee on September 26, 2006. The Staff Report and proposed SIP 

revision were made available on that day. The public notice was also mailed to all major 

sources within the District as well as other parties who requested public notices for District 

rulemaking activities. In addition, Staff discussed the inclusion of the Kiefer Landfill flare permit 

as a SIP revision with the County of Sacramento Department of Waste Management and 

Recycling and received their concurrence. 

Conclusion 

The proposed SIP revision will satisfy the requirements of the federal Clean Air Act and federal 

regulations (40 CFR 51.912). Therefore, staff reoommends that the Board determine that the 

proposed SIP revision is exempt from CEQA and approve the attached resolution adopting the 

SIP revision. 

Respectfully Submitted 

Larry Greene, Air Po lution Control Officer 

Sacramento Metropolitan 

Air Quality Management District 

Approved as to form: 

i:) &~ ';o 4&4 

Kathrine Pittard, District Counsel 

Sacramento Metropolitan 

Air Quality Management District 

Attachments 

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