# Air Resources Board Mary D. Nichols,Chainnan Linda S. Adams 1001 I Street P.O.Box 2815 Arnold Schwarzenegger

Secretaryfor Sacramento, California 95812 www.arb.ca.gov Govemor EnvironmentalProtection



### September 8,2009

Ms. LauraYoshii Acting RegionalAdniirlistrator U.S. Environmental ProtectionAgency Region9 75 Hawthorne Street San.Francisco, California 94105 Dear Ms. Yoshii: TheAir Resources Board (ARB or Board) istransmittingto the U. S. Environmental ProtectionAgency (U.S. EPA)three public corrlment letters on the California Regional Haze Plan, along with our responses. This supplements the comments and responses from the U.S. Departmentof Interior and the U.S. Department of Agriculture, which were included with the submitted Plan. Under State law, State Implementation Plans are typically first adopted by local air districts, and public comments are addressed by the district level. However, since ARB prepared a single statewide regional haze SIP, we are respondingto the public comments inthis instance. The Regional Haze Planwas approved as a revisionto the California State Implementation Plan by Resolution, after a public hearing on January 22, 2009. The Board Resolution directed the ARB Executive Officerto work with the U.S. EPAto resolve any completeness and approvability issues, including transmitting technical corrections, clarifications, or additions that may be necessaryto secure U.S. EPA approval of the Regional Haze Plan. ARB respondedto oral comments at the Board hearing as recorded inthe hearing transcript already transmittedto you. Enclosed are two copies of the written public commentson the Regional Haze Plan from non-Federal agencies, with ARB responses, and an electronic copy of each.

Theenergy challenge facing Californiais real. Every Californian needs to take immediateaction to reduce energy consumption. Fora list ofsimple ways you can reduce demandand cutyour energy costs, see our website: http:/lwww.arb.c~.~ov. 

### California Environmental ProtectionAgency

- - - - - --- - - - Printed on RecycledPaper

### Ms. Laura Yoshii September 8,2009 Page 2

Ifyou have any questions, pleasecall Ms. LynnTerry, Deputy Executive Officer, at (916) 322-2739, or haveyour staff contact Ms. Karen Magliano, Chief,Air Quality Data Branch, at (916) 322-7137. Sincerely,

Executive0fFicd
Enclosures (2)

cc: Lynn Terry Air Resources Board
Karen Magliano Air Resources Board

# CALIFORNIA REGIONAL HAZE PLAN

PUBLIC COMMENTS AND RESPONSESALAMEDA COUNTY Tom Bates ' (Secretary) Scott Haygerty Jennlfer Hosterman Nate Miley

CONTRA COSTA COUNTY John G~ola Mark Ross Mlchael Shl~nansky Gayle B. Uilkema

MARIN COUNTY tlarold C. Brown,Jr

NAPA COUNTY BradWagenknecht (Vice-Chairperson)

SAN FRANCISCO COUNTY Chris Daly Gavln Newsorn

SAN MATE0 COUNTY Carol Klatl Carol Groom

SANTA CLARA COUNTY Susan Garner Yortko Ktshlmoto LIL Kn~ss KenYeagcr

SOLANO COUNTY El~zabelh Patterson

SONOMA COUNTY

Sh~rlee Zane PamelaTorllati (Cha~rperson) Ms LYIII~ ']'cry Ilcputy Eseculive Olliccr Ci~lifornia Air liesources Boarcl 1001 -1' Stl~cct P.0.13017815 Sucrii~ncnto. CA 958 12
Dear Ms.'T'ci.r),:
.I hc purposc ol'tliis Icltcr IS loclarifj [lie l>istricr't, I3.AI1.1 tlclcl nlinatio~i fol tllc Valcro [jcnic~a Iiclilicr) fbr ~ncluslon 111the Stale I1cgionul IlaxSII'
.l'htt Ilisrrict bclicvcs rhar existilig rcgulato1.y rcquircnicnrs, along \\.irli crliission lilnirs on core pl.occss units in Valerots Consent [>ccl.ec \\:ill1 ~hc I;f'AillOJ, rnccl or csccctl 13All'l' rcqui~uncn~s. Additiolial crnissioll control projec~s 1101 spccilicull? ~.equi~.ctl uritler llic C'onscnr [lccl~ce hiive beell evaluuletl. bill Ilil\*cbecn'clclcriiiiiicd 1101 to be cosl-clTi.cti\ c Ibr the increrncnriil \.isibiliry inlprove~nc~ir (as dclno~lslralcd 11) tllc proposeti 13hli.I' tlcrcrlnin>irio~i dared Dccc~nber 2. 7,008.\i,liich is in\lie I>rsliCirlili,r~\ialicpiolial Ilwzc I'li~li as Appe~~dix D). l'herel~.c,llie [)istl.icl ctilinoi ~.ccluire ~llcst' i~drli~ioli;~l rccluclioli~ 1111tlc1 tlrc Itcgio~ial IInzc r~lles.
Arracllcd is il revisedTable 5-4 fix thc tinal Plan. Onl!, liri~ils Sor the "tnnin s\;ick" icokcr. I-'CCIJ, 2 CO boile1.s) are proposed ro be considcrcd I'or rhe pr.~rl~oscs of~hc 13A11'I' deterrninalion, ThcNOx 13Ali'l' level ~.eferencetl ill tllc currc~it drali Pla~l is incorrcc~. l'llc basis for rhc 1.eviscd NOS limit is existing fctlerally-c~lli)rccablc col.~ditiorl nu~nbcr 11

030. prir.13. 'rhc basis for rile 502 linii~s isthc Consent Ilccree, 'Slle basis fo~. rhc fillcr.able ~x~~liculale limits is SIIJ Regulatioli 6, I'al-ticulatc M;itter slid Visiblc I;~l.~issioi~s.
'I'llc tesl ofpages 5-24 alitl 5-25 inC1inl)lcr 5 oftlie Drafr C:aliJi)l.lliii R~gi~llill 1il/.~' l'1:11i clocs not 1cc1iirrcle\,isions.
I'lcitsu fcel ti,cc to call 131.iiinI3alc1niin~I'ITIJ, stiiffal (4 15) ?:\(I-,1653 if') nu Ii;t\~ :In\. cli~cslions regardillg rhis 11liitlu1..

Jack P Broadbent EXECUTIVE OFFlCERlAPCO'I'itblc 5-4 13,4131' Determination for Selectctl IJnits at Valet-o Refinery

UNIT

"Main Slack:" -Valero Cokcr, - ICCU, -CO Boilers (Units S3, S4, S5, S6) NOx Emission

Limit Citation

, RAAQMD Pernit Condition HI 1030, par1 3 

### SO2 Emission

Limit Citation Consent Decree cl~tcred it1 Utii/ed .~/u/e.s, PI.[I/. 1!. I/oler.o Itqfini~ig Co/ll/>ul7)~, el.ul.,I'W.11. T~.Y., Civil il

clio~i Nn. Sil05-(.:/I-0569, en/e/-ecl Noiw~irbe~. 23, 2005) 

### I'M Emission Limit Citation

SIIJRegulation 6 13AR'I'Implcmcntatiorl Date 1,imils incorpo~.ated in 'I'itle V lJcnnit by Dccember 31,2013Comments on the Regional Haze Monitoring Network: I attended the Regional Haze Workshop held in Sacramento on December 15,2008, and was pleased with the variety of interesting data that was presented by the group. During the discussion session, I asked whether new instrumentation was being considered for analysis. It was implied that there was field instrumentation being used to directly measure haze. However, reviewing a recent study by Malm et al. (2007), it appears that the only instrumentation in the IMPROVE network is a filter collection systems for offline analysis. There are significant drawbacks to this approach and I would suggest that new analytical techniques be explored, regardless of whether that includes instrumentation from my company, Activated Light Technology Industries (www.activated~ligh~.co~).
Filter collection is subject to a number of drawbacks. Forexample, species such as ammonium nitrate are often not efficiently collected by filters, due to the potential evaporation from the particle phase back into the gas phase. Some species, such as acyl peroxy nitrates (PANs), may be thermally unstable and thus will not survive the data collection process. Filter data is collected over multiple day periods and therefore does not reflect peak levels of pollution. Finally, while the initial investment in equipment is nominal, the cost of repeated sampling and analysis is considerable,because employees must be dispatched to collect and replace filters at each site every three days, and then the samples have to be brought back to the lab and subjected to workup and instrumental analysis.
It is possible to measure haze in real time with elimination of the effects of water droplets. A cavity ring-down (CARDS or CRDS) apparatus is capable of measuring hundreds of meters of attenuation within a compact housing. A drying tube added to the inlet will remove any water vapor and a cyclone can be added to remove coarse particles larger than PM 10. CARDS can now be carried out using inexpensive light emitting diodes (LEDs) in place of bulky and expensive lasers. A device operating at 450 nrn could give a valid measure of the actual deciviews of attenuation,rather than creating a calculated measure based on the composition and quantities of collected material. Additionally, speciation of particles can be obtained in real time using CARDS. My Ph.D. dissertation presents the thermal decomposition analysis of nitrogenous species from the particle phase (Hargrove, 2007). I was able to distinguish between organic and inorganic nitrates and was able to detect PANs as well. In combination with inexpensive analyzers, thermal analysis can provide data as is presented in the regional haze plan in real time and without data processing errors. It is also likely that sulfates and ammonium can be analyzed with simple extensions of the technique.
A key focus of the Regional Haze Workshop was identifying the necessary steps to reduce haze. This is where much of the effort needs to be. It would be very satisfying to see haze reductions in the coming years, and even better if the data were collected without significant effort and in real time. The analyzers I describe in this comment are currently available. If additional testing is needed before upgrades can be made, it is time to begin those studies.Hargrove, J.M., 2007. The Application of Cavity Ring-Down Spectroscopy to Atmospheric and Physical Chemistry,University of California, Riverside, Riverside. Malm, W.C., Pitchford, M.L., McDade, C. and Ashbaugh, L.L., 2007. Coarse particle speciation at selected locations in the rural continental United States. Atmospheric Environment, 41(10): 2225-2239.BENlClA REFINERY Valero RefiningCompany- California 3400 E. Second Street

# - Benicia,CA 94510-1005 Telephone (707)745-7011



### December 15,2008
VIA

### HAND

### DELIVERY
Ms. Sylvia Zulawnick Manager, ParticulateMatter Analysis Section CaliforniaAir Resources Board 1001

### I Street Sacramento,CA 95814


### Re: CaliforniaAir ResourcesBoard's Draft Regional Haze Plan
DearMs. Zulawnick,
Valero Refining Company-California ('Valero") is providing to the California Air Resources Board ("CARE$") its initial brief comments relative to CARB's Draft Regional Haze Plan ('Draft Plan"). Valero owns and operates the Benicia Refinery in Benicia, California. The Benicia Refinery produces approximately 25% 

### of the compliant, clean-burning transportation fbels for the Bay Area market.
As 

### Valero only became aware of the release the Draft Plan on Monday, December gth, 

### only a week before the December 15" public workshop, it has not had adequate time to thoroughly review and provide detail cornmd on the Draft Plan. Valero has concerns with the BART determination for the Benicia Refinery,including the cost-effective analysis and proposed limits.
Because of these concerns Valero would like to set up a meeting with CARB staff to discuss these concerns. TheDraft Plan in itscurrent form if adopted, couldjeopardize Valero's ability to produce compliant, clean-burning transportation fbels for the Bay Area market, and therefore, causepotential market constraints.
In conclusion, Valero would like to thank CARB for the opportunity to provide these initial comments and looks forward to working productively and cooperatively with CARB in developing a Final Plan.

### Valero's Initial Comments On CARB's DraftRegional Haze Plan December 15,2008 Page 2



### Please contactme

. 

### at

. 

### (707)745-7203if you shouldhave any questions or need clarifications concerningValero'sainitialcomments. We look forwardto meetingwith you in the very near fittureto discussour concernswith the 

### Draft

### Plan. 

# I Sincerelyyours, 

# %*

Tod



## .Lopez ~nviroment a1Manager

cc: Linda

### C. Murchinson, CARB KarenMagliano,

### CARB Tina Suarez-Murias, 

### CARBJanuary 21,2009
MA E-MAILAND FACSIMILE
E-mail: htt~://www.arb.ca.aov/lispub/comm/bcIist.ph~ Fax: (916) 322-3928
Linda C. Murchison,Chief Planning and Technical SupportDivision CaliforniaAir Resources Board 1001 

### I Street,P.O. Box 2815 Sacramento, CA 95812


### Re: Valero Benicia Refinery's Commentson the Proposed CulijorniaRegionalHaze Plan
Dear Ms. Murchison:
On l%ember 

### 5, 2008, the Califomia Air Resources Board ("CARB") released the proposed California Regional Haze Plan (the "Proposed Plan") adopted pursuant to the United States' Environmental ProtectionAgency's ("EPA") Regional Haze Rule (the 'T3egional HazeRule") (40 CFR Part 51,Subpart P; 

### $4 51.300 et seq.). This letter provides the comments ofthe Valero Benicia Refinery ("Valero") on the Proposed Plan. This letter supplements Valero's previous comments that were submitted on December 15,2008. Generally. CARB has done an excellent job in developing a Proposed Plan that is consistent with the Regional Haze Rule. In particular, the Proposed Plan recognizes that sinceenactment of the Califomia Clean 

### Air Act in 1988 Califomia has had a statutory requirement for application of Best Available Retrofit Control Technology (known as "BARCT") and "all feasible [emission reduction] measures" to existing stationary sources, such 

### as the Benicia Refinery, in state ozone nonattainment areas. The existence of these requirements substantially simplified California's obligation under the Regional Haze Rule to undertake a Best Available Retrofit Technology ("BART") determination for BART-eligible sources in California. In fact, and 

### as the Proposed Plan notes, existing emission controls that meet or exceed BART standards already exist throughout California, and additional BART-level controls are unnecessary for purposes of achieving the Regional Haze Rule's goal of attainingnatural visibility in all Class 

### I Areas by 2064. Although Valero generally supports the Proposed Plan, since the Benicia Refinery is the sole stationary source in California identified in the Proposed Plan as requiring a BART analysis and additional BARTlevel controls, we have several concerns and comments on that point. Specifically,for the reasons set forth below, Valero maintains that the Proposed Plan's identification ofthe Benicia Refinery 

### as subject to the requirement to do a BART analysis and then apply BART is incorrect, and that the Proposed Plan should not include any BART-level controls applicable to the Benicia Refinery.

Benicia Refinery

# . Valero Refining Compony-Californio 3400 East Second Street Benic~o, California 945 10-1097

# - Telephone (707) 745-70 1 1 

# .Facsimile (707) 745-75 14Linda C. Murchison, Re: ValeroBenicia Refinery's Commentson the Proposed CaliforniaRegional Haze Plan January 21,2009 Page 

### 2
First, a January 15, 2009 letter to CARB from the Bay Area Air Quality Management District (the "District") clarifiesthat the Proposed Plan's determination that the Benicia Refinery requires additional controls is incorrect. As the letter notes, the "Dismct believes that existing regulatory requirements, along with emission limits on core process units in Valero's Consent Decree with the EPAIDOJ,meet or exceed BART requirements." This is consistent with the District's conclusions concerning other stationary sources in the San Francisco Bay 

### Area, which were that improvements mandated by Consent Decrees between the facility operators and EPA qualifj. 

### as BART-level controls. The District's letter also makes clear that "[aldditional emissioncontrolprojects not specifically required under the Consent Decree have been evaluated, but have been determined not to be cost-effective for the incremental visibility improvement [and] therefore the District cannot require these additional reductions under the Regional Haze rules." Valero appreciatesthe clarifications made in the District's letter, and anticipates that with this additional information CARB will not require that 

### further BART-level controls be implemented at the Benicia Refinery. Valero requests that the District's letter be incorporated into the any Final Plan. Second, given the December 5, 2008 release date for the Proposed Plan, the review and comment process has been somewhat accelerated. Valero 

### has asked AECOM to review the BART exemption modeling which purported to demonstrate that emissions

### hm the Benicia Refinery lead to a visibility impact that exceeds the 0.5 deciview threshold for applying BART-level controls to avoid visibility impairment. AECOM's review has resulted in a strongrecommendation to implement two site-specific refinements, limited to the visibility post-processing step, that are consistent with the rest of the California Regional Haze Rule procedures and with national modeling practices. These refinements, discussed and described below, are specific to the Point Reyes National Park and would not affect the remainder of the CARB BART modeling, except 

### as noted below.


### In particular, there are two items identified for adjustments, one of which is the use of the new IMPROVE equation in the CALPOST visibility postpmcessing. This equation is consistent with the CARB characterization of visibility in its Appendix A Regional Haze Rule documentation, but which could not be implemented 

### in the CALPUFF processing until recently due to Federal Land Manager 

### (FLM) delays in approving and releasing this algorithm. The other refinement is the use of

### an ammonia background consistent with the Interagency Workgroup on Air Quality Modeling guidance preferred by the FLMs, which recommends for forested areas such as the Point Reyes National Park area 

### an ammonia background value of 0.5 ppb rather than the default 10ppb that CARB used. With these two important refinements (i.e., using the new IMPROVE equation along with updated ammonia background values), AECOM estimatesthat the highest modeled 98th percentile day for the controlling year, 2000, drops to a 0.44 deciview impact on visibility for the Benicia Refinery, which is below the BART applicability threshold of 0.5 deciview. This means that 

### BART applicability to the Benicia Refinery is not triggered. It is also noteworthy to mention that the change in the predicted 9gLhpercentile impacts due to implementation of these two refinements would result in a reduction of over 40% in the regional haze impact for the controlling year, 2000. A change of this type of magnitude would also be expected for other BART-eligible sources that CARB also modeled 

### in the Bay Area for impacts at Point ReyesLinda C. Murchison, Re: ValeroBenicia Refinery's Commentson the Proposed Calgurnia Regional Haze Plan January 2 1,2009 Page 3 I ! 

# i

National Park. The Benicia Refinery will make AECOM's CALPOST modeling results with two refinements discussed above for the controlling year, 2000, available to CARB staffupon request. Finally, Valero is concerned with the cost-benefit analysis prepared by the District in the Proposed Plan, "Appendix D - District BART Determination," 

### an analysis that should not be necessary with the exemption modeling outcome noted above. In this determination, the "Main Stack scrubber" required under the Consent Decree between Valero and EPA was evaluated 

### as a separate BART-level control. Appendix D states 

### that the cost of improvement related to requiring the Main Stack scrubber 

### as a separate BART-level control for purposes of achieving visibility improvements would be $202 million/deciview/year. (See Proposed Plan, App. D, 

## 5 1.A., p. 

### D-5).The evaluation nevertheless seems to conclude that despite this cost,the calculated 0.476 deciview improvementin visibility expected 

### if the Main Stack scrubber is required, would bejustified. (See Proposed Plan, App. D, 

### 4 l.G., p. D-7). The District's January 15,2009 letter indicatesthat the improvements required under the Consent Decree are being evaluated as existing BART-level controls and not as newly proposed requirements. Nevertheless, Valero wants to emphasize that a calculated cost-effectiveness of $202 million/deciview/year cannot possibly be considered cost-effective for the visibility improvements achieved.
In closing, Valero would like to thank CARB and CARB staff for the opportunity to comment on the Proposed Plan. Valero would also like to thank CARB staff for their willingness and availability to meet and discuss Valero's concerns with the Proposed Plan.
It should be emphasized that although Valero maintains that the Proposed Plan's identification of the Benicia Refinery as subject to the requirementto do a BART analysisand then apply BART is incorrect, and that the Fmposed Plan should not include any BART-level controls applicable to the Benicia Refinery for the compelling reasons discussed above, Valero remains committed to implementing emission controls consistentwith its Consent Decree requirements. Please contact me at (707) 745-7203 if you should have any questions or need clarifications concerning Vafero's comment

Sincer* yours,

~nviromental Manager
DWS:tml

cc: Sylvia Zulawnick,CARBLinda C.Murchison, Re: ValeroBenicia Rejnery 's Comments on theProposed CalifarniaRegional HazePlan January 

### 21,2009 Page 4

Karen 

### Magalieno, CARB Tina Suarez-Murias,

### CARB

### RESPONSES TO PUBLIC COMMMENT LETTERS on CALIFORNIA REGIONAL HAZE PLAN

Bav Area ~i? 

### Quality Management District (BAAQMD) Comment: The District believes that existing regulatory requirements, along with emission limits on core process units inValero's Consent Decreewith the EPAIDOJ, meet or exceed BART requirements. Attached isa revisedTable 

### 5-4 for the final Plan. Only limitsfor the "main stack" (coker, FCCU, 2 CO boilers) are proposed to be considered for the purposes ofthe BART determination. The NOx BART level referenced inthe current draft Plan is incorrect. The basis for the revised NOx limit is existingfederally-enforceable condition number 11030, part 3. The basisfor the SO2 limits isthe Consent Decree. The basis for thefilterable particulate limits isSIP Regulation 6, 

### Particulate Matter and Visible Emissions. Response: ARB agrees with the limits described, and has included BAAQMD's revised Table 5-4 in the final Planfor transmittal to the U.S. EPA.



### Mr. Richard Hargrove
1. 

### Comment: Mr. Hargrove states the drawbacks to a filter measurement approach for evaluating visibility andsuggests that other new analytic approaches be usedthat directly measure light attenuation. Response: As stated in Chapter 

### 9, California will rely on the filter-based IMPROVE monitoring program to collect and report data for Regional Haze purposes. ARB suggests Mr. Hargrove contact the IMPROVE Steering Committee regarding his product.


### Valero Refinery (December 

### 15, 2009 letter)
1. 

### Comment: Valero did not have adequate time to review thedraft Plan and prepare detailed comments because it

### was notavailable until one week before the public workshop. Valero requested a meetingwith CAR6staff to discuss their concerns. Response: The draft Plan was releasedto the public for review and comment at least 45 days in advance of the,public hearing on the Regional Haze Plan. ARB staff held a public workshop after the draft Plan was released to provide an opportunity to respond to questions about the ~egional Haze Plan. Valero attended the workshop. ARB also met several times with Valero, after the public workshop and before the public hearing,to discuss their concerns.'

Page 

### 1 of 4

### RESPONSES TO PUBLIC COMMMENT LETTERS on CALIFORNIA REGIONAL HAZE PLAN

Valero Refinery (Januarv 21, 2009 letter)
1. Comment: Valero generally supports the draft Plan. As the only facility 

### in California requiringa detailed BART determination, Valero maintains that identification of the Benicia Refinery as subject to BART is incorrect and the Regional Haze Plan should not include BART-level controls for the facility. Response: ARB staff followed the appropriate BART screening criteria as outlined in Chapter 5 of the Plan. ARB'S modeling indicated a visibility impact of greater than 0.5 deciviews above background at the nearby Class 1Area, the Point Reyes National Seashore, for the cluster of BART-eligible units at the Valero facility.. Therefore the Regional Haze Rule requires a BART determinationand the listing of BART-level controls in the Regional Haze Plan.
2. Comment: Valero appreciates the clarifications made inthe letter from BAAQMD dated January 15, 2009, and anticipates that CARB will not require further BART-levelcontrols at the refinery because, according to BAAQMD, "...existing regulatory requirements, along with emission limits on core process units inValero's Consent Decree with EPAIDOJ, meetor exceed BART requirements." Valero requeststhat the District's letter be incorporated into any final Plan. Response: BAAQMD's January 15, 2009 letter included refinements to Table 

### 5-4 listing the controls that meet or exceed BART levels. At the ARB hearing on the draft Plan, the Board approved incorporating the BAAQMD table into the final Plan.
3. 

### Comment: Valero states the review and comment period on the "Proposed Plan" has been accelerated. Response: A 45-day review periodwas provided for the Regional Haze Plan. ARB posted 

### a public notice of draft availability, including a public hearing notice, on December 5, 2008 for the January 22, 2009 public hearing on the Regional Haze Plan. There was no acceleration of the review and comment period.

Page 2 of 4

### RESPONSES TO PUBLIC COMMMENT LETTERS on CALIFORNIA REGIONAL HAZE PLAN

Valero Refinery (January 21, 2009 letter) (continued)
4. 

### Comment: Valero asked a consultant to review the BART exemption modeling, and questions two site-specific refinements specific to Point Reyes National Seashore. First, the new IMPROVE equation should be used for CALPOST visibility post-processing, although it 

### could not be implemented inthe CalPuff processing until recently due tothe Federal Land Manager (FLM) delays in approving and releasing the algorithm. Second, the Interagency Workgroup on Air Quality Modeling guidance preferred by the FLMs recommends'an ammonia background value of 0.5 ppb rather than the default 10ppbthat CARB used. With these two refinements, Valero's consultant estimatesthat the highest modeled 98th 

### percentile day for the controlling year, 2000, drops to a 0.44 dv impact at Point Reyes, which is more than a 40% 

### reduction inthe impact modeled by CARB. Response: ARB'S modeling protocolwas reviewed by U.S. EPA staff for conformance with the BART modeling requirements. The impact threshold was set at 0.5 deciviews above a background value calculated using the original haze algorithm, not the new haze algorithm. It 

### would not be appropriateto use different algorithmsfor various steps in the niodeling protocol.
ARB used an ammonia background of 10 ppb for CalPuff modeling in the Bay Area based on available data from measurementsduring the recent Central California Regional PMlOlPM2.5Air Quality Study. Using a region-specific value is more accurate than the nationwide default for forested areas. The coastal Point Reyes National Seashore is not entirely forested, nor is the nearby urbanized Bay Area where most of the reactions with ambient ammonia occur.

Page 3 

### of 4

### RESPONSES TO PUBLIC COMMMENT LETTERS on CALIFORNIA REGIONAL HAZE PLAN

Valero Refinery (January 

### 21,2009 letter) (continued)


### 5. Comment: Valero isconcerned with the cost-benefit analysis prepared bythe BAAQMD inthe draft Plan "Appendix D

## - District BART Determination". Valero wants to emphasize that a calculated costeffectiveness of 

### $202 million/deciview/year cannot possibly be considered cost-effective for the visibility improvements achieved by improvingthe "Main Stack Scrubber" as required by the consent decree betweenValero and the U.S. EPA. Response: The characterization of $202 million/deciview/year reflects the total cost of the scrubber, CO boiler replacements, and SCR for the boilers. As noted in ,thecomment, these controls are already required under the consent decree. The Plan simply acknowledges that these existing control requirements satisfy BART.
6. 

### Comment: Valero maintains that the draft Plan's identification of the Benicia Refinery as subject to the requirementto do a BART analysis andthen apply BART is incorrect and that the Regional Haze Plan should not include any BART-level controls applicable tothe Benicia Refinery. Nevertheless, Valero remains committedto implementing emission controls consistent with its consent decree requirements. Response: ARB followed the process outlined in the Regional Haze Rule for identifying and screening the BART-eligible facilities and units for subject-toBART modeling. As indicated in the response to comment 1,ARB'Smodeling indicated a visibility impact of greater than 0.5 deciviews for the cluster of units at the Valero facility. Therefore, BART-level controls are applicable to the Valero facility.

Page 4 

### of 4

# CALIFORNIA REGIONAL HAZE PLAN

PUBLIC COMMENTS AND RESPONSESALAMEDA COUNTY Tom Bates (Secretary) Scott Haggerty Jennlfer Hosterman Nate Miley

CONTRA COSTA COUNTY John Gioia Mark Ross Mlchael Sh~mansky Gayle B. Uilkema

MARIN COUNTY I-laroldC. Brown. Jr

NAPA COUNTY Brad Wagenknecht (Vice-Chairperson)

SAN FRANCISCO COUNTY Chris Daly Gavln Newsom

SAN MATE0 COUNTY Carol Klatl Carol Groom

SANTA CLARA COUNTY Susan Garner Yoriko Kishimoto Liz Kniss Ken Yeager

SOLANO COUNTY ElrrabethPatterson

SONOMA COUNTY

Shlrlee Zane Pamela Torl~att (Chairperson) 

### Ms.Ly111i'I'erl'y Ilcputy Executive Officer Ci~liforriin Airliesources 13o:trtl I00 l "I' Street P.0. 130s 2815 Sacralnento. CA 958 12
Dear Ms.7'erl-y:
.l'hc purpose oftliis letter isto clarifq tlie llistrict's I3ARTtlctcrminatiol~ for the Valcro Rcnicia I<cfincl> I'or iliclu~ion intlic State Regional IfaxSIP.
The Ilistric~ believes that existing rcgulatoly recluireli~ents, along\\.it11 emission lilnils 011 core process units inValero's Consent Decree witI1tllc I':I'A/I>OJ, meet orexccccl 13Ali'l' rcquircnients. Adtiitiolli~l enlissiol, control projects not specilicc~lly rcquirccl ullclcr the Conscnr I)ec~.eehave been ev;~luatecl, but have been de~erminccl nor to be cost-clli.clii.c thr 11ic i~icrc~n~~ital visibiliry iniprovemc~it (as tic~no~iswatcd inrllc pl.oposcd 13A 111' dcter~nination dared I>cccmbt.r 2, 1,008.\vliicli is intlie I>raliCalili)l.l~ia Rcgiolial IIn/.e l'l:tr~ as ,\ppelldix D). l'hereTo~.e,rlie I)istrict cannot require rliesc ;~dtlitioniil rctluctio~~s LIII(ICI. ~IIC liegiol~el 1-lazerulcs.
Attaclicd is a revised Table 5-4 tk the finill Plan. Only limirs Ihrtlic .*main stack" (cokcr. T'CCtJ, 2 CO boilers) are proposedto be considered for rhe prrrposes oftlic t3A11'1' determination. The NOxIIAl<'l' level referenced inthe currc~~l dralt Pl:ui is incorrcc~. '1'11~ basis forthc 1.evised NOx limit is existing federally-enforceable corldition n~lmber 1 1030. par13. 'flit basis for tlie SO2 limits isthe Conscnt Decree. 'l'lle basis for tlie filterable pa~-ticulate limits is SIP Regulation 6, I-'articulare Matteranti Visible I3nissions.
'The text of pages 5-24 alitl 5-25 inChap~cr 5 oftlie Draft Califorl~iii Rcgiol~al 1lar.c t'li111 docs not rccliiire r.evisions.
I'lcase feel ficeto call Brian Ilatclnan ofmy staffat (415)7.19-41653 iI'>o\lIlavc an), clucstions regarding this niatrcr. 

# &"13-

Pollution Colilrol Ofliccr

Jack P. Broadbent EXECUTIVE OFFICERIAPCOTi~ble 5-4 BART Determination for Selected Units at Valel-oRefinery

UNIT

"Main Stack:" -Valelo Cokcr, - I'CCU, -CO Boilers

- (Units S3, S4, S5,

S6) 

### NOx Emission

Limit Citation RAAQMD Perinit Conditio~l HI 1030, pa113 13AII'T Implementation Date I.,imits incorporated in 'I'itle V I'cnnit by December 31,2013 SO2 Emission

.Limit Citation Collsent Decree entered it1 U~ii~ed SIUIOS, el.ul. v. I'olero Hflning Cortipurij~, el.ul.,iJ4.11. T~.Y., C'ivtl :I crioliNo.SiIOj-C:/I -0569, e1~1ct.cr1 Noiw~r~her 23, ?005) I'M Emission Limit Citation

SII' Ilegulacion 6Comments on the Regional Haze MonitoringNetwork:
I attended the Regional Haze Workshopheld in Sacramentoon December 15,2008,and was pleased with the variety of interesting data that was presented by the group. During the discussion session,I asked whethernew instrumentationwas being considered for analysis. It was implied that there was field instrumentation being used to directly measure haze. However, reviewing a recent study by Malm et al. (2007), it appears that the only instrumentation in the IMPROVE network is a filtercollection systems for offline analysis. There are significant drawbacks to this approach and I would suggest that new analytical techniques be explored, regardless of whether that includes instrumentationfrom my company, ActivatedLight Technology Industries (www.activated1ight.com).
Filter collection is subject to anumber of drawbacks. For example, species such as ammoniumnitrate are often not efficiently collectedby filters, due to the potential evaporation from the particle phase back into the gas phase. Some species, such as acyl peroxy nitrates (PANS),may be thermally unstable and thus will not survivethe data collection process. Filter data is collected over multiple day periods and therefore does not reflect peak levels of pollution. Finally, while the initial investment in equipment is nominal, the cost ofrepeated sampling and analysis is considerable,because employees must be dispatched to collect and replace filters at each site every three days, and then the samples have to be brought back to the lab and subjected to workup and instrumental analysis.
It is possible to measure haze in real time with elimination of the effects of water droplets. A cavity ring-down (CARDS or CRDS) apparatusis capable of measuring hundreds of meters of attenuation within a compacthousing. A drying tube added to the inlet will remove any water vapor and a cyclone can be added to remove coarse particles larger than PM 10. CARDS can now be carried out using inexpensive light emitting diodes (LEDs) in place of bulky and expensive lasers. A device operating at450 nm could give a valid measure of the actual deciviews of attenuation, rather than creating a calculated measure based on the composition and quantities of collected material. Additionally, speciation of particles can be obtained in real time using CARDS.My Ph.D. dissertation presents the thermal decomposition analysis of nitrogenous species from the particle phase (Hargrove,2007). I was able to distinguishbetween organic and inorganic nitrates and was able to detect PANSas well. In combination with inexpensive analyzers, thermal analysis can provide data as is presented in the regional haze plan in real time and without data processing errors. It is also likely that sulfatesand ammonium can be analyzed with simple extensions of the technique.
A key focus of the Regional Haze Workshop was identifying the necessary steps to reduce haze. This is where much of the effortneeds to be. It would be very satisfying to see haze reductions in the comingyears, and even better if the data were collected without significant effort and in real time. The analyzers I describe in this comment are currently available. If additional testing is needed before upgrades can be made, it is time to begin those studies.Hargrove,J.M.,2007.The Application of Cavity Ring-Down Spectroscopy to Atmospheric and Physical Chemistry, University of California, Riverside, Riverside. Malm, W.C.,Pitchford,M.L.,McDade, C. and Ashbaugh, L.L.,2007. Coarse particle speciation at selected locations in the rural continental United States. Atmospheric Environment, 41(10): 2225-2239.BENlClA REFINERY Valero Refining Company

### - California 3400 E. Second Street Benicia, CA 84510-1005 Telephone (707)745-7011



### December 15,2008 VIAHANDDELZWR

### Y Ms. Sylvia Zulawnick Manager, ParticulateMatter Analysis Section CaliforniaAirResourcesBoard 1001I Street Sacramento, CA 95814


### Re: CaliforniaAir ResourcesBoard's DraftRegional 

### HazePlan
DearMs. Zulawnick, Valero Refining Company-California ('Yalero") is providing to the California Air Resources Board 

### ('%ARBw)its initial brief commentsrelative to CARB's Draft Regional Haze Plan ("Draft Plan"). Valem owns and operates the Benicia Refinery in Benicia, California The Benicia Refinery produces approximately 25% of the compliant, clean-burning transportation fhels for the Bay Area market.
As Valero only became aware of the release the 

### Draft Plan on Monday, December tith,

### only a week before the December 15~ public workshop, it has not had adequate time to thoroughly review and provide detail comments on the Draft Plan. Valem has concerns with the BART determinationforthe BeniciaRefinery, includingthe cost-effective analysisandproposed limits.
Because of these concerns Valero would like to set up a meeting with CARB staff to discuss theseconcerns. TheDraft Plan in itscurrent formifadopted, couldjeopardize Valero's abilityto produce compliant, clean-burning transportation fiels for the Bay Area market, and therefore, cause potential marketconstraints.
In 

### conclusion, Valero would like to thank CARB for the opportunity to provide these initial comments and looks forward to working productively and cooperatively with CARB in developing a Final Plan.

### Valero's Initial Comments On

### CARB's Draft RegionalHaze Plan December 15,2008 Page 2



### Pleasecontactme at (707) 

### 745-7203

### ifyou should have any questions or need clarifications concerningValero's initial comments. 

### We look forwardto meeting

### with you in the verynear htureto discussour concerns 

### withthe Draft Plan.
Sincerelyyours, 

# yig*

Tod



## .Lopez EnviromentalManager

cc: Linda

### C. Murchinson, CARB Karen Magliano, CARB Tina Suarez-Murias,

### CARBJanuary 21,2009
VIAE-MAIL AND FACSIMILE
E-mail: 

### httD:/hvww.arb.ca.e;ov/lispub/comm/bclist.~hv Fax:. (916) 322-3928
Linda C. Muchison, Chief Planning and Technical Support Division CaliforniaAir Resources Board 1001

### I Street,P.O. Box 2815 Sacramento,CA 95812


### Re: ValeroBeniciaRefiery 's Commentson the ProposedCaliforniaRegionalHazePlan
Dear Ms.Murchison:
On December 5, 2008, the California Air Resources Board ("CARB") released the proposed California Regional Haze Plan (the "Proposed Plan") adopted pursuant to the United States' Environmental ProtectionAgency's ("EPA") Regional Haze Rule (the '$Regional Haze Rule") (40CFR Part 51, Subpart P; §§ 51.300 et seq.). This letter provides the comments of the Valem Benicia Refinery ("Valero") on the Proposed Plan. This letter supplements Valero's previous comments that were submitted on December 15,2008. Generally, CARB has done an excellent job in developing a Proposed Plan that is consistent with the Regional Haze Rule. 

### In particular, the Proposed Plan recognizes that since enactment ofthe California Clean 

### A.ir Act in 1988 California has had 

### a statutory requirement for application of Best Available Retrofit Control Technology (known as "BARCT") and "all feasible [emission reduction] measures" to existing stationary sources, such 

### as the Benicia Refinery, in state ozone nonattainment 

### areas. The existence ofthese requirements substantiallysimplified California's obligation under the Regional Haze Rule to undertake a Best Available Retrofit Technology ("BART") determination for BART-eligible sources in California. In fact, and 

### as the Proposed Plan notes, existing emission controls that meet or exceed BART standards already exist throughout California, and additional BART-level controls are unnecessary for purposes ofachieving the Regional Haze Rule's goal of attaining natural visibility in all Class I Areas by 2064. Although Valero generally supports the Proposed Plan, since the Benicia Refinery is the sole stationary source in California identified in the Proposed Plan asrequiring a BART analysis and additional BARTlevel controls, we have several concerns and comments on that point. Specifically, for the reasons set forth below, Valero maintains that the Proposed Plan's identification ofthe Benicia Refinery as subject to the requirement to do a BART analysis and then apply BART is incorrect, and that the Proposed Plan should not include any BART-level controlsapplicableto the Benicia Refinery.

hicia Rdnory Volero Refining ComponyColifornia 3400 East Second Street Benicio, Colifornio945 10-1097 Telephone (707)745-701 1 Facsimile (70717457514Linda C. Murchison, Re: ValeroBenicia Refinery's Commentson theProposed CaliforniaRegional Haze Plan Janllary 21,2009 Page 2
First, a January 15, 2009 letter to CARB hm the Bay Area Air Quality Management District (the "District") clarifies that the Proposed Plan's determinationthat the Benicia Refinery requires additional controls is incorrect. As the letter notes, the "District believes that existing regulatory requirements, alongwith emission limitson coreprocess units in Valero's Consent Decree with the EPAIDOJ, meet or exceed BART requirements." This is consistent with the District's conclusions concerning other stationary sources in the San FranciscoBay Area, which were that improvementsmandated by Consent 

### Decrees between the facility operators and EPA qualify as BART-level controls. The District's letter also makes clear that "[a]dditional emission control projectsnot specifically required under the Consent Decree have been evaluated, but have been determined not to be cost-effective for the incremental visibility improvement [and] therefore the District cannot require these additional reductions under the Regional Haze 

### rules." Valero appreciates the clarificationsmade in the District's letter, and anticipates that with this additional information CARE3 will not require that further BART-level controls be implemented at the Benicia Refinery. Valero requests that the District's letter be incorporated into the any Final Plan. Second, given the December 

### 5, 2008 release date for the Proposed Plan, the review and comment process has been somewhat accelerated. Valero has asked AECOM to review the BART exemption modeling which purported to demonstratethat emissions from the Benicia Refinery lead to a visibility impact that exceeds the 0.5 deciview threshold for applying BART-level controls to avoid visibility impairment. AECOM's review 

### has resulted in a strongrecommendation to implement two site-specific refinements, limited to the visibility post-processing step, that 

### are consistent with the rest of the California Regional Haze Rule procedures and with national modeling practices. These refinements, discussed and described below, are specific to the Point Reyes National Park and would not affect the remainderofthe CARE3 BART modeling, except asnoted below.


### In particular, there are two items identified for adjustments, one of which is the use of the new IMPROVE equation in the CALPOST visibility postprocessing. This equation is consistent with the 

### CARB characterizationof visibility in its Appendix A Regional 

### Haze Rule documentation, but which could not be implemented 

### in the 

### CALPUFF processing until recently due to Federal Land Manager 

### (FLM)delays in approvingand releasing this algorithm, The otherrefinement isthe use of an ammonia background consistent with the InteragencyWorkgroup on Air Quality Modeling guidance preferred by theFLMs, which recommendsfor forested areas such 

### asthe Point ReyesNational Park area an ammonia background value of 0.5 ppb rather than the &fault 10ppb that CARB used. With these two important refinements (i.e., using the new IMPROVE equation along with updated ammonia background values), AECOM estimatesthat the highest modeled 98th percentile day for the controllingyear, 2000,drops to a 0.44 deciview impact on visibility for the Benicia Refinery, which is below the BART applicability threshold of 0.5 deciview. This means that BART applicability to the Benicia Refinery is not triggered. It is also noteworthy to mention that the change in the predicted 98mpercentile impacts due to implementation of these two refinements would result in a reduction of over 40% in the regional haze impact for the controlling year, 2000. A change of this type of magnitude would also be expected for other BART-eligible sources that CARB also modeled in the Bay Area for impacts at Point ReyesLinda 

### C. Murchison,Re: ValeroBenicia Refinery's Commentson the Proposed CalijbrniaRegional Haze Plan January 21,2009 Page 3

National 

### Park. The Benicia Refinery will make AECOM's CALPOST modeling results with two refinements discussed above for the controllingyear, 2000, availableto CARB staffupon request. Finally, Valero is concerned with the cost-benefit analysis preparedby the District 

### in the Proposed Plan, "Appendix D 

### - District BART Determination," an analysis that should not be necessary with the exemption modeling outcome noted above. 

### In this determination, the "Main Stack scrubber" required under the Consent Decree 

### between Valero 

### and EPA was evaluated 

### as a separate BART-level control. Appendix D states that the cost of improvement related to requiring the Main Stack scrubber as a separate BART-level control for purposes of achieving 'visibility improvements would be $202 million/deciview/year. (SeeProposed Plan, App. D, § 1.A., p. D-5). The evaluation nevertheless seems to conclude that despitethiscost, the calculated0.476 deciviewimprovement in visibility expected if the 

### Main Stack 

### scrubberis required, would bejustified. (See Proposed Plan, App. D, 

## 5 1.G.. p. D-7). The District's 

### January 15,2009letter indicatesthat the improvements requiredunder the Consent Decree are being evaluated 

### as existing BART-level controls and not as newly proposed requirements. Nevertheless, Valero wants to emphasize that a calculated cost-effectiveness of $202 million/deciview/year cannot possibly be considered cost-effective for the visibility improvements achieved.
In closing, Valero would like to thank CARB and CARB staff for the opportunity to comment on the Proposed Plan. Valero would also like 

### to thank 

### CARB staff for their willingness and availability to meet and discuss Valero's concernswith the ProposedPlan.
It should be emphasized that although Valero maintains that the Proposed Plan's identification of the Benicia Refinery as subject to the requirement to do a BART analysis and then apply BART isincorrect, and that the Proposed Plan should not include any BART-level controls applicable to the Benicia Refinery for the compelling reasons discussed above, Valero remains committed to implementing emission controls consistent with itsConsent Decreerequirements.
Please contact me at (707) 745-7203 if you should have any questions or need clarifications concerning Vatero's comments

~nvirornental Manager DWS:tml

cc: Sylvia Zulawnick, CARB

### Linda C.Murchison, 

### Re: ValeroBenicia Refinery'sCommentsontheProposed CaliforniaRegional Haze Plan 

### January21,2009 

### Page 4

Karen Magalieno, CARB 

### Tina Suarez-Murias,CARB

### RESPONSESTO PUBLIC COMMMENT LETTERS on CALIFORNIA REGIONAL HAZE PLAN

Bay Area Air Quality Management District (BAAQMD)
1. 

### Comment: The District believes that existing regulatory requirements, along with emission limits on core process units inValero's Consent Decreewith the EPAIDOJ, meet or exceed BART requirements. Attached isa revised Table 5-4 for the final Plan. Only limitsfor the "main stack" (coker, FCCU, 2 CO boilers) are proposed to be considered for the purposes ofthe BART determination. The NOx BART level referenced inthe current draft Plan is incorrect. The basis for the revised NOx limit is existingfederally-enforceable condition number 11030, part 3. The basis for the SO2 limits isthe Consent Decree. The basis for the filterable particulate limits is SIP Regulation 

### 6, Particulate Matter and Visible Emissions. Response: ARB agrees with the limits described, and has included BAAQMD's revised Table 5-4 in the final Planfor transmittal to the U.S. EPA.



### Mr. Richard Hargrove


### 1. Comment: Mr. Hargrove states the drawbacks to a filter measurement approach for evaluating visibility and suggests that other new analytic approaches be usedthat directly measure light attenuation. Response: As stated in Chapter 

### 9, California will rely on the filter-based IMPROVE monitoring program to collect and report data for Regional Haze purposes. ARB suggests Mr. Hargrove contact the IMPROVE Steering Committee regarding his product.


### Valero Refinery (December 15.2009 letter)
1. 

### Comment: Valero did not have adequate time to reviewthe draft Plan and prepare detailed comments because it

### was notavailable untilone week before the public workshop. Valero requested a meetingwith CAR6 staffto discuss their concerns. Response: The draft Planwas releasedto the public for review and comment at least 45 days in advance of the,public hearing on the Regional Haze Plan. ARB staff held a public workshop after the draft Plan was releasedto provide an opportunity to respondto questions about the Regional Haze Plan. Valero attended the workshop. ARB also met several times with Valero, after the public workshop and before the public hearing,to discuss their concerns.

Page 1of 4

### RESPONSESTO PUBLIC COMMMENT LETTERS on CALIFORNIA REGIONAL HAZE PLAN

Valero Refinerv (January 21, 2009 letter)



### I.Comment: Valero generally supportsthe draft Plan. As the only facility inCalifornia requiringa detailed BART determination, Valero maintains that identification ofthe Benicia Refinery as subjectto BART is incorrect and the Regional Haze Plan should not include BART-level controls forthe facility. Response: ARB staff followed the appropriate BART screening criteria as outlined in Chapter 5 of the Plan. ARB'Smodeling indicated a visibility impact of greater than 0.5 deciviews above background at the nearby Class 1 Area, the Point Reyes National Seashore, for the cluster of BART-eligible units at the Valero facility. Therefore the Regional Haze Rule requires a BART determination and the listing of BART-level controls in the Regional Haze Plan.
2. Comment: Valero appreciates the clarifications made inthe letter from BAAQMD dated January 15, 2009, and anticipates that CARBwill not require further BART-level controls atthe refinery because, accordingto BAAQMD, "...existing regulatory requirements, alongwith emission limits oncore process units inValero's Consent Decreewith EPAIDOJ, meet or exceed BART requirements." Valero requests that the District's letter be incorporated into any final Plan. Response: BAAQMD1s January 15, 2009 letter included refinements to Table 5-4 listing the controls that meet or exceed BART levels. At the ARB hearing on the draft Plan, the Board approved incorporating the BAAQMD table into the final Plan.


### 3. Comment: Valero states the review and comment period onthe "Proposed Plan" has been accelerated. Response: A 45-day review period was provided for the Regional Haze Plan. ARB posted a public notice of draft availability, including a public hearing notice, on Decerr~ber 5, 2008 for the January 22, 2009 public hearing on the Regional Haze Plan. There was no acceleration of the review and comment period.

Page 2 of 4

### RESPONSES TO PUBLIC COMMMENT LETTERS on CALIFORNIA REGIONAL HAZE PLAN

Valero Refinery (January 21,2009 letter) (continued)
4. Comment: Valero asked a consultant to review the BART exemption modeling, and questions two site-specific refinements specific to Point Reyes National Seashore. First, the new IMPROVE equation should be used for CALPOST visibility post-processing, although it

### could not be implemented inthe CalPuff processing until recently due tothe Federal Land Manager (FLM) delays inapproving and releasing the algorithm. Second, the Interagency Workgroup on Air Quality Modeling guidance preferred by the FLMs recommends an ammonia backgroundvalue of 0.5 ppb rather than the default 10ppbthat CARB used. With these two refinements, Valero's consultant estimates that the highest modeled 98th percentile day for the controlling year, 2000, drops to a 0.44 dv impact at Point Reyes,which is more than a40% reduction inthe impact modeled by CARB. Response: ARB'S modeling protocol was reviewed by U.S. EPA staff for conformance with the BART modeling requirements. The impact threshold was set at 0.5 deciviews above a background value calculated using the original haze algorithm, not the new haze algorithm. It would not be appropriate to use different algorithms for various steps inthe modeling protocol.
ARB used an ammonia background of 10 ppb for CalPuff modeling in the Bay Area based on available data from measurements during the recent Central California Regional PMI0lPM2.5 Air Quality Study. Using a region-specific value is more accurate than the nationwide default for forested areas. The coastal Point Reyes National Seashore is not entirely forested, nor is the nearby urbanized Bay Area where most of the reactions with ambient ammonia occur.

Page 

### 3 of 4

### RESPONSES TO PUBLIC COMMMENT LETTERS on CALIFORNIA REGIONAL HAZE PLAN

Valero Refinerv (January 

### 21, 2009 letter) (continued)


### 5. Comment: Valero is concerned withthe cost-benefit analysis prepared by the BAAQMD inthe draft Plan "Appendix D

## - District BART Determination". Valero wants to emphasize that a calculated costeffectiveness of 

### $202 miIlion/deciviewlyear cannot possibly be considered cost-effectivefor the visibility improvements achieved by improvingthe "Main Stack Scrubber" as required by the consent decree between Valero and the U.S. EPA. Response: The characterization of $202 million/deciview/year reflects the total cost of the scrubber, CO boiler replacements, arid SCR for the boilers. As noted inthe comment, these cor~trols are already required under the consent decree. The Plan simply acknowledges that these existing control requirements satisfy BART.
6. 

### Comment: Valero maintains that the draft Plan's identification ofthe Benicia Refinery as subject tothe requirement to do a BART analysis and then apply BART is incorrectand that the Regional Haze Plan should not includeany BART-level controls applicable to the Benicia Refinery. Nevertheless, Valero remains committed to implementing emission controls consistentwith its consent decree requirements. Response: ARB followed the process outlined in the Regional Haze Rule for identifying and screening the BART-eligible facilities and units for subject-toBART modeling. As indicated in the responseto comment 1,

### ARB'Smodeling indicated a visibility impact of greater than 0.5 deciviews for the cluster of units at the Valero facility. Therefore, BART-level controls are applicable to the Valero facility.

Page4 

### of 4