Air Resources Board 

Mary D. Nichols, Chainnan 

Linda S. Adams 1001 I Street P.O. Box 2815 Arnold Schwarzenegger 

Secretary for Sacramento, California 95812 www.arb.ca.gov Govemor 

Environmental Protection 

September 8,2009 

Ms. Laura Yoshii 

Acting Regional Adniirlistrator 

U.S. Environmental Protection Agency 

Region 9 

75 Hawthorne Street 

San. Francisco, California 941 05 

Dear Ms. Yoshii: 

The Air Resources Board (ARB or Board) is transmitting to the U. S. Environmental 

Protection Agency (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. Department of 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 

responding to the public comments in this instance. 

The Regional Haze Plan was approved as a revision to the California State 

Implementation Plan by Resolution, after a public hearing on January 22, 2009. The 

Board Resolution directed the ARB Executive Officer to work with the U.S. EPA to resolve 

any completeness and approvability issues, including transmitting technical corrections, 

clarifications, or additions that may be necessary to secure U.S. EPA approval of the 

Regional Haze Plan. ARB responded to oral comments at the Board hearing as recorded 

in the hearing transcript already transmitted to you. Enclosed are two copies of the written 

public comments on the Regional Haze Plan from non-Federal agencies, with ARB 

responses, and an electronic copy of each. 

The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. 

For a list of simple ways you can reduce demand and cut your energy costs, see our website: http:/lwww.arb.c~.~ov. 

California Environmental Protection Agency - - - - - --- - - - 

Printed on Recycled Paper 
Ms. Laura Yoshii 

September 8,2009 

Page 2 

If you have any questions, please call Ms. Lynn Terry, Deputy Executive Officer, at 

(916) 322-2739, or have your staff contact Ms. Karen Magliano, Chief, Air Quality Data 

Branch, at (916) 322-71 37. 

Sincerely, 

Executive 0fFicd 

Enclosures (2) 

cc: Lynn Terry 

Air Resources Board 

Karen Magliano 

Air Resources Board 
CALIFORNIA REGIONAL HAZE PLAN 

PUBLIC COMMENTS AND RESPONSES 

ALAMEDA 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 

Brad Wagenknecht (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 

Ken Yeagcr 

SOLANO COUNTY 

El~zabelh Patterson 

SONOMA COUNTY 

Sh~rlee Zane 

Pamela Torllati 

(Cha~rperson) 

Ms LYIII~ ']'cry 

Ilcputy Eseculive Olliccr 

Ci~lifornia Air liesources Boarcl 

1001 -1' Stl~cct 

P.0. 1301 78 15 

Sucrii~ncnto. CA 958 12 

Dear Ms. 'T'ci.r),: 

.I hc purposc ol'tliis Icltcr IS lo clarifj [lie l>istricr't, I3.AI1.1 tlclcl nlinatio~i fol tllc Valcro 

[jcnic~a Iiclilicr) fbr ~ncluslon 111 the Stale I1cgionul I lax SII' 

.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\*c becn '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>rsli Cirlili,r~\ia licpiolial I lwzc 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 revised Table 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, Thc NOx 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.1 3. 'rhc basis for rile 502 linii~s is thc 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 of pages 5-24 alitl 5-25 in C1inl)lcr 5 of tlie Drafr C:aliJi)l.lliii R~gi~llill 1il/.~' l'1:11i 

clocs not 1cc1iirrc le\,isions. 

I'lcitsu fcel ti,cc to call 131.iiin I3alc1niin ~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 

SIIJ Regulation 6 

13AR'I' 

Implcmcntatiorl 

Date 

1,imils 

incorpo~.ated in 

'I'itle V lJcnnit 

by Dccember 

31,2013 
Comments 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. For example, 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 Refining Company - California 3400 E. Second Street - Benicia, CA 94510-1005 Telephone (707) 745-7011 

December 15,2008 

VIA HAND DELIVERY 

Ms. Sylvia Zulawnick 

Manager, Particulate Matter Analysis Section 

California Air Resources Board 

1001 I Street 

Sacramento, CA 95814 

Re: California Air Resources Board's Draft Regional Haze Plan 

Dear Ms. 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. The Draft Plan in its current form if adopted, could jeopardize Valero's ability to 

produce compliant, clean-burning transportation fbels for the Bay Area market, and therefore, 

cause potential 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 Draft Regional Haze Plan 

December 15,2008 

Page 2 

Please contact me . at . (707) 745-7203 if you should have any questions or need clarifications 

concerning Valero'sainitial comments. We look forward to meeting with you in the very near 

fitture to discuss our concerns with the Draft Plan. 

I Sincerely yours, 

Tod %* . Lopez 

~nviroment a1Manager 

cc: Linda C. Murchinson, CARB 

Karen Magliano, CARB 

Tina Suarez-Murias, CARB 
January 2 1,2009 

MA E-MAIL AND FACSIMILE 

E-mail: htt~://www.arb.ca.aov/lispub/comm/bcIist.ph~ 

Fax: (916) 322-3928 

Linda C. Murchison, Chief 

Planning and Technical Support Division 

California Air Resources Board 

1001 I Street, P.O. Box 2815 

Sacramento, CA 958 12 

Re: Valero Benicia Refinery's Comments on the Proposed Culijornia Regional Haze 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 

Protection Agency's ("EPA") Regional Haze Rule (the 'T3egional Haze Rule") (40 CFR Part 5 1, Subpart 

P; $4 5 1.300 et seq.). This letter provides the comments of the 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 since enactment 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 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 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 of the 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 10-1 097 - Telephone (707) 745-70 1 1 . Facsimile (707) 745-75 14 
Linda C. Murchison, Re: Valero Benicia Refinery's Comments on the Proposed California Regional 

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") clarifies that 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 emission control projects 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 appreciates the 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 strong recommendation 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 10 ppb that CARB used. With these two important 

refinements (i.e., using the new IMPROVE equation along with updated ammonia background values), 

AECOM estimates that 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 9gLh percentile 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 Reyes 
Linda C. Murchison, Re: Valero Benicia Refinery's Comments on 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 staff upon 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 improvement in visibility expected if the 

Main Stack scrubber is required, would be justified. (See Proposed Plan, App. D, 4 l.G., p. D-7). The 

District's January 15, 2009 letter indicates that 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 requirement to do a BART analysis and 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 consistent with 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, CARB 
Linda C. Murchison, Re: Valero Benicia Rejnery 's Comments on the Proposed Califarnia Regional 

Haze Plan 

January 2 1,2009 

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 in Valero's Consent 

Decree with the EPAIDOJ, meet or exceed BART requirements. 

Attached is a revised Table 5-4 for the final Plan. Only limits for the 

"main stack" (coker, FCCU, 2 CO boilers) are proposed to be considered 

for the purposes of the BART determination. The NOx BART level 

referenced in the current draft Plan is incorrect. The basis for the 

revised NOx limit is existing federally-enforceable condition number 

11030, part 3. The basis for the SO2 limits is the 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 Plan for 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 used that 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 the draft Plan 

and prepare detailed comments because it was not available until one 

week before the public workshop. Valero requested a meeting with 

CAR6 staff to discuss their concerns. 

Response: The draft Plan was released to 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 requiring a 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 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 

determinationand the listing of BART-level controls in the Regional Haze 

Plan. 

2. Comment: Valero appreciates the clarifications made in the letter from 

BAAQMD dated January 15, 2009, and anticipates that CARB will not 

require further BART-level controls at the refinery because, according to 

BAAQMD, "...existing regulatory requirements, along with emission 

limits on core process units in Valero's Consent Decree with EPAIDOJ, 

meet or exceed BART requirements." Valero requests that 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 period was 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 in the CalPuff processing until recently due to the 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 10ppb that 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 a 40% reduction in the 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 in the niodeling 

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 PMlOlPM2.5 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 Refinery (January 21,2009 letter) (continued) 

5. Comment: Valero is concerned with the cost-benefit analysis prepared 

by the BAAQMD in the 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 

improving the "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, and SCR for the boilers. 

As noted in ,the comment, 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 requirement to do a BART analysis 

and then apply BART is incorrect and that the Regional Haze Plan 

should not include any BART-level controls applicable to the Benicia 

Refinery. Nevertheless, Valero remains committed to 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'S modeling 

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 RESPONSES 

ALAMEDA 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-larold C. 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 

Elrrabeth Patterson 

SONOMA COUNTY 

Shlrlee Zane 

Pamela Torl~att 

(Chairperson) 

Ms. Ly111i 'I'erl'y 

Ilcputy Executive Officer 

Ci~liforriin Air liesources 13o:trtl 

I00 l "I' Street 

P.0. 130s 28 1 5 

Sacralnento. CA 958 12 

Dear Ms. 7'erl-y: 

.l'hc purpose oftliis letter is to clarifq tlie llistrict's I3ART tlctcrminatiol~ for the Valcro 

Rcnicia I<cfincl> I'or iliclu~ion in tlic State Regional Ifax SIP. 

The Ilistric~ believes that existing rcgulatoly recluireli~ents, along \\.it11 emission lilnils 011 

core process units in Valero's Consent Decree wit I1 tllc I':I'A/I>OJ, meet or exccccl 13A li'l' 

rcquircnients. Adtiitiolli~l enlissiol, control projects not specilicc~lly rcquirccl ullclcr the 

Conscnr I)ec~.ee have been ev;~luatecl, but have been de~erminccl nor to be cost-clli.clii.c thr 

11ic i~icrc~n~~ital visibi liry iniprovemc~it (as tic~no~iswatcd in rllc pl.oposcd 13A 111' 

dcter~nination dared I>cccmbt.r 2, 1,008. \vliicli is in tlie I>rali Calili)l.l~ia Rcgiolial I In/.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-laze rulcs. 

Attaclicd is a revised Table 5-4 tk the finill Plan. Only limirs Ihr tlic .*main stack" (cokcr. 

T'CCtJ, 2 CO boilers) are proposed to be considered for rhe prrrposes of tlic t3A11'1' 

determination. The NOx IIAl<'l' level referenced in the currc~~l dralt Pl:ui is incorrcc~. '1'11~ 

basis for thc 1.evised NOx limit is existing federally-enforceable corldition n~lmber 11030. 

par1 3. 'flit basis for tlie SO2 limits is the Conscnt Decree. 'l'lle basis for tlie filterable 

pa~-ticulate limits is SIP Regulation 6, I-'articulare Matter anti Visible I3nissions. 

'The text of pages 5-24 alitl 5-25 in Chap~cr 5 of tlie Draft Califorl~iii Rcgiol~al 1lar.c t'li111 

docs not rccliiire r.evisions. 

I'lcase feel fice to call Brian Ilatclnan of my staffat (41 5) 7.19-41653 iI'>o\l Ilavc an), 

clucstions regarding this niatrcr. 

&"13- 

Pollution Colilrol Ofliccr 

Jack P. Broadbent 

EXECUTIVE OFFICERIAPCO 
Ti~ble 5-4 BART Determination for Selected Units at Valel-o Refinery 

UNIT 

"Main Stack:" 

-Valelo Cokcr, - I'CCU, 

-CO Boilers 

- (Units S3, S4, S5, 

S6) 

NOx 

Emission 

Limit 

Citation 

RAAQMD 

Perinit 

Conditio~l 

HI 1030, 

pa11 3 

13AII'T 

I mplementation 

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 crioli No. SiIOj-C:/I -0569, 

e1~1ct.cr1 

Noiw~r~her 23, 

?005) 

I'M Emission 

Limit 

Citation 

SII' Ilegulacion 6 
Comments 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.activated1ight.com). 

Filter collection is subject to a number of drawbacks. For example, 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 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 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 Refining Company - California 3400 E. Second Street Benicia, CA 84510-1005 Telephone (707) 745-7011 

December 15,2008 

VIA HAND DELZWR Y 

Ms. Sylvia Zulawnick 

Manager, Particulate Matter Analysis Section 

California Air Resources Board 

100 1 I Street 

Sacramento, CA 958 14 

Re: California Air Resources Board's Draft Regional Haze Plan 

Dear Ms. Zulawnick, 

Valero Refining Company-California ('Yalero") is providing to the California Air Resources 

Board ('%ARBw) its initial brief comments relative 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 

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. The Draft Plan in its current form if adopted, could jeopardize Valero's ability to 

produce compliant, clean-burning transportation fiels for the Bay Area market, and therefore, 

cause potential 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 Draft Regional Haze Plan 

December 15,2008 

Page 2 

Please contact me at (707) 745-7203 if you should have any questions or need clarifications 

concerning Valero's initial comments. We look forward to meeting with you in the very near 

hture to discuss our concerns with the Draft Plan. 

Sincerely yours, 

Tod yig* . Lopez 

Enviromental Manager 

cc: Linda C. Murchinson, CARB 

Karen Magliano, CARB 

Tina Suarez-Murias, CARB 
January 2 1,2009 

VIA E-MAIL AND FACSIMILE 

E-mail: httD:/hvww.arb.ca.e;ov/lispub/comm/bclist.~hv 

Fax:. (91 6) 322-3928 

Linda C. Muchison, Chief 

Planning and Technical Support Division 

California Air Resources Board 

1001 I Street, P.O. Box 2815 

Sacramento, CA 95812 

Re: Valero Benicia Refiery 's Comments on the Proposed California Regional Haze Plan 

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 

Protection Agency's ("EPA") Regional Haze Rule (the '$Regional Haze Rule") (40 CFR Part 51, Subpart 

P; §§ 5 1.300 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 1 5,2008. 

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 of the 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 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 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 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 of the 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. 

hicia Rdnory Volero Refining ComponyColifornia 

3400 East Second Street Benicio, Colifornio 945 10-1 097 Telephone (707) 745-70 1 1 Facsimile (7071 74575 14 
Linda C. Murchison, Re: Valero Benicia Refinery's Comments on the Proposed California Regional 

Haze Plan 

Janllary 2 1,2009 

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 determination that the Benicia Refinery requires additional 

controls is incorrect. As the letter notes, the "District 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 qualify as BART-level controls. The District's letter 

also makes clear that "[a]dditional emission control projects 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 appreciates the clarifications made 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 demonstrate that 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 strong recommendation 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 CARE3 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 postprocessing. 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 &fault 10 ppb that CARB used. With these two important 

refinements (i.e., using the new IMPROVE equation along with updated ammonia background values), 

AECOM estimates that 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 98m percentile 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 Reyes 
Linda C. Murchison, Re: Valero Benicia Refinery's Comments on the Proposed Calijbrnia Regional 

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 controlling year, 2000, available to CARB staff upon 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, § 1 .A., p. D-5). The evaluation nevertheless seems 

to conclude that despite this cost, the calculated 0.476 deciview improvement in visibility expected if the 

Main Stack scrubber is required, would be justified. (See Proposed Plan, App. D, 5 1.G.. p. D-7). The 

District's January 15,2009 letter indicates that 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 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 for the compelling reasons discussed above, Valero remains committed to implementing 

emission controls consistent with its Consent Decree requirements. 

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: Valero Benicia Refinery's Comments on the Proposed California Regional 

Haze Plan 

January 2 1,2009 

Page 4 

Karen Magalieno, CARB 

Tina Suarez-Murias, CARB 
RESPONSES TO 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 in Valero's Consent 

Decree with the EPAIDOJ, meet or exceed BART requirements. 

Attached is a revised Table 5-4 for the final Plan. Only limits for the 

"main stack" (coker, FCCU, 2 CO boilers) are proposed to be considered 

for the purposes of the BART determination. The NOx BART level 

referenced in the current draft Plan is incorrect. The basis for the 

revised NOx limit is existing federally-enforceable condition number 

11030, part 3. The basis for the SO2 limits is the 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 Plan for 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 used that 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 the draft Plan 

and prepare detailed comments because it was not available until one 

week before the public workshop. Valero requested a meeting with 

CAR6 staff to discuss their concerns. 

Response: The draft Plan was released to 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 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 1 of 4 
RESPONSES TO PUBLIC COMMMENT LETTERS 

on CALIFORNIA REGIONAL HAZE PLAN 

Valero Refinerv (January 21, 2009 letter) 

I. Comment: Valero generally supports the draft Plan. As the only facility 

in California requiring a 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 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 in the letter from 

BAAQMD dated January 15, 2009, and anticipates that CARB will not 

require further BART-level controls at the refinery because, according to 

BAAQMD, "...existing regulatory requirements, along with emission 

limits on core process units in Valero's Consent Decree with 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 on the 

"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 in the CalPuff processing until recently due to the 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 10ppb that 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 a 40% reduction in the 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 in the 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 PMI 0lPM2.5 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 with the cost-benefit analysis prepared 

by the BAAQMD in the draft Plan "Appendix D - District BART 

Determination". Valero wants to emphasize that a calculated costeffectiveness of $202 miIlion/deciviewlyear cannot possibly be 

considered cost-effective for the visibility improvements achieved by 

improving the "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 in the 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 of the 

Benicia Refinery as subject to the requirement to do a BART analysis 

and then apply BART is incorrect and that the Regional Haze Plan 

should not include any BART-level controls applicable to the Benicia 

Refinery. Nevertheless, Valero remains committed to 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'S modeling 

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