## Feather River Air Quality Management District Staff Report

2006 Reasonably Available Control Technology (RACT) Analysis for State Implementation Plan (SIP)

November 2006Executive Summary

The U.S. Environmental Protection Agency (E PA) published the Final Rule to implement the 8-Hour Ozone National Ambient Air Qu ality Standard—Phase 2 on November 29, 2005 (70 FR 71611). The Phase 2 Rule include s a new section which is the Code of Federal Regulations (40 CFR 51.912) that requires the nonattainment areas to submit a revision to the State Implementation Plan (SIP ) to meet the Reasonably Available Control Technology (RACT) requirements for volatil e organic compounds (VOC) and nitrogen oxides (NOx) in accordance with Sections 182(b) (2) and 182(f) of the federal Clean Air Act. This requirement is referred as th e RACT SIP. Two pa rts of the FRAQMD are designated nonattainment for the national ambi ent air quality standard (NAAQS) for 8- hour ozone: southern Sutter County as serious nonattainment and atop (>2,000 ft) of
Sutter Butte as nonattainment.

RACT requirements apply to all source cate gories for which the U.S. EPA has published a Control technique Guideline (CTG) document as well as all major sources of VOC and NOx. The District staff performed a RACT analysis on District permitted sources and District rules for all CTG categories and ma jor sources of VOC and NOx. As a result of this analysis, Staff has determined that th e District has fulfilled the requirements of RACT, as applicable to the 8-Hour ozone standard, for al l CTG source categories. The District staff also determines that there is no major source in the nonattainment areas within the FRAQMD.

Staff has prepared a revision to the Ozone SIP to satisfy the federal RACT requirements. The proposed SIP revisions includes: 1) nega tive declarations for major sources for which neither south Sutter nor atop of Su tter Buttes has such sources; 2) negative declaration for CTG source category for atop of Sutter Buttes for there is no any source; and 3) CTG source category analysis for gaso line service stations in south Sutter.

The District staff reviewed FRAQMD Rule s 3.8 Storage and Transfer of Gasoline and
3.12 Benzene Airborne Toxic Control Measur e—Retail Service Stations for their compatibility with RACT requirements for CT G source category and concluded: 1) both FRAQMD Rules 3.8 and 3.12 exempt low-use gaso line service stations; 2) both rules are compatible with CTG requirements for gaso line service stations ; and 3) it is not necessary for the FRAQMD to amend Ru le 3.12 to revoke exemptions on low-use gasoline service station due to its cost effectiveness.

2Introductions

RACT SIP

The U.S. Environmental Protection Agency (E PA) published the Final Rule to implement the 8-Hour Ozone National Ambient Air Qu ality Standard—Phase 2 on November 29, 2005 (70 FR 71611). The Phase 2 Rule include s a new section which is the Code of Federal Regulations (40 CFR 51.912) that requires the nonattainment areas to submit a revision to the State Implementation Plan (SIP ) to meet the Reasonably Available Control Technology (RACT) requirements for volatil e organic compounds (VOC) and nitrogen oxides (NOx) in accordance with Sections 182(b) (2) and 182(f) of the federal Clean Air Act. This requirement is referred as the RACT SIP.

RACT SIP must be submitted to U.S. EPA by California Air Resources Board (ARB) on
behalf of the local air districts and must fulfill 40 CFR 51 Appendix V completeness
criteria.

U.S. EPA’s letter to ARB, dated Marc h 9, 2006, stated the following necessary components in the RACT SIP:

• Describe efforts to identify all source categories within the District requiring RACT, including CTG sources (i .e., covered by an EPA Control Technique Guideline document) and major non-CTG sources.

• Submit negative declarations where there are no facilities (major or minor) within the District subject to a CTG.

• For all categories needing RACT, list the state/local regulation that implements RACT. It may also be he lpful to list the date EPA approved thee regulations as fulfilling RACT.

• Describe the basis for concluding that the regulations fulfill RACT. Documents useful in establishing RACT include CTGS, Alternative Control Techniques guidance (ACTs), Maximum Achievable Control Technology (MACT) standards, Ne w Source Performance Standards (NSPS), California Suggested Contro l Measures (SCM) and RACT/Best
Available Retrofit Control Tec hnology (BARCT) determinations, regulations adopted in other District s, and guidance and rules developed by other state and local agencies.

• If Districts use CAPCOA’s September 2003, Potential All Feasible Measures (AFM) Report to help demonstrate RACT, the RACT SIP should certify that local regulations are equivalent to AFM, justify the assumption that the AFM fulfilled RACT in 2003, and include some sort
of certification/demonstration that no additional control have become
more reasonable available since then.

Nonattainment Areas in the FRAQMD

Two parts of the FRAQMD are designated non attainment for the national ambient air quality standard (NAAQS) for 8-hour ozone : southern Sutter County as serious

3nonattainment and atop (>2,000 ft) of Sutter Butte as nonattainment. The southern Sutter County is bounded on the north by Subaco Road and Bear River, on the east by Placer County, on the south by Sacramento Count y, and on the west by Yolo County. The Feather River Air Quality Management Dist rict (FRAQMD) is located in Northern Sacramento Valley Air Basin which is bounded on the north and west by the Coastal Mountain Range and on the east by the southern portion of the Cascade Mountain Range and the northern portion of the Sierra Neva da Mountains. These mountain ranges reach heights in excess of 6000 feet with peaks rising much higher. This provides a substantial physical barrier to locally generated polluti on as well as that tr ansport northward on prevailing winds from the Sacramento Metropolitan area (N SVAB Air Quality Attainment Plan, 2003). The vast majority of FRAQMD’s population lives and works below 1000 feet sea level, which is often subjec ted to inversion layers that, coupled with geographic barriers and high summer temper atures, create a high potential for air pollution problem.

Source Identification

The FRAQMD staff reviewed the District’s ma ster database for permitted facilities in order to identify existing sources in south Sutter and atop of Sutter Buttes. The staff identified 26 permitted stationary sources in south Sutter and no source atop of Sutter Buttes. Table 1 presents permitted facilities in south Sutter, their permit ID number, business type, and their potential emissions of ozone precursors.

4Table 1. Permitted Facilities in South Sutter
Facility

ID Company Name Site City Source Type Potential THC
Emission

(TPY) Potential NOx
Emission

(TPY)

2113 Hamar Associates
LLC Akrnak Natural gas production 0.12 0.1

6003 Bianchi/Sills Dryer & Storage Elverta Rice dryer 0 0.1

6005 Pacific International Rice Mills, Inc. Robbins Rice dryer 1 3

6006 Catlett Warehouse Grove Rice dryer 0.05 1.16

6007 El Centro Storage Grove Rice dryer 0.01 0.2

6014 Sutter Basin Growers Cooperative Landing Rice/bean dryer 0.03 0.95

6017 Van Dyke’s Rice Dryer Inc. Grove Rice dryer 0.03 1.23

6019 Dana Bins Nicolaus Rice scalping 0 0

11037 Broesch Automotive Landing Auto body 1.4 0

14052 Perozzi’s 99 North Nicolaus Gas retail 0.73 0

16003 &

36055 Holt of California,

Inc. Grove Various equipment 5.75/0.02 5.81/0

20013 Trichert Readymix Grove Concrete batch 0.02 0.66

21016 Sutter Mutual Water
Co. Kirkville Gas private 0.12 0

21028 Sutter County— Trowbridge Nicolaus Gas private 0.99 0

23008 GTE-Robbins C.O.-
Verizon Robbins ICE genset 0.04 0.26

23009 WorldCom (Sacramento Junction) Elverta ICE genset 0.25 1.75

23014 360 Networks Robbins Amp Site Robbins ICE genset 0.03 0.28

23017 Level 3
Communications Robbins ICE genset 0.02 0.32

23032 Verizon WirelessRobbins Robbins ICE genset 0 0

23034 Verizon WirelessEast Nicolaus Nicolaus ICE genset 0.01 0.07

23035 Sysco Food Services of Sacramento, Inc. Grove ICE genset 0.17 3.42

23041 SBC/Pacific BellPleasant Grove Grove ICE genset 0.01 0.22

23043 SBC/Pacific BellEast Nicolaus East Nicolaus ICE genset 0.04 0.55

23071 Clear Channel Radio Grove ICE genset 0.08 1.04

23100 Western Wood
Fabricators Elverta ICE Fire pump 0 0.08

23121 New Cingular Wireless PCS, LLC Nicolaus Emergency
ICE 0.02 0.05

5Major Source Identification

According to the potential emissions demonstrated Table 1, there are no major sources existing in south Sutter. The FRAQMD Rule 10.1 D. 20 defines a major source as “ a major source for the affected pollutant if it em its or has the potential to emit an affected pollutant in quantities equal to or exceeding any of the following thresholds: For the SFNA portion of the FRAQMD—25 tons per year of nitrogen ox ides, 25 tons per year of reactive organic compounds, 100 tons per year of carbon monoxide, 100 tons per year of

PM 10

, or levels specified in the federal Clean Air Act of 1990, Section 112 (a)(1) .”

CTG Category Source Identification

There are seven different cate gories of facilities presented in Table 1, which are natural gas production, grain dryer, auto body shop, ga s service, concrete batch, internal combustion engines, and miscellaneous. Ta ble 2 presents CTG categories for non-major
sources and the source existence in south Su tter. According to Table 2, the only existing CTG category source in south Su tter is service stations (gasoline service stations).

6Table 2. CTG Categories That Are Applicab le to Minor Sources in South Sutter

CTG Category CTG Date FRAQMD Rule (Most Recent Amendment) FRAQMD Rule Requirements and Exemptions

Aerospace Manufacturing Dec. 1997 No source

Automobile Coating May 1977 No source Cutback Asphalt 1977 No source Dry Cleaning (Petroleum Solvent) Sep. 1982 No source

Gasoline Service
Stations Nov. 1975 FRAQMD Rule 3.8 Storage and Transfer of Gasoline (amended 06/1991)

FRAQMD Rule 3.12 Benzene
Airborne Toxic Control
Measure—Retail Service Stations (amended 06/1991) Rule 3.8: Requirements are compatible with Phase I Vapor Recovery System for new sources (exempts low-use)

Rule 3.12: Phase I Vapor Recovery System (exempts low-use retail gasoline service stations); Phase II Vapor Recovery System (exempts private and low use).

Gasoline Tank Trucks
and Bulk Plants Oct. 1977,
Dec. 1977 and
Dec. 1978 No source

Graphic Arts (Rotogravure) Dec. 1978 No source

Graphic Arts (Flexographic) Dec. 1978 No source

Large Appliance Coating 1977 No source

Magnetic Wire Coating Dec. 1977 No source

Metal Can Coating May 1977 No source

Metal Coil Coating May 1977 No source

Metal Furniture Coating Dec. 1977 No source

Metal Parts and Products Coating June 1978 No source

Natural Gas/Gasoline Processing Dec. 1983 No source

7Table 2. CTG Categories That Are Applicable to Minor Sources in South Sutter (Cont.)

CTG Category CTG Date FRAQMD Rule (Most Recent Amendment) FRAQMD Rule Requirements and Exemptions

Paper and Fabric Coating May 1977 No source

Petroleum Liquid Storage Tanks Dec. 1977 and
Dec. 1978 No source

Pharmaceutical
Products Manufacturing Dec. 1978 No source

Resin Manufacturing – High Density Polyethylene, Polypropylene, and Polystyrene Nov. 1983 and
Mar. 1984 No source

Refineries Oct. 1977 and
June 1978 No source

Rubber Tire Manufacturing Dec. 1978 No source

Ship Coating Aug. 1996 No source Solvent Cleaning (Degreasers) Nov. 1977 No source

Synthetic Organic
Chemical Manufacturing Mar. 1984, Dec. 1984 and Aug.
1993 No source

Wood Coating (Flat Wood Paneling) June 1978 No source

Wood Furniture Coating Apr. 1996 No source

Rule Analysis

The District Rules 3.8 Storage and Tran sfer of Gasoline (amended 06/1991, see Appendix A) and 3.12 Benzene Airborne T oxic Control Measure—Retail Service Stations (amended 06/1991, see Appendix B) are compatible with CTG requirements on Phase I Vapor Recovery System for both reta il and private gasolin e service stations. Both rules exempt low-use stations due to a high cost effectiveness.

8Appendix A.

FRAQMD RULE 3.8
STORAGE AND TRANSFER OF GASOLINE

9RULE 3.8 - STORAGE AND TRANSFER OF GASOLINE (Adopted 6/91)

a. Any person who installs any gasoline stor age tank with a capacity of 250 gallons or more which is not equipped with a permanent submerged fill pipe or other equipment referred to in this Rule is gu ilty of a misdemeanor. This provision does not apply to any storage tank which is used primarily for the fueling of implements of husbandry, as such vehicles are defined in Division 16 (commencing with Section 3600) of the Vehicle Code.

TRANSFER OF GASOLINE INTO STATIONARY STORAGE CONTAINERS

b.
1. A person shall not transfer or permit the transfer of gasoline from any delivery vessel (i.e., tank truck or trailer) into any stationary storage container with a capacity of more than 250 gallons unless 90% by weight of the vapors displaced from such transfer are prevented from being released to the atmosphere.

The provisions of this section shall be subject to the following exceptions:

a. The transfer of gasoline into any stationary storage container used primarily for the fueling of implements of husbandry as such
vehicles are defined in Division 16 (Section 3600 et seq.) of the
California Vehicle Code.
b. The transfer of gasoline into any stationary storage container in existence prior to date of adoption of this rule when such container is served by a delivery vessel exempted by the Air Pollution Control Officer pursuant to Section 3a of this Rule.

c. The transfer of gasoline into any stationary storage container in existence prior to adoption of th is regulation which is equipped with an offset fill pipe.
d. The transfer of gasoline into a ny stationary storage container installed prior to the effective date of this regulation for which the total monthly throughput of the facility does not exceed 25,000 gallons.
2. No person shall store gasoline in or ot herwise use or operate any gasoline vessel unless such vessel is designed to be vapor tight. Any delivery vessel into which gasoline vapors are required to be transferred shall be filled only at a loading facility that is equi pped with a system that prevents at least 90% by weight of the gasoline vapors displaced from entering the atmosphere.
3.

a. The owner or operator of any bulk loading facility which was in operation prior to the date of adop tion of this Rule and for which the annual throughput to stationary storage containers that are not

10exempted from Section 1a does not exceed 500,000 gallons, may petition the Air Pollution Control Officer to have the facility's delivery vessels and other indepe ndently owned gasoline delivery vessels which are exclusively serviced at such facility exempted from the provisions of Section 2. The owner and operator of such a facility must petition annually to renew such exemptions.
b. A person shall not load gasoline in to any delivery vessel from any loading facility granted an exempti on pursuant to Section 3a of this Rule unless such delivery vessel is loaded through a submerged fill pipe.
4.

a. For the purposes of the Rule, the term "gasoline" is defined as any petroleum distillate having a Reid Vapor pressure of 4 pounds or
greater. b. For the purposes of this Rule "gasoline vapors" means the organic compounds in the displaced vapor s including any entrained liquid gasoline.

c. For the purposes of this Rule, the term "submerged fill pipe" is defined as any fill pipe, the discharge opening of which is entirely submerged when the liquid level is 6 inches above the bottom of the container. "Submerged fill pipe " when applied to a container
which is loaded from the side is defined as any fill pipe the discharge opening of which is en tirely submerged when the liquid
level is 18 inches above th e bottom of the container.

TRANSFER OF GASOLINE INTO TANK TRUCKS, TRAILER, AND
RAILROAD TANK CARS AT LOADING FACILITIES

c. 1. A person shall not load gasoline into any tank truck, trailer, or railroad tank car from any loading facility having an annual throughput of 5,000,000 gallons or more unless the loading facility is equipped with a vapor collection and disposal system or its equivalent approved by the Air Pollution Control Officer. Loading shall be accomplished in such a manner that all displaced vapor and ai r will be vented only to the vapor collection system. Measures shall be taken to prevent liquid from the loading device when it is not in use or to accomplish complete drainage before the loading device is disconnected.
2. The vapor disposal portion of the vapor collection and disposal system shall process all vapors and reduce th e emission of gasoline vapors by at least 90% by weight of uncontrolled emissions.

STORAGE OF GASOLINE PRODUCTS AT TERMINALS AND LARGE
BULK LOADING FACILITIES

d.

111. A person shall not place, store or hold in any stationary tank, reservoir or other container of more than 40,000 ga llons capacity gasoline unless such tank, reservoir or other container is a pressure tank ma intaining working pressures sufficient at all time to prev ent gasoline vapor or gas loss to the atmosphere, or is designed and equipp ed with one of the following vapor loss control devices, properly inst alled, in good working order and in operation.

a. A floating roof of an approved type. The Control equipment provided for in this paragraph shal l not be used if the gasoline has a vapor press of 11.0 pounds per square inch absolute or greater under actual storage conditions. All tank gauging and sampling devices shall be gas tight excep t when gauging of sampling is taking place.
b. A vapor recovery system, of effi ciency equivalent to a floating roof meeting the requirements of a) above, consisting of a vapor gathering system capable of co llecting the gasoline vapors and gases discharged, and a vapor disposal system capable of processing such gasoline vapors a nd gases so as to prevent their emissions to the atmosphere and with all tank gauging and sampling devices gas tight excep t when gauging or sampling is taking place.

c. Other equipment of equal efficiency, provided such equipment is submitted to and approved by the Air Pollution Control Office(should have criteria to determine the efficien cy).

12Appendix B.

FRAQMD Rule 3.12
BENZENE AIRBORNE TOXIC CONTRO L MEASURE - RETAIL SERVICE
STATIONS

13RULE 3.12 - BENZENE AIRBORNE TOXI C CONTROL MEASURE - RETAIL
SERVICE STATIONS (Adopted 6/91)

a. Phase I Vapor Recovery System Requirements:
1. No owner or operator sh all transfer, permit the transfer, or provide equipment for the transfer of gasolin e, and no other person shall transfer gasoline from a delivery tank equipped with a vapor recovery system into a stationary storage tank at a retail service station unless an ARB Certified Phase I vapor recovery system is in stalled on the stationary storage tank and used during the transfer.
2. The provisions of subsection a.1., shall not apply to:

a. A transfer to a stationary storage tank with a capacity of less than 1.0 cubic meter (260 gallons).
b. A transfer to a stationary storage container used the majority of the time for the fueling of implements of husbandry as defined in Division 16, Chapter 1, of the Vehicle code.

c. A transfer to a stati onary storage tank used exclusively to fuel motor vehicles with a fuel capacity of five gallons or less.
d. An existing retail service station with an annual station gasoline throughput from tanks or other than those described in subsections a.2.a), a.2.b.), and a.2.c)., of 480,000 or fewer gallons during the calendar year prior to district a doption of this ru le. If during any calendar year thereafter the gasoli ne throughput from such tanks at the existing retail service station exceed 480,000 gallons, this exemption shall cease to apply co mmencing with the first day of the following calendar year.

e. A transfer to a stationary storage tank at an existing retail service station which receives gasoline exclusively from delivery tanks that are not required to be equippe d with vapor recovery systems.
3. Notwithstanding subsection a.2.d)., at th e time of tank replacement at an existing retail service st ation, ARB Certified Ph ase I vapor recovery systems shall be installed and used thereafter on all of the station facilities, except those which are exempt fr om the Phase I requirement by subsections a.2.a)., a.2.b)., and a.2.c)., or a.2.e).
b. Phase II Vapor Recovery System Requirements:
1. No owner or operator sh all transfer, permit the transfer, or provide equipment for the transfer of gasoline from a stationary storage tank at a
retail service station into a moto r vehicle fuel tank unless an ARBcertified Phase II vapor recovery syst em is installed and used during the
transfer.
2. The provisions of subsection b.1. shall not apply to:

a. A transfer of gasoline from a st ationary storage tank which is exempt from Phase I under subsec tion a.2.a)., a.2.b)., or a.2.c).
b. An existing retail service station which is exempt from Phase I requirements under subsection a.2.d).

143. Notwithstanding subsection b.2.b.)., at th e time of tank replacement at an existing retail service st ation, ARB Certified Ph ase II vapor recovery system shall be installed and used ther eafter on all of the station facilities, except those which are exempt fr om the Phase II requirement by subsection b.2.a.).

c. Correction of Defects: No owner or oper ator shall use or permit the use of any Phase II system or any component thereof containing a defect identified in Title 17, California Code of Regulations, S ection 94006 until it has been repaired, replaced, or adjusted, as necessary to remove the de fect, and, if required under Health and Safety Code Section 41960.2, district personnel have inspected the system or have authorized its use pendi ng reinspection. Nothing in this subsection shall excuse compliance with subsection b.1.
d. Compliance Schedule: For purposes of this rule, the following compliance schedule shall apply:
1. The owner or operator of any new retail service station subject to this section shall comply with the provisions of this rule at the time gasoline is
first sold from the station.
2. The owner or operator of an existi ng retail service station without ARBCertified Phase I and II vapor recovery system shall notify the Air Pollution Control Officer in writing in advance of an intended tank replacement and secure all permits and other approvals necessary for installation of Phase I and II vapor recovery systems. The owner or operator of an existing retail serv ice station shall comply with the provisions of this rule upon completion of the tank replacement.
3. The owner or operator of an existing re tail service station subject to this rule, who has not earlier complied in accordance with subsection d.2., shall within 15 months after district adoption of this rule secure all permits and other approvals necessary for instal lation of the equipment required by this rule. The owner or operator shall comply with the provisions of this
rule within 24 months after di strict adoption of this rule.
4. Excluding those existing reta il service stations subject to this rule as a result of tank replacement, the owne r or operator of a previously exempt stationary storage tank or retail se rvice station wher e the operation or annual throughput has changed such th at the exemption from either the Phase I or II requirements or both is no longer applicable, shall comply with the rule's provisions in accordance with subsection d.3., above, provided that the first day the retail service station or stationary storage tank is no longer exempt shall be cons idered as the date of district adoption of this rule.

15