### OCTOBER 22, 2013 RESPONSE TO COMMENTS AIR POLLUTION CONTROL DISTRICT BOARD HEARING



### Errata - Oct 21, 2013 Comments #7 and #8 Additional comments after Board package submittal 

### COMMENT FROM COMMENT RESPONSE Comment 7 (Letter) 

### California Air Resources Board - Patrick Au No Comment

While CARB had no comments after their review the response indicates that the rules were examined by the following ARB divisions: Enforcement, Monitoring and Laboratory, and Stationary Source. Comment noted

Comment 8 (E-mail) 

### United States Environmental Protection Agency - Andrew Steckel Comment 1 Commenter requested a consideration by the Air District to lower emissions limits in Section C of Rule 400.3. To help in the consideration US EPA references San Joaquin Valley Rule 4702, Feather River Rule 3.22 and CARB's "Determination of Reasonable Available Control Technology and Best Available Retrofit Technology for Stationary Spark-Ignated internal Combustion Engines" The Air District reviewed the rules reference and the document from CARB. Feather River Rule 3.22 and Placer County Rule 242, whose designation for Ozone is similar to Imperial County were used as models and have the same emission limits as proposed in Rule 400.3. Both of these rules were recommended by US EPA as models.

### OCTOBER 22, 2013 RESPONSE TO COMMENTS AIR POLLUTION CONTROL DISTRICT BOARD HEARING



### Errata - Oct 21, 2013 Comments #7 and #8 Additional comments after Board package submittal 

### COMMENT FROM COMMENT RESPONSE Comment 8 (E-mail) 

### United States Environmental Protection Agency - Andrew Steckel Comment 2 Commenter requested that section D.1 of Rule 400.4 be elimated or revised to be consistent with national policy referenced as 78 FR 12460 (February 22, 2013) The Air District reviewed Federal Register Volume 78 No. 36 dated Friday, February 22, 2013 (FR). Generally, the US EPA reviewed SIP provisions from 39 different States and either granted, partially granted, partially denied or denied petitions on the basis that "each state's SIP" was substantially inadequated to meet Clean Air Act (CAA) requirements because they are inconsistent with CAA requirements with regard to how the state treats excess emissions from sources during periods of startup, shutdown, and malfunction. Generally, US EPA states throughout the FR that SIP's must contain emission limitations that are continuous and any excess emissions above the limitation is a violation regardless of the phase of the operations such as startup, shutdown, malfunction or maintenance. The Air District utilized 7 primary points to help bring Rule 400.4 into consistency with CAA requirements. The 7 poins are listed below as EPA presented them. In addition, Rule 400.4 was revised to reflect the changes as indicated in the response in blue. Please see attached revised rules. This Errata sheet is being made as part of the staff report.

### OCTOBER 22, 2013 RESPONSE TO COMMENTS AIR POLLUTION CONTROL DISTRICT BOARD HEARING



### Errata - Oct 21, 2013 Comments #7 and #8 Additional comments after Board package submittal 

### COMMENT FROM COMMENT RESPONSE Comment 8 (E-mail) Continued 

### United States Environmental Protection Agency - Andrew Steckel Response Continued 

### Response continued

1.The revision must be limited to specific, narrowly-defined source categories using specific control strategies (e.g., cogeneration facilities burning natural gas and using selective catalytic reduction); Addessed in sections A.1 and A.2 2 . Use of the control strategy for this source category must be technically infeasible during startup or shutdown periods; Wallboard Kilns will comply with the limits in this rule by installing Low NOx burners. Compliance with the limits during startup episodes is infeasible due to Low NOx burners use excess oxygen during startup episodes (approximately 70 percent excess); therefore, the potential for NOx generation increases, specially, during the first part of startup episode. When the startup episode surpass 50 % of the range, the excess oxygen reduces and burners get in compliance with the limits. Same is true for shutdown episodes; however, the duration of the episode is shorter. 3 . The frequency and duration of operation in startup or shutdown mode must be minimized to the maximum extent practicable; Is the duration limit minimized? Please see D.1.a, D.1.b, and D.1.c, the period for startup and shutdown episodes had been reduced from 12 hours each to 2 hours and 15 min, respectively. In addition, the excess NOx emissions during these episodes had been limited to 60 ppm.

4. As part of its justification of the SIP revision, the state should analyze the potential worst-case emissions that could occur during startup and shutdown; The potential impact from excess NOx emissions for startups and shutdowns is analyzed during the review of an Authority to Construct application, through air modeling. 5 . All possible steps must be taken to minimize the impact of emissions during startup and shutdown on ambient air quality; Please see D.1.d. 6. At all times, the facility must be operated in a manner consistent with good practice for minimizing emissions, and the source must have used best efforts regarding planning, design, and operating procedures to meet the otherwise applicable emission limitation; and Please see D.1.e 7.The owner or operator's actions during startup and shutdown periods must be documented by properly signed, contemporaneous operating logs, or other relevant evidence. Please see E.1.