UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX AIR DIVISION

Technical Support Document for t he EPA ’ s Notice of Proposed Rulemaking for the California State Implementation Plan

The EPA ’ s Evaluation of

Antelope Valley Air Quality Management District, 2015 8

- Hour Reasonably Available Control Technology

– State Implementation Plan Analysis ( 2015 RACT SIP Analysis)

- Adopted Ju ly 2 1 , 201 5

“ 201 5 RACT SIP TSD ”

Prepared by: Ja mes Shears and Stanley Tong Reviewed by: Andrew Steckel

November 2016- 2

- RULE IDENTIFICATION

-
Agency: Antelope Valley Air Quality Management District ( AV AQMD)

SIP Approved Version : There is no previous SIP approved AVAQMD RACT SIP for the 2008 8

- hour ozone standard or for the 1997 8

- hour ozone standard. 1

Subject of this TSD: AV AQMD 8

- Hour Reasonably Available Control Technology

– State Implementation Plan Analysis ( 2015 RACT SIP Analysis) Adopted

– Ju ly 2 1 , 201 5 Submitted

– October 23 , 20 1 5

Completeness Finding: Determination of Completeness letter: March 9, 2016

BACKGROUND

-
Volatile organic compounds (VOC) and nitrogen oxides (NOx) in the presence of sunlight can lead to the formation of ground

- level ozone or “ smog ” which can result in significant impacts to human health and the environment

. Section 182 of the Clean Air Act ( CAA) requires areas that are classified as moderate or above for ozone nonattainment to implement reasonably available control technology (RACT) for specific types of sources. The Antelope Valley Air Quality Management District ( AV AQMD) falls under this re quirement as the District is classified

as a severe

- 15 ozone nonattainment area for the 2008 ozone standard ( May 21, 2012 77 FR 30088 at 30100).

Under CAA § 182(b)(2) and (f), AV AQMD must, at a minimum, adopt RACT level controls for sources covered by a Control Techniques Guidelines (CTG) document and for any major stationary source of VOC or NOx

. The EPA defines RACT as the “ lowest emissions limitation that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility. ” 44 FR 53761 (September 17, 1979)

. A RACT analysis should, therefore, take into account the technological and economic feasibility of controls, and may differ from source to source and location to location.

SUBMITTAL SUMMARY

–
The District adopted its RACT SIP certification for the 2008 ozone standard on Ju ly 2 1 , 201 5 and the California Air Resources Board (CARB) submitted it to the EPA on October 23, 201 5

. AV AQMD performed its RACT SIP analysis based on an ozone non

- attainment classification

1 On January 31, 2007, AVAQMD submitted its 2006 RACT SIP certification for the 1997 8

- hour ozone standard. The 2006 RACT SIP is being evaluated in a separate TSD . EPA will act on both the 2006 RACT SIP and 2015 RACT SIP submittals in a single rulemaking action.- 3

- of “severe

- 15” . This classification defines a major source as those facilities that e mit or have the potential to emit at least 25 tons per year (tpy) of VOC or NOx. See CAA Sections 182(b)(2)(C), 182(f), and 302(j).

AV AQMD’s submittal included the following documents:

a. “ 8

- Hour R easonably Available Control Technology

– State Implementation Plan Analysis (RACT SIP Analysis) ”, dated July 201 5 [hereinafter “ 20 1 5 RACT SIP ” ]

.

b. “Final Staff Report

– Adoption of the 2015 8

- Hour Reasonably Available Control Technology

– State Implementation Plan Analysis (2015 RACT SIP Analysi s)”, dated July 21, 2015.

c. “Final Staff Report

– Adoption of the Federal Negative Declarations for Twenty Control Techniques Guidelines Source Categories ”, dated July 21, 2015.

d. Resolution 15

- 05, “A Resolution of the Governing Board of the Antelope Valley Air Quality Management District Making Findings, Certifying the Notice of Exemption, Adopting the 2015 8

- Hour Reasonably Available Control Technology

– State Implementation Plan Analysis (2015 RACT SIP Analysis) and Directing Staff Actions”, dated July 21, 2015.

e. Resolution 15

- 04, “A Resolution of the Governing Board of the Antelope Valley Air Quality Management District Making Findings, Certifying the Notice of Exemption, Adopting the Federal Negative Declarations for Twenty Control Techniques Guidelines S ource Categories and Directing Staff Actions”, dated July 21, 2015.

AV AQMD’s analysis included the following areas. Further discussion is provided below.

• Review of its previous RACT analysis for the 1997 8

- hour ozone standard (“ 200 6 RACT SIP ”) along with its March 13, 2014 supplement (“2014 Supplemental Analysis”)

• Further e valuation of selected AV AQMD Rules and Regulations

• M ajor sources identified

• Negative declarations

EPA EVALUATION

– The EPA evaluated t he following elements of AV AQMD ’ s 201 5 RACT SIP :

• The bases for concluding l ocal rules implement RACT

• Efforts to identify major non

- CTG source s of VOC or NOx within the District

• N egative declarations where there are no facilities subject to a CTG

T he following documents were also used to support our review:

• “ Final Rule to Implement the 8

- Hour Ozone National Ambient Air Quality Standard

– Phase 2 ” (70 FR 71612; November 29, 2005).

• “ State Implementation Plans, General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990 ” ( 57 FR 13498; April 16, 1992).- 4

- • Enforceability

- Section 110(a) of the CAA requires enforceable emission limitations and other control measures. Several EPA guidance documents are used to evaluate rule enforceability, including “ Issues Relating to VOC Regula tion Cutpoints, Deficiencies, and Deviations

, ” EPA, M ay 25, 1988 (The Blue Book), and “ Guidance Document for Correcting Common VOC & Other Rule Deficiencies, ” EPA Region 9, August 21, 2001 (the Little Bluebook).

• “ State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990 ” (57 FR 55620, November 25, 1992) ( “ the NOx Supplement ” ).

• Memorandum from William T. Harnett to Regional Air Division Directors, (May 18, 20 06),

“ RACT Qs & As

– Reasonably Available Control Technology (RACT) Questions and Answers ”

.

• RACT SIPs, Letter dated March 9, 2006 from EPA Region IX (Andrew Steckel) to CARB (Kurt Karperos) describing Region IX ’ s understanding of what constitutes a minimal ly acceptable RACT SIP.

• Letter dated April 4, 2006 from EPA Region IX (Andrew Steckel) to CARB (Kurt Karperos) listing the EPA ’ s current CTGs, ACTs, and other documents which may help to establish RACT.

• “ Implementation of the 2008 National Ambient Air Qual ity Standards for Ozone: State Implementation Plan Requirements’’ (80 FR 12264; March 6, 2015).

• EPA ’ s CTGs and ACTs : https://www.epa.gov/ozone

- pollution/control

- techniques

guidelines

- and

- alternative

- control

- techniques

- documents

- reducing

• CARB ’ s emissions inventory database http://www.arb.ca.gov/app/emsin v/facinfo/facinfo.php

• AV AQMD , CARB

, and EPA Region IX databases of AV AQMD rules AV AQMD : http://avaqmd.ca.gov/rule

- book CARB: http://www.arb.ca.gov/rldb/rldb.htm EPA: http://www.epa.gov/approved

- sips/approved

- sips

- region

- 9

The following summarizes AV AQMD actions to address RACT requirements and the EPA ’ s evaluation of those actions.

1. Bases for Concluding Local Rules Implement RACT

RACT is required for source categories covered by an EPA Control Techniques Guidelines document ( “ CTG sources ” ) and all sources that are not covered by a CTG document but are

“ major sources ” (i.e., for AV AQMD, “ non

- CTG sources ” that emit or have the potential to emit at least 25 tons per year of VOCs or NOx )

.

AV AQMD action : 2015 RACT SIP, 2006 RACT SIP and 20 14 Supplemental Analysis

AV AQMD’ s 2015 RACT SIP states that the original 2006 RACT SIP Analysis (for the 1997 8

- hour ozone standard), together with the supplemental March 13, 2014 RACT SIP Analysis, and the 2015 RACT SIP represent a current and complete RACT SIP Analysis document to satisfy the District’s RAC T obligation for the 1997 and 2008 8

- hour ozone- 5

- standards. 2 T he 2006 RACT SIP and 2014 S upplemental A nalysis are evaluated in a separate TSD.

In its 2015 RACT SIP , Appendix A , AVAQMD examined 14 rules

, 1 1 of which regulate VOCs and are cover ed by CTGs. T he remaining three rules regulate NOx emissions

. The District indicated that for four of the 11 VOC categories, it d id not h ave sources that met the CTGs’ applicability threshold and therefore wer e not subject to RACT

. These categories

were:

• Rule 463, Storage of Organic Liquids (3/11/94)

• Rule 1102, Petroleum Solvent Dry Cleaners (12/7/90)

• Rule 1104, Wood Flat Stock Coating Operations ( 3/1/91 3 )

• Rule 1176, VOC Emissions from Wastewater Systems ( 5/13/94 4 )

The District also states in Appendix A that it “..will not file a [ Federal Negative Declaration ] at this time but will update the rule to current Federal RACT when a source is acquired.” 5

Five o f the remaining seven VOC rules were identified by the District as needing to be updated for RACT . The 2015 RACT SIP states, in part :

• Rule 462, Organic Liquid Loading (6/9/95) : to be amended to address deficiencies identified in EPA’s Proposed Rule: limited approval/disapproval ( 62 FR 26460

, May 14, 1997)

. 6

• Rule 1107, Coating of Metal Parts and Products (3/8/96) : the rule is consistent with the 2008 CTG, but several VOC coating limits are less stringent than South Coast Air Quality Management District (SCAQMD) Rule 1107 (1/6/06) , and thus, should be amended to meet RACT.

• Rule 1145, Plastic, Rubber and Glass Coatings ( 1/10/92 : the rule has several VOC coating limits that are less stringent than SCAQMD Rule 1145 (12/4/09) and needs update s to its d efinitions , transfer efficiency

, a nd test methods sections

.

2 AVAQMD RACT SIP Analysis, page 1, July 2015.

3 Rule 1104 (Amended 3/1/91) was approved into the SIP on 6/23/94 (59 FR 32354).

4 Rule 1176 (Amended 5/13/94) was approved into the SIP on 8/25/94 (59 FR 43751)

.
5 2015 RACT SIP Appendix A, pgs A

- 4, A

- 5, and A

- 6. For Rule 1176, Appendix A, pg A

- 16 indicates a negative declaration was previously adopted for the 1997 8

- hour ozone stand ard. See 76 FR 38572 , July 1, 2011.

6 Antelope Valley was formed from South Coast AQMD in July 1997. We proposed approval a limited approval/disapproval of SCAQMD Rule 462 on Ma y 14, 1997, prior to the separation of AVAQMD from SCAQMD. Our final rulemaking action on Rule 462 was published on November 13, 1997 ( 62 FR 60784 ), after Antelope Valley separate d from SCAQMD and stated the final action was for SCAQMD and excluded Antelope Valley.- 6

- • Rule 1151, Motor Vehicle and Mobile Equipment Coating Operations (6/19/12) : the rule must be amended to incorporate provisions of the Control Techniques Guidelines for Automobile and Light

- Duty Truck Assembly Coating as applicable to “Heavier” vehicles, which includes all vehicles that meet the definition of the term “other motor vehicles”, as defined at 40 CFR 63.3176. The 2015 RACT SIP states that BYD Coach and Bu s is not a major source but its operating permit allows VOC emissions above the applicability threshold for the 2008 CTG for Automobile and Light Duty Truck Assembly Coatings.

• Rule 1171, Solvent Cleaning Operations (11/17/98) : the rule needs to be update d to include work practices, adjust categories for consistency with source specific rules, and include an alternative composite vapor pressure limit.

AVAQMD concluded that these remaining two VOC rules do not need updating at this time :

• Rule 1106.1, Pleasure Craft Coating Operations (6/13/97)

• Rule 1141.1, Coatings and Ink Manufacturing (3/6/92)

AVAQMD’s evaluation of the three NOx rules is summarized in section 3 below.

EPA Evaluation

We revi ewed AVAQMD’s analysis of the 11 VOC rules . B ased on a review of CARB’s emissions inventory, we agree with the District ’s conclusion that it does not currently have sources subject to the CTGs covered by Rules 463, 1102, 1104, and 1176.

• Rule 463, Storage of Organic Liquids (3/11/94)

o EPA 450/2

- 78

- 04 7

, Emissions from Petroleum Liquid Storage in External Floating Roof Tanks

o EPA 450/2

- 77

- 036

, Control of Volatile Organic Emissions from Storage of Petroleum Liquids in Fixed Roof Tanks

• Rule 1102, Petroleum Solvent Dry Cleaners (12/7/90)

o EPA

- 450/3

- 82

- 009, Control of Volatile Organic Compound Emissions from Large Petroleum Dry Cleaners

• Rule 1104, Wood Flat Stock Coating Operations ( 3/1/91 ) 7

o EPA 450/2

- 78

- 032

, Control of Volatile Organic Compounds Emissions from Existing Stationary Sources Volume VII: Factory Surface Coating of Flatwood Paneling

o EPA

- 453/R

- 06

- 004

, Control Techniques Guidelines for Flat Wood Paneling Coatings

• Rule 1176, VOC Emissions from Wastewa ter Systems ( 5/13/94 )

o EPA 450/2

- 7 7

- 0 25, Control of Refinery Vacuum Producing Systems, Wastewater Separators, and Process Unit Turnarounds

We reviewed AVAQMD’s analysis of five of the remaining seven VOC rules that need to be updated to meet RACT. Our eval uation follows:

7 AVAQMD’s 2015 RACT SIP, Table 2 lists the 2008 Flat Wood Paneling CTG as a negative declaration but does not list the 1978 Flat Wood CTG. Conversely, Appendix A, item 4 Wood Flat Stock Coating Operations states it does not have any sources that meet the CTG applicability threshold for the 1978 CTG, but does not mention the 2008 Flat Wood CTG.- 7

- • Rule 462, Organic Liquid Loading : we concur that this rule needs to be updated to revise the definition of “facility vapor leak” to remove the two centimeter measurement distance to be consistent with EPA Method 21 and to meet RACT. Action

- R evise rule to implement RACT

• Rule 1107, Coating of Metal Parts and Products : AVAQMD’s RACT SIP states that the VOC limits in Rule 1107 is consistent with the 2008 Miscellaneous Metal and Plastic Parts Coatings CTG , but several VOC limits are less stringent than SCAQMD Rule 1107 Coating of Metal Parts and Products (1/6/2006)

. We reviewed Rule 1107 and concluded it implements RACT by meeting the 2008 CTG and conclude the more stringent limits in SCAQMD Rule 1107 to be beyond RACT. 8

However, we find that Rule 1107 does not contain VOC limits for can coating operations which are found in the 1977 CTG for Surface C oating of C ans, C oils, P aper, Fabrics A utomobiles, and Li ght

- D uty T rucks ; nor does it contain VOC limits for drum coating operations which are found in the 2008 CTG for Miscellaneous Metal and Plastic P arts C oatings . Specifically, page iv of the 1977 CTG lists VOC limits for can coating operations and Table 2 of the 2008 CTG lists recommended VOC limits for drum coatings but AVAQMD Rule 1107 states it does not apply to metal containers (e.g., drums). We therefore conclude that AVAQMD does not currently regulate can or drum coating operations and does not have a negative declaration for the 2008 8

- hour ozone standard for these coating categorie s.

We note that can and drum coatings were previously covered under AVAQMD Rule 1125 Metal Container, Closure, and Coil Coating Operations. On February 17, 2004, AVAQMD rescinded Rule 1125 and at the same Board Action, adopted a negative declaration certi fying it had no sources regulated by Rule 1125. The EPA approved AVAQMD’s rescission and negative declaration for can and drum coatings in 2004. 9 AVAQMD should adopt a negative declaration for can coating operations for the 1977 CTG under the 2008 8

- hour ozone standard. 10

8 SCAQMD Rule 1107’s VOC limits for three categories (general, extreme hi gh

- gloss, and pre

- fabricated architectural

- for air dried coatings) are more stringent than the identical categories in EPA’s 2008 CTG for Miscellaneous Metal and Plastic Parts Coatings. We reviewed the metal coating rules from 11 California air districts and found that where the air district regulated the general, extreme high

- gloss, or pre

- fabricated architectural coating categories, its limits were identical to the limits in the 2008 CTG and none of the 11 air districts had adopted SCAQMD’s more stringe nt VOC limits. EPA generally considers controls that have been achieved in practice by a significant number of sources to be technologically and economically feasible, and therefore concludes SCAQMD Rule 1107’s more stringent limits for these three categor ies to be beyond RACT.

9 See 69 FR 56355 (September 21, 2004).

10 Our TSD for the 1997 ozone standard also recommends AVAQMD adopt a negative declaration for the 1997 8

- hour ozone standard for can coating operations subject to EPA

- 450/2

- 77

- 008, Control of Volatile Organic Emissions from Existing Stationary Sources

– Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light

- Duty Trucks.- 8

- Action

- AVAQMD should evaluate adopting , for the 2008 8

- hour ozone standard, a negative declaration for the can coating portion of the 1977 CTG: EPA

- 450/2

- 77

- 008

, Control of Volatile Organic Emissions from Existing Stationary Sources

– Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Aut omobiles, and Light

- Duty Trucks

. AVAQMD should also evaluate adopting a negative declaration for the drum coating portion of the 2008 CTG: EPA 453/R

- 08

- 003 , Control Techniques Guidelines for Mi scellaneous Metal and Plastic Parts Coatings

, or incorporate the applicable can/drum VOC limits into a SIP rule

.

• Rule 1145, Plastic, Rubber and Glass Coatings : We find that the VOC limits for plastic parts coatings in Rule 1145 is consistent with Table 3 of the 2008 CTG for Miscellaneous Metal and Plastic Parts Coatings with the exception that Rule 1145 does not have a category for “Extreme Performance

– 2 pack coating s”

. We interpret the Extreme Performance category would therefore fall under Rule 1145’s G eneral Coatings category for two component coatings, which is consistent with the CTG’s limit of 420 g/L

. EPA does not have a CTG for rubber or glass coatings. No further action is required for RACT.

• Rule 1151, Motor Vehicle and Mobile Equipment Coating Operations : the EPA concurs that BYD Coach and Bus is not currently a major source of VOC o r NOx. BYD Coach and Bus started operations in Antelope Valley in 2013. A review of CARB’s emissions inventory for 2014 does not show this facility. 11

Rule 1151 appl ies to the refinishing of automobil es and not to coating of new vehicles . Based on the District’s statement that BYD Coach’s permit allows it to exceed the applicability threshold of the 2008 CTG for Automobile and Light

- Duty Truck Assembly Line Coatings, Rule 1151 will either need to be amended or a new rule adopted to implement RACT for this category.

Action

- AVAQMD should amend Rule 1151 or adopt a new rule to incorporate VOC RACT coating limits for new heavier duty vehicles and, as applicable, VOC content limits from the 2008 CTG for Miscellaneous Metal and Plastic Parts Coatings, Table 6 Motor Vehicle Materials

.

• Rule 1171, Solvent Cleaning Operations : we concur that this rule does not completely implement the 2006 CTG for Industrial Cleaning Solvents and should be revised to include work practices, VOC limits, and other items to implement RACT.

11 BYD Motors Inc. appears to have started production in Lancaster, CA in the Spring of 2013. See http://sfvbj.com/news/2015/sep/08/byd

- contract

- brings

- more

- bus

- building

- lancaster/

. AVAQMD states that BYD had total VOC emissions of 1.789 tons in 2015, which is below the CTG. See S. Detwiler ( CARB) email to S

. Tong (EPA), November 8, 2016, RE : VOC / NOx emissions for BYD Motors, Lancaster, CA?- 9

- Action

- AVAQMD should amend Rule 1171 to implement RACT.

We reviewed the two rules listed above that AVAQMD con cluded do not need to be updated at this time to implement RACT

. Our evaluation follows:

• Rule 1106.1, Plea sure Craft Coating Operations: we concur that this rule implements RACT, but recommend the next time the rule is o pened, that the compliance test methods be update d to reflect the latest methods as shown in SCAQMD Rule 1106

. 1, section (e)(1) (64 FR 47392, August 31, 1999)

.

• Rule 1141.1, Coatings and Ink Manufacturing: this is not a CTG category and based on reviewing CARB’s emissions inventory, AVAQMD does not have a coatings and ink manufacturing facility that is a major source of VOC. Rule 1141.1 contains work practices to minimize VOC emissions.

2. Efforts to Identify M ajor non - CTG sources of VOC or NOx within the District

AV AQMD action:

AV AQMD ’s 2015 RACT SIP , Table 1, lists five facilities that are major sources that emit or have the potential to emit (PTE) at least 25 tons/year of VOC or NOx. The 2015 RACT SIP states that t wo of these facilities, Antelope Valley Public Landfill and Lancaster Landfill and Recycling Center, do not emit a large amount of reactive VOCs, and therefore are not major sources of ozone precursors. Northrup

- Grumman and Lockheed Martin Skunk Works are major VOC sources, and Wm. Bolthouse Farms is a major source of NOx.

E PA evaluation:

We reviewed CARB’s 2010

- 2014 emissions inventory for Antelope Valley Public Landfill and Lancaster Landfill and Recycling Center and agree that actual VOCs are signi ficantly less than 25 tons/year. Maximum actual VOC emissions from the Antelope Valley Public Landfill for 2010

- 2014 was 7.2 tpy and for the Lancaster Landfill and Recycling Center it was 2.6 tpy

. As indicated by AVAQMD 12 , approximately 95% of the VOC P TE emissions at Northrup

Grumman and Lockheed Martin Skunk Works are controlled by Rule 1124, Aerospace and

12 T. Walters (AVAQMD ) email to J. Shears (EPA), April 19, 2016

, FW: AV RACT SIP more questions

. Northrup

Grumman ’s 2014 emissions was 20.6 tpy and Lockheed Martin was 16.8 tpy VOC . AVAQMD stated approximately 95% of the VOC PTE emissions are controlled by Rule 1124. The remai ning 5% represents approximately 1 tpy. Since EPA’s CTGs generally have an applicability threshold of 2.7 or 3 tpy, we conclude the remaining approximately 1 tpy is not likely to be subject to RACT controls and therefore did not further investigate these e missions. We also note that several VOC limits in Rule 1124 are more stringent than the recommended CTG limits and will help to achieve greater VOC reductions than required by the CTG (e.g., Adhesive Bonding- 10

- Component Manufacturing Operations (80 FR 60040

, October 5 , 2015). This rule meets RACT.

Wm Bol thouse F arms ’ NOx emissions 13 come from diesel engine well pumps and is considered a major source of NOx

. AVAQMD indicates the facility has electrified many of its engines and may, in the near future, be below the threshold for a t itle V permit

. 14 A review of the t itle V permit indicates th e applicable requirement to be CARB’s Airborne Toxic Control Measure (ATCM) for Diesel Particulate Matter from Portable Engines Rated at 50 Horsepower and Greater 15 . There does not however, appear to be a NOx SIP rule which

covers internal combustion engine s used for agricultural operations

. Specifically, CARB’s ATCM limits particulate matter and does not regulate NOx emissions and Rule 1110.2 Emissions from Stationary, Non

- road and Portable Internal Combustion Engines (January 21, 2003) exempts engines used for agricultural operations.

Action: A mend Rule 1110.2 to remove agricultural exemption or adopt a new rule

- see the next section for additional details

.

T he District ’ s efforts to identify all major source s appea r to be thorough

.

3. Other NOx Rules

AVAQMD action:

AVAQMD’s 2015 RACT SIP also examined the following 3 NOx rules:

• Rule 1110.2, Emissions from Stationary, Non

- road and Portable Internal Combustion Engines : The 2015 RACT SIP indicates Rule 1110.2 does not i mplement RACT and will be updat ed to meet other federal requirements. Rule 1110.2 must be updated to remove the agricultural exemption and address other EPA comments identified in the proposed limited approval / limited disapproval ( 69 FR 21482

, April 21, 2004).

• Rule 1146, Emissions of Oxides of Nitrogen from Industrial, Institutional and Commercial Boilers, Steam Generators, and Process Heaters: the District

c ompared its rule to SCAQMD Rule 1146 and San Joaquin Valley Unified air Pollution Control District ( SJVUAPCD ) Rule 4306, and found AVAQMD Rule 1146

was less stringent for certain NOx limits. The 2015 RACT SIP states it will survey

Primers

- Commercial and Military Aircraft, Fire

- Resistant interior coating

- civilian, and fuel tank coating

- general limit).

13 CARB’s emissions inventory shows 46 tpy NOx in 2012, 39.7 tpy in 2013 and 39.5 tpy in 2014.

14 T. Walters (AVAQMD) email to J. Shears (EPA), April 21, 2016

, FW: Wm. Bolthouse farms

.
15 CARB ATCM available at http://www.arb.ca.gov/diesel/peatcm/peatcm.htm

.- 11

- affected units for applic ability to this rule and determine if it is feasible to update the limits as RACT.

• Rule 1146.1, Emissions of Oxides of Nitrogen from Small Industrial, Institutional, and Commercial Boilers, Steam Generators, and Process Heaters: the District found the NOx limits in this rule to be consistent with the then current SIP

approved RACT limits in SJVUAPCD Rule 4307 (10/16/08) and SCAQMD Rule 1146.1 (9/5/08)

. The 2015 RACT SIP states these rules as well as the TSD for the SCAQMD Rule 1146.1 ( 9/ 5/08 ), will be used for updating requirements during the

ne x t rule update. 16

EPA evaluation:

Rule 1110.2, Emiss ions from Stationary, Non

- road and Portable Internal Combustion Engines : the EPA concurs that this rule needs to be updated to implement RAC T. Our April 21, 2004 proposed limited approval/limited disapproval was based on exempting agricultural internal combustion engine s from the rule and this exemption should be removed

. The limited approval/limited disapproval 17 also included a request for justification of the seasonal exemption for engines used for snow manufacturing and ski lift operation, a request to correct several citations, and a request to increase record s retention from 2 years to 5 years.

Action: Amend Rule 1110.2

Rule 1146, Emissions of Oxides of Nitrogen from Industrial, Institutional and Commercial Boilers, Steam Generators, and Process Heaters and Rule 1146.1, Emissions of Oxides of Nitrogen from Small Industrial, Institutional, and Commerci al Boilers, Steam Generators, and Process Heaters: the EPA evaluated these two rules and found the y do not appear to be associated with major NOx sources in the District. We t herefore conclude these rules are not required to implement RACT at this time.

4

. Submit negative declarations where there are no facilities subject to a CTG 18

.

AVAQMD action:

In lieu of adopting RACT rules, Districts can adopt negative declarations for CTG source categories if there are no sources in the District covered by the CTG

.

16 SJVUAPCD and SCAQMD subsequently amended its rules on April 21, 2016 and November 1, 2013 respectively.

17 See 69 FR 21482 (April 21, 2004).

18 Although AVAQMD’s July 21, 20 15 Final Staff Report

- Executive Summary ( p g . 1 ) incorrectly describes the CAA RACT requirement s to apply to CTG documents for “ major sources” of VOCs and NOx, AVAQM D did use the correct criteria to identify all sources and source categories that are subject to the RACT Analysis (see p.9 of the July 2015 RACT SIP Analysis).- 12

- Table 1 of AVAQMD’s “Final Staff Report

– Adoption of the Federal Negative Declarations for Twenty Control Techniques Guidelines Source Categories”, dated July 21, 2015, i dentifies the CTG source categories for which the District indicates it has no applicable stationary sources

. AVAQMD c ompiled this list by comparing its rules against EPA’s list of CTGs and ACTs and reviewing its permits, emissions inventory, and consulting with knowledgeable staff of the District’s permit and enforcement divisions.

The AVAQMD identified the following CTG source categories where it has an existing rule, but does not have sources exceeding the CTG ’s applicability threshold: Rule 463, Storage of Organic Liquids, Rule 1102, Petroleum Solvent Dry Cleaners, and Rule 1104, Wood Flat Stock Coating Operations. The District states that adoption of negative declarations for these categories does not affect the SIP status of the exist ing rules nor does it preclude the District from amending such rules in the future and submitting them as SIP revisions.

EPA Evaluation :

EPA’s proposed rule to implement the 2008 8

- hour ozone standard states: “ RACT SIPs must contain adopted RACT regulations, certifications where appropriate that existing provisions are RACT and/or negative declarations that there are no sources in the nonattainment area covered by a specific CTG source category. ” 19 We compared AVAQMD’s adopted rules and list of neg ative declarations to verify all the CTG categories were either addressed by a District rule or were covered by a negative declaration

. Table 2 below lists three negative declarations that were missing from the District’s analysis, and a recommendation for the District to adopt a negative declaration for these categories as appropriate. A negative declaration for the RACT SIP does not impact the SIP a pproval status of a rule previously approved into the SIP by the EPA

.

T able 1 below lists the CTG source categories included in AVAQMD’s 2015 Federal Negative Declarations Table 1. We searched CARB’s emissions inventory database and verified there do not appear to be facilities in AVAQMD that might be subject to these CTGs

.

Table 1

– AVAQMD Negative Declara tions

CTG Source Category CTG Reference Document
Bulk Gasoline Plants EPA

- 450/2

- 77

- 035, Control of Volatile Organic Emissions from Bulk Gasoline Plants Coils EPA

- 450/2

- 77

- 008

, Control of Volatile Organic Emissions from Existing Stationary Sources

– Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light

- Duty Trucks Fiberglass Boat Manufacturing Materials EPA

- 453/R

- 08

- 004, Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials Flat Wood Paneling EPA

- 453/R

- 06

- 004, Control Techniques Guidelines for Flat Wood Paneling Coatings

19 80 FR 12264 at 12278, March 6, 2015.- 13

- CTG Source Category CTG Reference Document
Fixed Roof Tanks EPA

- 450/2

- 77

- 036 , Control of Volatile Organic Emissions from Storage of Petroleum Liquids in Fixed Roof Tanks Floating Roof Tanks EPA

- 450/2

- 78

- 047, Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating Roof Tanks Insulation of Magnet Wire EPA

- 450/2

- 77

- 033, Control of Volatile Organic Emissions from Existing Stationary Sources

– Volume IV: Surface Coating of Insulation of M agnet Wire Large Appliances Coatings EPA

- 450/2

- 77

- 034, Control of Volatile Organic Emissions from Existing Stationary Sources

– Volume V: Surface Coating of Large Appliances

EPA

- 453/R

- 07

- 004, Control Techniques Guidelines for Large Appliance Coatings Large Petroleum Dry Cleaners EPA

- 450/3

- 82

- 009, Control of Volatile Organic Compound Emissions from Large Petroleum Dry Cleaners Manufacture of High

- Density Polyethylene, Polypropylene, and Polystyrene Resins EPA

- 450/3

- 83

- 008, Control of Volatile Organic Compound Emissions from Manufacture of High

- Density Polyethylene, Polypropylene, and Polystyrene Resins Metal Furniture Coating EPA

- 453/R

- 07

- 005, Control Techniques Guidelines for Metal Furniture Coatings Natural Gas/Gasoline Processing Plants EPA

- 450/2

- 83

- 007, Control of Volatile Organic Compound Equipment Leaks from Natural Gas/Gasoline Processing Plants Petroleum Refinery Equipment EPA

- 450/2

- 78

- 036, Control of Volatile Organic Compound Leaks from Petroleum Refinery Equipment Pneumatic Rubbe r Tires EPA

- 450/2

- 78

- 030, Control of Volatile Organic Emissions from Manufacture of Pneumatic Rubber Tires Refinery Vacuum Producing Systems, Wastewater Separators, and Process Unit Turnarounds EPA

- 450/2

- 77

- 025, Control of Refinery Vacuum Producing System s, Wastewater Separators, and Process Unit Turnarounds

Shipbuilding and Ship Repair Operations Surface Coating 61 FR 44050 and EPA

- 453/R

- 94

- 032

, Control Techniques Guidelines for Shipbuilding and Ship Repair Operations (Surface Coating) Synthetic Organic Chemical Polymer and Resin Manufacturing Equipment EPA

- 450/3

- 83

- 006, Control of Volatile Organic Compound Leaks from Synthetic Organic Chemical Polymer and Resin Manufacturing Equipment Synthesized Pharmaceutical Products EPA

- 450/2

- 78

- 029, Control of Vol atile Organic Emissions from Manufacture of Synthesized Pharmaceutical Products Synthetic Organic Chemical EPA

- 450/3

- 84

- 015, Control of Volatile Organic Compound Emissions from Air Oxidation Processes in Synthetic Organic Chemical Manufacturing Industry

EPA

- 450/4

- 91

- 031, Control of Volatile Organic Compound Emissions from Reactor Processes and Distillation Operations in Synthetic Organic Chemical Manufacturing Industry Wood Furniture Manufacturing EPA

- 453/R

- 96

- 007

, Control of Volatile Organic Compound Emissions from Wood Furniture Manufacturing Operations

We also compared the District’s earlier negative declarations for the 1997 ozone standard and found the Tank Truck Loading Terminal category was missing in the current list of negative declarations. We also note the 1978 Flat Wood Paneling and 1977 Metal Furniture- 14

- CTGs were not listed as negative declarations while the newer versions of these CTGs were adopted as negative declarations for the 2008 8

- hour ozone standard.

AVAQMD should determine if the following are negative declarations for the 2008 ozone standard and adopt negative declarations as appropriate.

Table 2

– Su ggest ed Additional Negative Declarations

CTG Source Category CTG Reference Document Tank Truck Terminal >76,000 L EPA

- 450/2

- 77

- 026

, Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals Negative declaration was adopted for the 1997 8

- hour ozone standard but not for the 2008 8

- hour ozone standard Flat Wood Paneling EPA

- 450/2

- 78

- 032

, Control of Volatile Organic Emissions from Existing Stationary Sources

– Volume VII: Factory Surface Coating of Flat Wood Paneling Negative declaration was adopted for th e 2008 CTG for Flat Wood Paneling, but not for the 1978 CTG for Flat Wood Paneling Metal Furniture EPA

- 450/2

- 77

- 032

, Control of Volatile Organic Emissions from Existing Stationary Sources

– Volume III: Surface Coating of Metal Furniture Nega tive declaration was adopted for the 2007 CTG for Metal Furniture Coatings , but not for the 1977 CTG for Metal Furniture Coatings

5. Summary With the exception of the following rules , we conclude that AVAQM D ’ s 201 5 RACT SIP in combination with its 2006 RACT SIP Analysis for the 1997 8

- hour ozone standard and its 2014 Supplemental Analysis largely satisfies the District’s RACT obligation for the 1997 and 2008 8

- hour ozone standards. The rules that need to be amended to implem ent RACT are:

Rule 462 Organic Liquid Loading

- Amend rule to address deficiencies in the proposed Limited Appr oval/Limited Disapproval in 62 FR 26 4 60, 05/14/1997.

Rule 1110.2 Emissions from Stationary, Non

- road and Portable Internal Combustion Engines

- Amend rule to remove agricultural exemption.

Rule 1151

- Motor Vehicle and Mobile Equipment Coating Operations

- A mend or adopt separate rule to cover c oating of new h eavier d uty v ehicles and, as applicable, VOC content limits from the 2008 CTG for Miscellaneous Metal and Plastic Parts Coatings, Table 6 Motor Vehicle Materials

.

Rule 1171

- Solvent Cleaning Operations

- Amend rule to incorporate work practices from 2006 Industrial Solvent Cleaning CTG

.

Evaluate adopting ne gative d eclarations for the following CTGs for the 2008 8

- hour ozone standard : EPA

- 450/2

- 77

- 008 Can coating portion- 15

- EPA

- 453/R

- 08

- 003 Drum coating portion and Pleasure craft portion EPA

- 450/2

- 77

- 026 Tank Truck Gasoline Lo ading Terminals EPA

- 450/2

- 78

- 032 Flat Wood Paneling coating EPA

- 450/2

- 77

- 032 Metal Furniture coating

Final disapproval will result in offset and highway sanctions unless EPA approves a SIP revision amending the above rule s as fulfilling RACT within 18 mon ths of the effective date of the disapproval. See CAA section 179 and 40 CFR 52.31. We will not finalize this partial disapproval, however, if we receive and fully approve the se rule s fulfilling RACT before finalizing action on the 201 5 RACT SIP. EPA is committed to working with CARB and the District to resolve these RACT deficiencies, and we encourage the State and District to submit a SIP revision correcting the identified deficiencies as expeditiously as practicable. A revised 201 5 RA CT SIP demonstration will not be necessary if the submitted amended rule s correct the identified deficiencies.
In addition, CAA section 110(c)(1) provides that EPA must promulgate a Federal Implementation Plan (FIP) within two years after finding that a S tate has failed to make a required submission or disapproving a SIP submission in whole or in part, unless EPA approves a SIP revision correcting the deficiencies within that two

- year period.

6. Suggestions for Additional VOC / NOx Reductions If addition al emission reductions are needed beyond RACT, the District may want to investigate:

1) Controlling emissions from chain driven charbroilers

. See SCAQMD Rule 1138, Control of Emissions from Restaurant Operations ; SJVUAPCD Rule 4692, Commercial Charbroiling; or Bay Area AQMD Regulation 6 Rule 2 Commercial Cooking Equipment.

2 ) Warm mix asphalt as an option to hot mix asphalt

– See San Joaquin 2015 DRAFT Warm Mix Asphalt Further Study Report http://www.valleyair.org/notices/Docs/2015/12

- 01

- 15_%28WMA%29/WMA.pdf

REFERENCES

-

1. “Final Staff Report

– Adoption of the 2015 Reasonably Available Control Technology

– State Implementation Plan Analysis (2015 RACT SIP Analysis)”, dated July 21, 2015.

2. “8

- Hour R easonably Available Control Technology

– State Implementation Plan Analysis (RACT SIP Analysis)”, dated July, 2015 [hereinafter “2015 RACT SIP”].

3. “Final Staff Report

– Adoption of the Federal Negative Declaration s for Twenty Control Techniques Guidelines Source Guidelines”, dated July 21, 2015.- 16

- 4. AV AQMD “8

- Hour Reasonably Available Control Technology

– State Implementation Plan Analysis (RACT SIP Analysis)”, dated August 2006.

5. AVAQMD “8

- Hour Ozone Reasonably Available Control Technology (RACT) State Implementation Plan (SIP) Analysis

– Supplemental Analysis”, dated March 13, 2014.

6. R ACT SIPs, Letter dated March 9, 2006 from EPA Region IX (Andrew Steckel ) to CARB (Kurt Karperos) describing Region IX ’ s understanding of what constituted a minimally acceptable RACT SIP

.

7. RACT SIPs, Letter dated April 4, 2006 from EPA Region IX (Andrew Steckel) to CARB (Kurt Karperos) listing EPA ’ s current CTGs, ACTs, and other documents which may help to establish RACT.

8. RACT Qs & As

– Reasonably Available Control Technology (RACT): Questions and Answers, May 18, 2006 Note from William T. Harnett, Director, Air Quality Policy Division, to Regional Air Division Directors. http://www3.epa.gov/ttn/caaa/t1/memoranda/ractqanda.pdf

9. “ Final Rule to Implement the 8

- Hour Ozone National Ambient Air Quality Standard

– Phase 2 ” (70 FR 71612; November 29, 2005).

10. “ Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State Implementation Plan Requirements’’ (80 FR 12264; March 6, 2015).

11. “ Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations, ” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988 http://archive.epa.gov/ttn/ozone/web/pdf/voc_bluebook.pdf

12. “ Guidance Document for Correcting Common VOC & Other Rule Deficiencies, ” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001 http://www.arb.ca.gov/drdb/lbb2001.pdf

13. “ State Implementation Plans, General Preamble for the Implementation of Title I of the Clean Air Act A mendments of 1990 ” (57 FR 13498; April 16, 1992).

14. “ State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990 ” (57 FR 55620, November 25, 1992) ( “ the NOx Supplem ent ” ).

15. EPA ’ s CTGs and ACTs https://www.epa.gov/ozone

- pollution/control

- techniques

guidelines

- and

- alternative

- control

- techniques

- documents

- reducing

16. CARB ’ s emissions inventory database http://www.arb.ca.gov/app/ems inv/facinfo/facinfo.php

17. AV AQMD, CARB, and EPA Region IX databases of AV AQMD rules- 17

- AV AQMD: http://avaqmd.ca.gov/rule

- book CARB: http://www.arb.ca.gov/rldb/rldb.htm EPA: http://www.epa.gov/approved

- sips/approved

- sips

- region

- 9

18. “ BYD Contract Brings More Bus Building to Lancaster” . See http://sfvbj.com/news/2015/sep/08/byd

- contract

- brings

- more

- bus

- building

- lancaster/

19. T. Walters (AVAQMD) email to J. Shears (EPA), April 19, 2016 FW: AV RACT SI P more questions

.

20. CARB’s emissions inventory for AVAQMD showing 46 tpy NOx in 2012, 39.7 tpy in 2013 and 39.5 tpy in 2014 for Wm Bolthouse Farms.

21. T. Walters (AVAQMD) email to J. Shears (EPA), April 21, 2016 , FW: Wm. Bolthouse farms

.

22. S. Detwiler (CARB) email to S. Tong (EPA), November 8, 2016, RE: V OC / NOx emissions for BYD Moto rs, Lancaster, CA?