# A NALYSIS OF 

# C OMPLIANCE WITH



# 40 C.F.R. S ECTION 

# 51.160( A 

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BY



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## E NGINEER



## R EVIEWED BY



## B RENDA 

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# A UGUST 

# 20122



### Table of Contents Preventing Violations of Control Strategy:

................................ ................................ ................................ ... 3
Preventing Interference with Attainment or Maintenance of NAAQS:

................................ ........................ 3

Ozone:

................................ ................................ ................................ ................................ ....................... 3

PM 10 and PM 2.5 :

................................ ................................ ................................ ................................ ......... 5

NO 2 :

................................ ................................ ................................ ................................ ........................... 7

SO 2 :

................................ ................................ ................................ ................................ ............................ 8

CO:

................................ ................................ ................................ ................................ ............................. 9

Lead:

................................ ................................ ................................ ................................ ........................ 103 Analysis of Compliance with 40 C.F.R. §§ 160(a) &(b)

40 C.F.R. Sections 160(a) and 160(b) require that the SIP must include provisions that will prevent permitted sources from (1) violating any portion of the region’s Control Strategy and (2) interfering with attainment or maintenance of any NAAQS. Se ction 160(a) requires that the SIP have provisions for the District to determine whether any such source will cause such a violation or interference; and Section 160(b) requires that the SIP have provisions for the APCO to deny a permit for a source that w ill cause such a violation or interference. These requirements apply to the entirety of the District’s NSR program, not just the “Major NSR” elements that are subject to 40 C.F.R. Sections 165 (for non

- attainment pollutants) and 166 (for attainment/unclas sified pollutants). The District’s NSR program under the Proposed Amendments will fully satisfy these requirements, as explained below.



### Preventing Violations of Control Strategy: The District’s review of permit applications under its NSR program will ens ure that no new or modified source (of any size) will violate any portion of the District’s Control Strategy. The District’s permit review process
– applicable to all Authorities to Construct for all new and modified sources at all facilities regardless o f size

– involves a thorough review all applicable air quality regulatory requirements to ensure that the new/modified source will comply. If this review shows that there will be a violation of any such requirement (which includes all
elements of the Dist rict’s control strategy under the SIP), then the District will deny the permit. This denial authority is set forth in Regulation 2

- 1

- 304 (Denial, Failure To Comply With Applicable Requirements).



### Preventing Interference with Attainment or Maintenance of NAAQS: The District’s NSR review requirements will also ensure that no new or modified sources for which NSR permits are issued will interfere with attainment or maintenance of any NAAQS. Several aspects of the District’s NSR program combine to ensure th is result. The discussion below addresses each of the NAAQS in turn.



### Ozone: EPA’s current NAAQS for ozone is 75 ppm, averaged over 8 hours. The Bay Area is currently designated as non

- attainment of this standard. T o address this situation, the Bay Area 2010 Clean Air Plan (CAP) 1 provides a comprehensive plan to improve Bay Area air quality and protect public health. The 2010 CAP has been prepared in close collaboration with the Air

1 Bay Area 2010 Clean Air Plan, September 15, 2010

.4

District’s regional agency partners, and has been informed by extensive o utreach to the public and interested stakeholders.

Ozone is not emitted d irectly from pollution sources. Instead, ozone is formed in the atmosphere through complex chemical reactions in the presence of sunlight between two types of precursor chemicals: h ydrocarbons, often referred to as “reactive organic gases” (ROG), and nitrogen oxides (NOx). Ozone is also a regional pollutant. Emissions of ROG and NOx throughout the Bay Area contribute to ozone formation. Because emissions in one part of the region can impact air quality miles away, efforts to reduce ozone levels focus on reducing emissions of ROG and NOx throughout the region.

There are literally millions of sources of ozone precursors in the Bay Area, including industrial and commercial facilities , motor vehicles, and consumer products such as household cleaners and paints. Even trees and plants produce ozone precursors. The main sources of ROG emissions in the Bay Area are motor vehicles and evaporation of solvents, fuels and other petroleum pro ducts. The main sources of NOx are motor vehicles and combustion at industrial

a nd other facilities. The Bay Area annual average emission inventory for ozone precursors, ROG and NOX is presented in Table 2‐3 in Volume I of the 2010 CAP 2

.
The inventory and projections are based upon CARB EMFAC 2007, Version 2.3 and reflects the effect of regulations adopted as of December 31, 2006. The inventories do not include additional emissions reductions from State or federal measures adopted since 2007 or CARB’s

“ Pavley regulations” to reduce greenhouse gases from motor vehicles.

Reactive Organic Gases (ROG) (TPY) Oxides of Nitrogen (NOx) 2005 2009 2012 2015 2020 2005 2009 2012 2015 2020 Stationary Sources* 120.4 124.4 125.3 127.1 130.5 63.8 75.8 77 78.4 80.9

Grand Total Emissions 393 354 331 317 306 521 473 432 394 357

* Stationary Sources include: Industrial/Commercial Processes, Other Industrial/Commercial Processes, Combustion

– Stationary Sources, Burning of Waste Materials, Banked Emissions, and Alternate Compliance Allowance. Banked Emissions are current emission reduction credits in the District’s emission banking program that may be used in the future to offset future emission increases. Alternate Compliance Allowance are surplus emissions, v oluntarily reduced, available for alternative compliance with BARCT requirements of selected rules, as prescribed by State Law and BAAQMD Regulation 2, Rule 9.

The District’s CAP allow for a certain amount of growth in stationary sources (i.e., sources

pe rmitted by the District under its NSR program)

. Furthermore
, per Regulation 2

- 2

- 302, ROG and NOx offsets will be required for facilities with increases over 10 TPY, and any increase at all for facilities above this threshold, which is far lower than what is required under the federal
CAA. There is not yet a PSD modeling methodology for ozone. Hence, there is no proposal to

2 BAAQMD Bay A rea 2010 Clean Air Plan, September 15, 2010

.5

model ozone for minor sources. However, the thresholds for public noticing will ensure a “backstop” requirement for those applications with significant increases in emissions of ROG
and NOx. Issuing minor NSR permits for new and modified sources will not interfere with attainment and maintenance of the ozone NAAQS.



### PM 10 

### and PM 2.5 

### : EPA has established three NAAQS for particulate matter: a 150 μg/m 3 24

- hour

- average standard for PM 10 ; and a 35 μg/m 3 24

- hour

- average standard and a 15 μg/m 3 annual average standard for PM 2.5 . The measured ambient air quality in the Bay Area is currently in compliance with all PM NAAQS.
The Bay Area is administratively designated by EPA as being in attainment of the PM 10 NAAQS and the annual

- average PM 2.5 NAAQS. From our monitoring network, the District’s monitoring network has detected the following concentrations of PM 10 in the Bay Area:

2008: Maximum 24

- hr: 77 ug/m 3 ; Maximum annual average: 24.1 ug/m 3 3

2009: Ma ximum 24

- hr: 55 ug/m 3 ; Maximum annual average: 20.4 ug/m 3 4

2010: Maximum 24

- hr: 70 ug/m 3 ; Maximum annual average: 21.0 ug/m 3 5

Hence, for PM 10 the maximum 24

- hr concentration is 51 % of standard, while the maximum annual concentration is 17 % of standard.

The Bay Area is currently designated by EPA as being non

- attainment for the 24

- hour average
PM 2.5 NAAQS, but an analysis of monitoring data over the past few years shows that as a factual
matter 24

- hour PM 2.5 concentrations have been below the standard. The District has developed a comprehensive emissions inventory and report of the PM in the Bay Area 6

. The purpose of the report is to (1) fulfill federal air quality planning requirements for PM2.5, and (2)

gu ide the Air District’s long

- term efforts to analyze and reduce PM emissions and population exposure to PM in the Bay Area.

The breakdown of primary PM2.5 emissions by source category differs for the winter PM2.5 inventory compared to the annual inventory . The key difference is that PM2.5 emissions from residential fuel combustion account for 38% of the winter inventory versus 24% in the case of the annual inventory. PM2.5 emissions from residential fuel combustion, which is dominated by wood

- burning in fireplaces and wood stoves, are 65% higher (an additional 7 tons per day) in the winter months than the annual emissions for this category. However, emissions from

3 BAAQMD Annual Bay Area Air Quality Summary, 2008

. 4 BAAQMD Annual Bay Area Air Quality Summary, 2009

. 5 BAAQMD Annual Bay Area Air Quality Summary, 2010

. 6 BAAQMD Particulate Matter: Understanding PM to Protect Public Health in the Bay Area, August 2012.6

several source categories are lower in winter. For example, winter emissions from off

- road equipment, as well as from the industrial sector, are lower than annual average emissions due to reduced activity during the winter months. Accidental fires and geological dust emissions are also lower in the winter than the annual average. Overall, how ever, winter

- time PM2.5 emissions are 4% higher (an additional 2 tons per day) than annual

- average emissions. The relationship between annual PM10 and winter PM10 is similar to that for PM2.5. The main difference is that emissions for residential fuel co mbustion (primarily wood

- burning) increase from 11% of the annual PM10 inventory to 18% of the winter PM10 inventory, while emissions from accidental fires (primarily wildfires) decrease from 5% of the annual PM10 inventory to 1% of the winter PM10 invento ry.
Annual average emissions of primary PM2.5 have decreased from an estimated 87 tons per day, as reported in the 2010 CAP, to 47 tons per day, a decline of 46%. The revised inventory includes significant reductions in several major source categories, su ch as residential wood

burning, commercial cooking, off

- road vehicles (“Other Mobile Sources”), and road dust (included in “Geological dust”). This decrease in the inventory is based in part on real emission
reductions due to factors such as turnover in t he vehicle fleet and the impact of new regulations that had not been accounted for in previous emission factors. However, changes in methodologies used to estimate emissions also account for a significant portion of the decrease in the inventory. The est imated emis sions provided in the inventory 7 are based upon data from source tests, published emission factors, and engineering calculations. Emission inventories are revised and improved on a regular basis. The current PM inventory 7 differs significantly from the inventory provided in the 2010 CAP. This is due to the fact that, since the release of the 2010 CAP, ARB and Air District staff reviewed and improved the methodologies used to estimate emissions from several of the most imp ortant PM source categories, as explained below.

Future emissions projections for primary PM and PM precursors are based on estimated future trends in population growth and household formation, land use, economic activity, and motor vehicle travel. The p rojected inventory includes anticipated emission reductions from turnover in the motor vehicle fleet (whereby older, dirtier vehicles are replaced by newer, cleaner vehicles), and well as ARB and Air District regulations that have already been adopted.
Im plementation of ARB regulations on mobile sources is typically phased in, so the entire benefit of these adopted regulations will not be realized until they have been fully implemented over the next 10

- 15 years. At that point, emissions are projected to s lowly increase in response to population and economic growth, if no additi onal regulations are adopted.

7 BAAQMD Particulate Mat ter: Understanding PM to Protect Public Health in the Bay Area, August 2012.7 PM10 (TPY) PM2.5 2010 2015 2020 2025 2030 2010 2015 2020 2025 2030 Stationary Sources* 34.9 35.5 36.5 37.7 38.8 29.8 30.3 31.0 31.9 32.8

Grand Total Emissions 104 104 105 108 111 49 48 48 49 51

* Stationary Sources include: Industrial/Commercial Processes, Other Industrial/Commercial Processes, Combustion

– Stationary Sources, Burning of Waste Materials, Banked Emissions, and Alternate Compliance Allowance. Banked Emissions are current emission reduction credits in the District’s emission banking program that may be used in the future to offset future emission increases. Alternate Compliance Allowance are surplus emissions, voluntarily reduced, available for alternative compliance with BARCT requirements of selected rules, as prescribed by State Law and BAAQMD Regulation 2, Rule 9.

Overall, the projected inventory shows little change in total emissions of primary PM2.5 and primary PM10 from 2010 through 2030, based on the (unlikely) assumption that no future regulations or policies are adopted to further reduce emissions. As such, the projected emissions represent a “business as usual” scenario as to future emission levels. PM emission s from sources under District jurisdiction are projected to increase at a rate of around 1% per year based on previous observed growth and regulations adopted to date.

As with ozone above, the District is projecting an overall a decline in winter

- time PM 2 .5 emissions (with a slight up

- tick in 2030), which is expected to keep the Bay Area below the NAAQS. The District has also projected a certain amount of growth in stationary sources/industrial sources. Again, the slight up

- tick in 2030 does not include the unlikely assumption that no future regulations or policies are adopted to further reduce emissions. In addition, for major sources, offsets for increases of PM 10 and PM2.5 will be required. The thres holds for modeling and public noticing will ensure a “backstop” requirement to perform air quality modeling and public noticing for those applications with significant increases in
emissions. Issuing minor NSR permits for new and modified sources will not interfere with attainment and maintenance of the PM 2.5 and PM 10 NAAQS.



### NO 2 

### : EPA’s current NAAQS for nitrogen dioxide is 0.1 ppm on an hourly basis and 0.053 ppm averaged over an annual average. The Bay Area is currently designated as in attainment of th e annual average standard and unclassified for the hourly standard

. To attain this hourly standard, the 3

- year average of the 98th percentile of the daily maximum 1

- hour average at each monitor within an area must not exceed 0.100 ppm (effective January 2 2, 2010). The latest inventory for N O 2 (2008) is 449 tons per day and 163,890 tons per year 8

. Only 13% comes from stationary sources (combustion), while 87 % of the inventory is from motor vehicles 8 . The District has reviewed application data 9 and determined that if all increases fr om

8 BAAQMD Base Year 2008 Bay Area Emissions Inventor y Summary Report, May 2011

.8

plants less than 40 tons were added together for each year for years 1991 to 201 1 that the averaged, annual total N O 2 increase is 22 7 tons per year and ranges from 34 to 557 tons per year, which is only 0.02 % to 0.34 % of the total inventory. From our monitoring network, the District’s monitoring network has detected the following concentrations of N O 2 in the Bay Area:

2008: Maximum 1

- hr: 0.0 80 pp m ; Maximum annual average: 0.0 17 pp m 10

2009: Maximum 1

- hr: 0.0 69 pp m ; Maximum annual average: 0.0 1 6 pp m 11

2010: Maximum 1

- hr: 0.0 9 3 pp m ; Maximum annual average : 0.0 16 pp m 12

Hence, the maximum 1

- hr concentration is 93 % of standard, while the maximum annual
concentration is 32 % of standard. It is unlikely than even a significant increase in N O 2 will hurt the District’s continual attainment of the NAAQS for N O 2 . Furthermore, per Regulation 2

- 2

- 302,
NO 2 offsets will be required for facilities with increases over 10 TPY, and any increase at all for facilities above this threshold, which is far lower than what is required under the federal CAA. The thresholds for modeling and public noticing will ensure a “backstop” requirement to perform air quality modeling and public noticing for those applications with significant
increases in emissions. Issuing minor NSR permits for new and modified sources wil l not interfere with attainment and maintenance of the NO 2 NAAQS.



### SO 2 

### : EPA’s current NAAQS for sulfur dioxide is 75 ppb on an hourly basis
, 140 ppb averaged over 24 hours, and 30 ppb over an annual average. The Bay Area is currently designated as in attainment of th ese standard s . The latest inventory for SO 2 (2008) is 82 to ns per day and 29,930 tons per year 13

. Approximately 48% comes from stationary sources, while 52% of the inventory is from motor vehicles 13

. The District has reviewed application data 14 and determined that if all increases f rom plants less than 40 tons were added together for each year for years 1991 to 201 1 that the averaged, annual total SO 2 increase is 49 tons per year and ranges from 8 to 93 ton s per year, which is only 0. 027 % to 0. 311 % of the total inventory. From our monitoring network, the District’s monitoring network has detected the following concentrations of SO 2 in the Bay Area:

2008: Maximum 24

- hr: 13 ppb; Maximum annual average: 2.1 ppb 15

2009: Maximum 24

- hr: 7 ppb; Maximum annual average: 1.7 ppb 16

9 BAAQMD Application Data from Years 1991 to 2012.
10 BAAQMD Annual Bay Area Air Q uality Summary, 2008

. 11 BAAQMD Annual Bay Area Air Quality Summary, 2009

. 12 BAAQMD Annual Bay Area Air Quality Summary, 2010

. 13 BAAQMD Base Year 2008 Bay Area Emissions Inventory Summary Report, May 2011

. 14 BAAQMD Application Data from Years 1991 to 2011.
15 BAAQMD Annual Bay Area Air Quality Summary, 2008

.9 2010: Maximum 24

- hr: 6.5 ppb; Maximum 1

- hr : 37 ppb 17

, 18

In 2010 , the maximum 1

- hr concentration is 49.3 % of standard, while the maximum 24

- hr
concentration s is 49.3 % of the annual standard. It is unlikely than even a significant increase in
SO 2 will hurt the District’s continual attainment of the NAAQS for SO 2 . In addition, for major sources, offsets for increases of SO 2 will be required. The thresholds for modeling and public

no ticing will ensure a “backstop” requirement to perform air quality modeling and public noticing for those applications with signi ficant increases in emissions . Issuing minor NSR permits for new and modified sources will not interfere with attainment and maintenance of the SO 2 NAAQS.



### CO: EPA’s current NAAQS for carbon monoxide is 35 ppm on an hourly basis and 9 ppm averaged over 8 hours. The Bay Area is currently designated as attainment of this standard. The latest inventory for CO (2008) is 1723 tons per day and 628,900 tons per year 13

. Only 1 0 % is from stationary sources (combustion), while 88% of the inventory is from motor vehicles (the remaining 2% is from consumer products/dust sources/fires) 19

. The District has revie wed application data 20 and determined that if all increases f rom plants less than 100 tons were added together for each year for years 1991 to 2012 that t he average d, annual total CO
increase is 351 tons per year and range s from 50 to 804 tons per year, whi ch is only 0.08% to 0.128% of the total inventory. From our monitoring network, the District’s monitoring network
has detected the following concentrations of CO in the Bay Area:

2008: Maximum 1

- hr: 5.7 ppm; Maximum 8

- hr: 2.5 ppm 15

2009: Maximum 1

- hr: 4.6 ppm; Maximum 8

- hr: 2.9 ppm 16

2010: Maximum 1

- hr: 3.0 ppm; Maximum 8

- hr: 2.2 ppm 17

Hence, the maximum 1

- hr concentration is 16% of standard, while the maximum 8

- hr concentration is 32% of standard. It is unlikely than even a significant increase in CO will hurt the District’s continual attainment of the NAAQS for CO. The thresholds for modeling and public noticing will ensure a “backstop” requirement t o perform air quality modeling and public noticing for those applications with significant increases in emissions. Issuing minor NSR permits for new and modified sources will not interfere with attainment and maintenance of the CO NAAQS.

16 BAAQMD Annual Bay Area Air Quality Summary, 2009

. 17 BAAQMD Annual Bay Area Ai r Quality Summary, 2010

. 18 Note that the form of the standard changed in 2010.
19 BAAQMD Base Year 2008 Bay Area Emissions Invento ry Summary Report, May 2011

. 20 BAAQMD Application Data from Years 1991 to 2011.10



### Lead: The Air District has been classified as “in attainment” for the pre

- 2008 lead standard of 1.5 ug/m3 and also the post

- 2008 lead standard

. On November 12, 2008 EPA strengthened the NAAQS for lead. EPA revised the level of the primary (health

- based) standa rd from 1.5 micrograms per cubic meter (ug/m 3 ) to 0.15 ug/m 3 and revised the secondary (welfare

- based) standard to be identical in all respects to the primary standard. In conjunction with strengthening the lead NAAQS, the EPA promulgated new monitoring r equirements including new design requirements for the lead NAAQS surveillance network. Monitoring is now required for lead sources that may contribute to violations of the lead NAAQS and for large urban areas

. The Bay Area does not have stationary source s with lead emissions that trigger the monitoring requirement. The f inal requirement sets the emission threshold for monitoring at stationary

sources at 0.50 tpy. However, the Bay Area does have three airports at which lead monitoring will be required o n an experimental basis: Palo Alto and Reid

- Hillview Airports in Santa Clara County, and San Carlos Airport in San Mateo County.

The following is the District’s 2009 inventory of stationary sources with lead emissions : LOCATION (lbs/yr) FACILITY Alameda 2.57E+02 Owens

- Brockway Glass Container Inc Alameda 1.31E+01 A B & I Foundry Alameda 1.24E+01 Ridge Foundry, Inc Alameda 6.77E+00 Pacific Steel Casting Co

- Plant #3 Alameda Total 2.89E+02 Contra Costa 1.62E+01 ConocoPhillips

- San Francisco Refinery
Contra Costa 7.37E+00 Shell Martinez Refinery
Contra Costa Total 2.36E+01 (lbs/yr) 3.13E+02

Additionally, the District monitors lead at its EPA National Core (NCore) monitoring location in
San Jose. NCore stations are multi

- pollutant monitoring stations. The lead data from the San Jose site for the 4 th quarter of 2011 shows lead levels 6 0% of the current NAAQS (0.00 9 ug/m3) 21

. A irports are a special category currently, and BAAQMD is monitoring for lead as part of a required 1

- year study at three regional airports (Reid Hillview and Palo Alto Airports in Santa Clara County and San Carlos Airport in San Mateo County), because emiss ions from piston engine aircraft using leaded fuel may approach 0.5 tons per year. The monitors will become permanent if any 3

- month rolling average is equal to or exceeds 50% of the NAAQS. Airport

21 Analytical Results of Testing, Eastern Research Group, July 11, 2012.11

lead TSP filter analysis is being performed by an EPA co ntract lab. The District is still awaitin g the first quarter’s results.

T he District has been monitoring from a Special Purpose Monitoring Site in Cupertino related to the Lehigh Cement plant. After collecting an entire year of data from September 2010 t hrough August 2011, the monitoring 22 showed a concentration of 0.002 ug/m 3 for both a 30 day average and 3 month average or 13% of the standard

. It is unlikely than even a significant increase in lead will hurt the District’s continual attainment of the NAAQS for lead. The thresholds for modeling and public noticing will ensure a “backstop” requirement to perform air quality modeling and public noticing for those applications with significant increases in emissions. Issuing minor NSR permits for new and modified sources will not interfere with attainment and maintenance of the lead NAAQS.

22 BAAQMD Summary and Analysis of Cupertino Air Monitoring Results, December 8, 2011

.