San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

Chapter 8: Commitment to Leave No Stone Unturn ed to Evaluate Additional Opportunities

2015 Plan for the 1997 PM2.5 Standard 

# Chapter 8

Commitment	to	Leave	No	Stone	Unturned	to	Evaluate Additional	Opportunities

2015 Plan for the 1997 PM2.5 Standard SJVUAPCDSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

Chapter 8: Commitment to Leave No Stone Unturn ed to Evaluate Additional Opportunities

2015 Plan for the 1997 PM2.5 Standard This page intentionally blank.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

8-1 Chapter 8: Commitment to Leave No Stone Unturn ed to Evaluate Additional Opportunities

2015 Plan for the 1997 PM2.5 Standard 

### Chapter 8: Commitment to Leave No Stone Unturned to Evaluate Additional Opportunities

As discussed earlier, this 2015 Plan for the 1997 PM2.5 Standard ( 2015 PM2.5 Plan) contains Most Stringent Measures , Best Available Control Measur es, and ensures expeditious attainment. Further more, under Section 4.2 of Chap ter 4, this plan commits to producing additional reductions in emissions to further expe dite attainment. Despite the fact that this plan contains all the necessary elements for approval, the District is fully aware that meeting the t ougher newer National Ambient Air Quality Standards require additional e fforts and further reductions in emissions.

Over the next year, the District must adopt State Implementatio n Plans (SIP) to address

the 2006 PM2.5 St andard (of 15 μg/m 3 annual and 35 μg/m 3 24-hr) and the 2012 PM2.5 Standard (of 12 μg/m 3 annual and 35 μg/m 3 24-hr). Additionally, the District must also develop a SIP for the 2008 Ozone Standard (of 75 ppb) by July 2 016. As always, the

District will leave no stone untur ned to evaluate and identify further opportunities to

advance attainment of the ever-t ightening National Ambient Air Quality Standards. Of course, the opportunities identif ied to reduce emissions toward s meeting these tougher standards may also help expedite attainment with the 1997 PM2.5 standard addressed by this plan. In developing these plans, the District will ree valuate all of its existing regulations and will ex plore all potential measures for all sou rce categories. However, in the short term, the Distric t commits to conduct the evaluati ons described below and to include any identified additional actions for reducing emission s and implementation

schedules in the District’s attain ment plan submission for the 2012 PM2.5 NAAQS in Fall 2016. Upon full approval of the 2015 PM2.5 Plan by EPA, these commitments will be enforceable by EPA as prov ided for under the Clean Air Act.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

8-2 Chapter 8: Commitment to Leave No Stone Unturn ed to Evaluate Additional Opportunities

2015 Plan for the 1997 PM2.5 Standard 8.1 Rule 4311—Flares

As demonstrated in Appendix C, District Rule 4311 already meets BACM and MSM requirements. However, due to the need to demonstrate attainme nt for multiple federal

ozone and PM2.5 standards in the coming years and need to searc h for all available emissions reductions, the Distric t commits to undertaking a com prehensive review of

FMPs submitted under Rule 4311 . The District commits to conduc t the evaluation and have a draft report available fo r public review and commenting by December 1, 2015. After addressing public comments , the District commits to final ize this report by March 31, 2016. This evaluation will be conducted in close coordinat ion with flare operators in the Valley and will include the following elements:

1. The District will review submi tted FMPs to identify the most effective flare minimization practices utilized by operators to reduce flaring in various source categories and applications. Upon completion of review, the Di strict commits to working closely with affected oper ators to evaluate and impleme nt, when feasible, the most effective flar e minimization practices throu gh the FMP submittal and approval process under Rule 4311.

2. The District will evaluate the technological achievability a nd economic feasibility of implementing new/additional m inimization practices or techno logies at affected

facilities.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

8-3 Chapter 8: Commitment to Leave No Stone Unturn ed to Evaluate Additional Opportunities

2015 Plan for the 1997 PM2.5 Standard 8.2 Warm Mix Asphalt

Emissions from asphalt usage are extremely small and do not sig nificantly contribute to

elevated PM2.5 levels in the Valley. However, due to the need to demonstrate attainment for multiple federal ozone and PM2.5 standards in th e coming years and need to search for all available emissions reductions, the Dist rict commits to a number of actions to evaluate and promot e the use of WMA in the Valley . The District commits

to conduct the evaluation and have a draft report available for public review and commenting by December 1, 2015. After addressing public commen ts, the District commits to finalize this report b y March 31, 2016. This evalua tion will be conducted in

close coordination with stakehol ders (asphalt plant operators, Caltrans, city and county planning departments, ARB, EPA , and others) and will include th e following elements:

1. The District will evaluate opportunities to further encourag e transportation and county agencies to continue transit ioning from HMA to WMA as fe asible. As part of this evaluation, the Distric t will explore the potential fea sibility of additional control measures and granting mitigation credits for WMA usage through the

District’s Indirect Source Review (ISR) program.

2. The District will evaluate potential outreach and education opportunities for encouraging project developers/ construction managers to increas e their adoption and implementation of WMA.

8.3 Rule 4550—Conservati on Management Practices

As documented in Appendix C, Dis trict Rule 4550 already meets B ACM and MSM requirements. It is also ques tionable that further opportuniti es for reducing PM2.5 emissions exist. However, as st ated earlier, in developing pla ns for the new and existing National Ambient Air Quality Standards, the District w ill reevaluate all existing regulations including Rule 4550 to evaluate all feasible opport unities for additional emissions reductions, if any. T he District commits to conduct the evaluation and have a draft report available for public review and commenting by May 31, 2016. After addressing public comments, the District commits to finalize th is report by October 15,

2016. This evaluation will be con ducted in close coordination with stakeholders (agricultural industry repres entatives, ARB, EPA, NRCS, farm bu reaus, and others).San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

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