July 28, 2010 

James Goldstene 

California Air Resources Board 

1001 "I" Street 

P.O. Box 281 5 

Sacramento, CA 958 1 2 

Re: 2009 1 997 8-Hour Ozone Modified Air Quality Management Plan (2009 Modified 

AQMP) and the 2809 Reasonably Available Control Technology State 

Implementation Plan (2009 RACT SIP) 

Dear Mr. Goldstene: 

The Imperial County Air Pollution Control District (Air District) is formally remitting to you 

the Final 2009 1997 8-Hour Ozone Modified Air Quality Management Plan (2009 

Modified AQMP) and the Final 2009 Reasonably Available Control Technolugy State 

Implementation Plan (2009 RACT SIP) and associated findings for your review, 

comment and adoption. The Final 2009 Modified AQMP and the Final 2009 RACT SIP 

were adopted by the lmperial County Air Pollution Control District Board of Directors on 

July 13, 2010. 

As a matter of background, the United States Environmental Protection Agency (US 

EPA) issued a final ruling on December 3, 2009 determining that the Imperial County 

"Moderaten 8-hour ozone non-attainment area attained the 1997 8-hour National 

Ambient Air Quality Standard (NAAQS). The determination by US EPA resulted in the 

suspension of the requirement of an attainment demonstration, a reasonable further 

progress plan, contingency measures and other planning requirements for as long as 

Imperial County continues to attain the 1997 8-hour ozone NAAQS. However, the 

determination did not constitute a re-designation to attainment under the Clean Air Act 

(CAA) section 107(d)(3) and as such the classification and designation status for 

lmperial County remains as "Moderate" non-attainment for the 1997 &hour ozone 

NAAQS. Therefore, in response to the retained "Moderate" non-attainment status 

lmperial County prepared and is submitting for CARB approval and remittance to US 

EPA this 2009 Modified AQMP. The Final 2009 Modified AQMP includes the following 

CAA requirements. 

1. A growth emissions inventory for Nitrogen Oxides (NOx) and Volatile Organic 

Compounds (VOC's) (CAA, sections 172(c)(3) and 182(a)(l) 

2. New Source Review (CAA, sections 172 (c)(4) and (5); and 182(a)(2)(C)) 
3 Subpart 2 RACT for VOC's and NOx (CAA, sections 182(b)(2). 182(f)) 

4. Periodic Inl~eniory (CAA, section 182(a)(3)(A)) 

5. Emissions Statement Rule (CAA, section 182(a)(3)(8)) 

S. Offset Ratio 1.15 to 1 (CAA, sections 182(a)(4) and 182(b)(5)) 

7. Stage 2 Gasoline Vapor Recovery (GVR), (CAA, section 182(b)(3)) 

The Final 2009 Modified AQMP fulfills the requirements as set forth in the CAA for those 

areas classified as a "Moderate" non-attainment for the 1997 ozone NAAQS. 

Of the listed CAA requirements contained in the Final 2009 Modified AQMP the Subpart 

2 RACT for VQC's and NQx has been included in this remittance as its own separate 

document for consideration and approval. The CAA requires that area classified as 

"Moderate" or above submit a demonstration that RACT is implemented for all sources 

subject to Control Technique Guideline (CTG) documents and for major sources of VOC 

and NOx that are not subject to a CTG. Therefore the Air District developed and 

adopted the Final 2009 RACT SIP for CARB approval and remittance to US EPA for 

consideration and approval. The Final 2009 RACT SIP is a new determination 

demonstrating that RACT is implemented on all sources subject to a CTG and major 

sources not subject to a CTG. The Final 2009 RACT SIP provides the follo~ving 

information as provided for by the US EPA in letters intended as guidance to air 

districts: 

1. A description of how source categories within the district were identified as requiring 

WCT. The description identifies those under a CTG and those that are major nonCTG sources. 

2. A section identifying where there are no facilities major or minor within the district 

subject to a CTG which clearly makes a negative declaration on those sources. 

3. A list of statellocal regulation that implements RACT for those categories needing 

RACT. Included in the list is the date EPA approved the regulations as fulfilling 

RACT. 

4. Included is a description of the basis for reaching the conclusion that the current 

regulations fulfill RACT. Supporting documents such as CTGs, Alternative Control 

Technique guidance (ACTS), Maximum Achievable Control Technology (MACT) 

standards, New Source Performance Standards (NSPS), California Suggested 

Control Measures (SCM) and Best Available Retrofit Control Technology (BARCT) 

determinations, regulations adopted in other districts, and guidance and rules 

developed by other state and local agencies are identified for reference. 
5. Although the Air District d~d not choose to use the California Air Pollution Control 

Officer's Association (CAPCOA's) Potential All Feasible Measures (AFM). EPA 

guidance indicated that a certification would be required which provided certification 

that the local regulations were equivalent to AFM as well as a justification that the 

assumption that the AFM fulfilled RACT when adopted in September of 2003. 

Both documents, the Final 2009 Modified AQMP and the Final 2809 RACT SIP, were 

developed with the participation and cooperation of stakeholders. Stakeholders 

included health, environmental and community representatives, industry and 

transportation agencies. Both State and Federal agencies included the US EPA and 

the GARB. 

Enclosed you will find a disc with the following information: 

I. The Final 2009 1997 &Hour Ozone Modified Air Quality Management Plan 

2. The Final 2009 Reasonably Available Control Techniques State Implementation Plan 

3. Staff Report. 

4. Minute Order (Board Approval) 

The Imperial County APCD greatly appreciates the cooperative working relationship that 

CAR6 staff has provided throughout this process. If you have any questions please do 

not hesitate to contact me at 760482-4606. 

~{ad Poiriez 

Air Pollution Control Officer 

CC: Lynn Terry, Deputy Executive Officer 

Karen Magliano, Air Quality Data Branch Chief