San Joaquin Valley Unified Air Pollution Control District March 11 , 2016

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### I. Background

Attainment of the 1997 PM10 Standard

The San Joaquin Valley ( Valley ) attained the 24

- hour 1997 PM10 National Air Quality Standard (NAAQS) of 150 micrograms per cubic meter μg/m 3 for particulate matter that is 10 microns or less in diameter (PM10) . Attainment was based on detailed technical information and monitoring data showing that all Valley PM10 mon itors attained the
PM10 NAAQS for the period of 2003 through 2005. The San Joaquin Valley Unified Air Pollution Control District ( District ) subsequently adopted the 2007 PM10 Maintenance

Plan satisfying all federal Clean Air Act (CAA) requirements for red esignation of the Valley to attainment. EPA proposed approval of the District 2007 PM10 Plan and redesignation of the Valley to attainment in April 2008 and issued final approval effective December 12, 2008.

District ’s 2007 PM10 Plan Contingency Plan

The Clean Air Act, Section (§) 175(d), requires maintenance plans to contain contingency provisions to assure prompt correction of any post

- redesignation events

. T he District’s 2007 PM10 Maintenance Plan identified the action level of 155 μg/m 3 and

s everal steps to address PM10 events above the action level :

1. Examination of Event

- First, the District will examine the event and determine if it needs to be classified as a natural or exceptional eve nt in accordance with EPA’s final rulemaking (72 FR 13560). If the data qualify for flagging under this rule, the District would proceed with preparing and submitting the necessary documentation for a natural/exceptional event, and would not consider the monitored level as a trigger for the maintenance plan contingency plan.

2. Determination of Causes and Needed Reductions

- If the event does not qualify as a natural or exceptional event, the District would then analyze the event to determine its possible c auses. It would examine emission reductions from adopted rules or rule commitments in adopted and approved plans to see if emission reductions not used in demonstrating maintenance would cover the

event

.
3. Identification of Controls from Feasibility Studies

- If reductions from Step 2 above are insufficient, the District would proceed with identifying control measures from any feasibility studies (e.g., from the 2007 Ozone Plan [SJVAPCD 2007]) completed to date that recommend future contro ls, and would prioritize development of the measures most relevant to reducing PM10 levels.San Joaquin Valley Unified Air Pollution Control District March 11 , 2016

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### II. Examination of Events

In recent years, the Valley has experienced events in which the measured levels at Valley PM10 monitors exceeded the 155 μg/m 3 action level. Upon evaluation, the

District determined that all of these events were caused by either high wind or extreme drought

- related exceptional events

.

Exceptional Event Evaluation Methodology

To consider whether an event qualifies as an exceptional event, the District closely examines a number of aspects of the event to determine if the criteria are satisfied pursuant to 40 CFR Part 50.14:

1. The event satisfies the crit eria set forth in 40 CFR 50.1(j);

2. There is a clear causal relationship between the measurement under consideration and the event that is claimed to have affected the air quality in the

area;
3. The event is associated with a measured concentration in excess o f normal historical fluctuations, including background; and

4. There would have been no exceedance or violation but for the event.

Through extensive meteorological and data analysis, the District determines whether

there is a clear causal connection between the event and the concentrations recorded, and whether the recorded value is outside of expected normal fluctuations. By demonstrating that the District’s control measures were in place at the time of the event, the exceptional event analysis is able to s how that the PM10 concentration would not have violated the federal standard “but for” the exceptional event that occurred.

Events Caused by High Wind

Below

, Table 1 displays the recent events that have been impacted by high wind

.

Table 1 Summary of Recent Events Caused by High Wind

Date Site PM10 Concentration ( μg/m 3 )

10/3 /2013 Corcoran 224

1/ 23 /201 4 Bakersfield

- California 260

Oildale 334

6/2/2014 Bakersfield

- California 17 2

6/10/2014 Oildale 310

6/11/2014 Bakersfield

- California 177

1 0 / 14 /2014 Corcoran 180

Oildale 336

Bakersfield

- California 419

12/11/2014 Corcoran 202San Joaquin Valley Unified Air Pollution Control District March 11 , 2016

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- As an example of the strong correlation between high winds speeds and elevated PM10 concentrations, the following Figure 1 shows the hourly wind speeds during a high wind event on October 3, 2013. The wind data and hourly PM10 concentrations recorded on October 3 indicate that Corcoran and Hanford were initially impacted by geologic material that was entrained by strong local w inds in the Lemoore and Tranqui lity areas, and then strengthened in western Merced County (Los Banos and Panoche). The

winds entr ained and transported the material across the western San Joaquin Valley to Kings County where it was dep osited in Corcoran and Hanford

.
Figure 1 Hourly Wind Speeds at the Panoche and Los Banos CIMIS S t ations, Lemoore NAS, and Hanford Municipal Airpo rt and PM10 Concentrations at

Corcoran and Hanford

*The 24

- Hour Average PM10 NAAQS is defined as 150 μg/m3 rounded to the nearest 10 μg/m3.

The high wind events outlined in Table 1 qualify as exceptional events in accordance with EPA’s final rulemaking . The District will be submitting exceptional event

documentation for these events to EPA.

Events Caused by Exceptional Drought Conditions

The following T able 2 summarizes the PM10 events caused by extreme drought

- related exceptional events

. 0 5 10 15 20 25 30 35

0 100 200 300 400 500 600

0:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 17:00 18:00 19:00 20:00 21:00 22:00 23:00 Wind Speed (mph) PM10 STP (μg/m3) October 3, 2013

Corcoran PM10 STP μg/m3 Hanford PM10 LC μg/m3
Panoche CIMIS Wind Speed (mph) Los Banos CIMIS Wind Speed (mph)
Lemoore NAS Wind Speed (mph) Hanford Municipal Airport Wind Speed (mph)

Wind Entrainment Threshold

Federal 24

- Hour Standard*San Joaquin Valley Unified Air Pollution Control District March 11 , 2016

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- Table 2 Summary of Events Caused by Exceptional Drought Conditions

Date Site Concentration ( μg/m 3 )

11/14/2013 Corcoran 162.5

12/17/2013 Corcoran 164.4

12/18/2013 Hanford 177

Corcoran 183.5

Visalia

- Church 155

1/21/2014 Bakersfield

- California 158.5

1/22/2014 Corcoran 156

The events caused by exceptional drought conditions all occurred within a three month period during the winter of 2013

- 2014. During this period, a persistent and strong high pressure ridge over the eastern Pacific Ocean and the western United States effectively

bloc ked weather disturbances from entering California. The historic strength and longevity of this high pressure siege resulted in a shocking lack of rainfall throughout the Valley, and California as a whole, during the months of November, December, and

Januar y. Many cities in California, including those in the San Joaquin Valley, shattered record low rainfall totals during the calendar year 2013, including some records that have stood for over 100 years.

The extreme weather conditions discussed above that led to extreme drought in the Valley also caused long periods of high pressure and stagnation that prevented pollutant dispersion throughout the winter of 2013

- 2014, resulting in PM2.5 and PM10 to become concentrated at extremely high levels th roughout the region , as shown in Figure 2 below . Additionally, the dry conditions from lack of precipitation resulted in the release of more suspended particulate matter into the atmosphere. These conditions led to exceptionally high PM2.5 and PM10 concentrations in the San Joaquin Valley.San Joaquin Valley Unified Air Pollution Control District March 11 , 2016

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- Figure 2 Average Atmospheric Stability per Winter Season (Nov to Feb)

T he District considers the exceptional drought conditions that caused the PM10 events

outlined in Table 2 to be exceptional e vents. Therefore, t he District will be submitting exceptional event documentation for these events to EPA.



### III. Determination of Causes and Needed Reductions

The District considers the exceptional drought conditions that caused the PM10 events outlined in Table 2 to be “exceptional events”. The EPA has also indicated that the prolonged duration and extreme stability conditions of the drought experienced in California may be considered as “exceptional events”. However, since the District has not received a definitive response from EPA regarding t his matter, the District has proceeded with the appropriate analysis and demonstration below that the contingency requirements have been satisfied.

Possible Causes

During the winter season of 2013

- 2014 when the high values found in Table 2 occurred, the Valley experienced the strongest recorded atmospheric stability over the past 15

years. Climate conditions caused by this type of weather pattern resulted in historically dry and poor air quality conditions in the San Joaquin Valley and other parts of

California. Due to the abnormally strong stability and lack of precipitation, the exception al drought continued to worsen beyond this winter season and covered much of the western parts of the San Joaquin Valley and the western U.S. as a whole. This -1.5 -1 -0.5 0 0.5 1 1.5 2 2.5 3 3.5

1999-2000 2000-2001 2001-2002 2002-2003 2003-2004 2004-2005 2005-2006 2006-2007 2007-2008 2008-2009 2009-2010 2010-2011 2011-2012 2012-2013 2013-2014 T850MB Stability Parameter ( ̊C)San Joaquin Valley Unified Air Pollution Control District March 11 , 2016

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- stable pattern effectively trapped pollutants and caused elevated PM10 and PM2.5

concentrations

, resulting in events above the action level

.

Emission Reductions Not Already Used In Maintenance Plan

Since the adoption of the 2007 PM10 Maintenance Plan, multiple rules and regulations have been adopted by the District and ARB to reduce PM10 emission s beyond the commitments in the plan

. In 2015 , the Valley did not experience any PM10 events

above the action level , including during the 2014

- 15 winter season during which the Valley continued to experience drought and stagnation conditions conducive to the

formation of PM10

. In 2016, the Valley has not experienced any PM10 events as of the date of this report. As the discussion below demonstrates and as evidenced by the Valley not experiencing any PM10 events from winter of 2014

- 15 to date

, the stringent

control measures adopted and implemented by the District and ARB beyond those

included in the maintenanc e plan achieve sufficient emissions reductions to minimize

the potential of future PM10 events

. These control measures will achieve even greater emissions reductions as they are fully implemented in the coming years. In addition to these regulatory measures, the District has implemented a robust incentive program

that has achieved significant additional cost

- effective emissions reductions.

District Rules

The District has adopted several rules, substantially reducing PM10 emissions beyond

the 2007 PM10 Maintenance Plan

. One example is Rule 4901( Wood Burning Fireplaces and Wood Burning Heaters )

. It is the most stringent rule of its kind in the nation and significantly reduces particulate matter emissions during periods of atmospheric stagnation when those reductions are needed most. Even though already providing considerable particulat e matter reductions, t he District amended this rule in

October 2008 to reduce particulate matter by an additional 2.4 tons per day. In September of 2014, the District amended it again to lower the curtailment threshold for

non

- registered wood burning devi ces from 30 to 20 μg/m 3 , which is significantly lower than any other rule in the nation

. This amendment further reduced particulate matter emissions by 5.1 tons per day. More reductions will be achieved as Valley residents

continue to replace their existing wood burning fireplaces and wood burning heaters with cleaner devices through the District’s Burn Cleaner incentive program.

The following is a summary of District rules amended or adopted that resulted in significant PM10 emission reductions bey ond the plan.San Joaquin Valley Unified Air Pollution Control District March 11 , 2016

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- Table 3 Summary of Rules Adopted After 2007 PM10 Maintenance Plan

District Rule Adoption/

Amendment Date(s)

Rule 4103 Open Burning 04/15/2010

Rule 4307 Boilers, Steam Gener ators, and Process Heaters

2 to 5 MMBtu/hr 10/16/2008

05/19/2011

Rule 4308 Boilers, Steam Generators, and Process Heaters

0.075 to <2 MMBtu/hr 12/17/2009

11/14/2013

Rule 4311 Flares 06/18/2009

Rules 4306 & 4320 Boilers, Steam Generators, and Process Heaters

>5 MMBtu/hr 10/16/2008

Rule 4352 Solid Fuel Fired Boilers, Steam Generators, and Process

Heaters 12/15/2011

Rule 4354 Glass Melting Furnaces 10/16/2008

09/16/2010

05/19/2011

Rule 4401 Steam

- Enhanced Crude Oil Production Wells 06/16/2011

Rule 4402 Crude Oil Production Sumps 12/15/2011

Rule 4566 Organic Material Composting Operations 08/18/2011

Rule 4570 Confined Animal Facilities 06/18/2009

10/21/2010

Rule 4601 Architectural Coatings 12/17/2009

Rule 4602 Motor Vehicle Assembly Coatings 12/17/2009

Rule 4603 Surface Coating Of Metal Parts And Products, Plastic Parts

And Products, And Pleasure Crafts 10/16/2008

09/17/2009

Rule 4605 Aerospace Assembly and Component Coatings Operations 06/16/2011

Rule 4606 Wood Products and Flat Wood Paneling Products 10/16/2008

Rule 4607 Graphic Arts and Paper, Film, Foil and Fabric Coatings 12/18/2008

Rule 4612 Motor Vehicle and Mobile Equipment Coating Operations 10/21/2010

Rule 4621 Gasoline Transfer into Stationary Storage Containers,

Delivery Vessels, and Bulk Plants 12/19/2013

Rule 4622 Gasoline Transfer into Motor Vehicle Fuel Tanks 12/19/2013

Rule 4 625 Wastewater Separators 12/15/2011

Rule 4653 Adhesives and Sealants 09/17/2009

09/16/2010

Rule 4682 Polystyrene, Polyethylene, and Polypropylene Products

Manufacturing 12/15/2011

Rule 4684 Polyester Resin Operations 09/17/2009

08/18/2011San Joaquin Valley Unified Air Pollution Control District March 11 , 2016

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- District Rule Adoption/

Amendment Date(s)

Rule 4692 Commercial Charbroiling 09/17/2009

Rule 4695 Brandy Aging and Wine Aging Operations 09/17/2009

Rule 4702 Internal Combustion Engines 08/18/2011

11/14/2013

Rule 4901 Wood Burning Fireplaces and Wood Burning Heaters 10/16/2008

09/18/2014

Rule 4902 Residential Water Heaters 03/19/2009

Rule 4905 Natural Gas

- Fired, Fan

- Type Central Furnaces 01/22/2015

Rule 9410 Employer

- based Trip Reduction 12/17/2009

ARB Mobile Source Control Measures

Since the adoption of the 2007 PM10 Maintenance Plan, ARB has adopted numerous mobile source control measures. For example, i n 2012, ARB adopted the On

- Road Heavy

- Duty Diesel Vehicles (In

- Use) Regulation (later readopted in 2014). The regulation requires diesel trucks and buses that operate in California to reduce emissions by replacing older trucks with newer diesel vehicles, r etrofitting engines, and installing diesel particulate filters. This rule has already achieved significant emission reductions, and as the compliance schedule below indicates, the requirement of this

rule will continue to achieve additional emission reduc tion s

.San Joaquin Valley Unified Air Pollution Control District March 11 , 2016

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- In addition to heavy duty trucks, other higher

- emitting heavy

- duty vehicles with long service lives can remain on the road for many years. To address this legacy fleet, ARB adopted heavy

- duty vehicle in

- use control measures to significantly reduce PM and NOx emissions from existing diesel vehicles operating in California. These recent in

- use control measures include:

 Drayage (Port or Rail Yard) Regulation;

 Public Agency and Utilities Regulation;

 Solid Waste Collection Vehicle Regulation;

 ATC M to Limit Diesel

- Fueled Commercial Motor Vehicle Idling;

 Heavy

- Duty Diesel Vehicle Inspection Program;

 Periodic Smoke Inspection Program;

 Fleet Rule for Transit Agencies;

 Lower

- Emission School Bus Program; and

 Heavy

- Duty Truck Idling Requirements.

I n 201 2, ARB also adopted California's Advanced Clean Cars program, a new

emissions

- control program for model years 2017 through 2025. Upon full implementation in 2025

, consumer vehicles will produce 75% less emissions.



### IV. Conclusion

As demonstrated in this docu ment, the District is in compliance with the 2007 PM10

Maintenance Plan and CAA contingency requirements for maintenance plans. F or all of

the PM10 events identified in this document

, t he District is in the process of preparing exceptional event documentation and upon completion will submit the documents to

ARB for eventual transmission to the EPA

. Additionally, f or events caused by exceptional drought conditions, the District has demonstrated compliance with the contingency requirements by determining the possible causes for the events and explaining how the extensive emission s reductions from adopted rules and regulationsSan Joaquin Valley Unified Air Pollution Control District March 11 , 2016

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- beyond those included in the 2007 PM10 Maintenance Plan are sufficient to cover the

events

. As the District continues to develop new attainment plans to address the latest

federal ozone and PM2.5 standards in the coming year, significant additional emissions

reductions are expected , particularly with respect to mobile sources unde r ARB and EPA jurisdiction that make up over 85% of remaining San Joaquin Valley emissions

.