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Specific EPA comments on SJV RACT-SIP

SJ 4306 – Boilers, Steam Generators and Process Heaters, > 5 MMBtu/hr 

The October 16, 2008 version of this rule, referred to in the RACT analysis, has not been 

submitted for SIP approval. The District should submit the rule. 

SJ 4307 – Boilers, Steam Generators and Process Heaters, 2 – 5 MMBtu/hr 

The October 16, 2008 version of this rule, referred to in the RACT analysis, has not been 

submitted for SIP approval. The District should submit the rule. 

SJ 4311 – Flares 

The conclusion on page 4-58 states that the District is amending the rule to incorporate flare 

minimization plans (FMPs) and expects to submit the amendments to its Board in the second 

quarter of 2009. Incorporation of an FMP requirement will help demonstrate implementation of 

RACT. 

SJ 4352 – Solid Fuel Boilers, Steam Generators and Process Heaters 

Page 4-68 states that a 40 ppm NOx emission limit is technologically infeasible for solid fuel 

fired units. The District should include or reference documentation to support this conclusion. 

SJ 4354 – Glass Melting Furnaces 

On page 4-71, the District states that the limits in Rule 4354 are more stringent than all other 

analogous limits except flat glass in the BAAQMD rule, and that there are no flat glass furnaces 

in the BAAQMD. The District should document that there are no such units in the BAAQMD, at 

least with reference to communication with BAAQMD staff. 

SJ 4402, Crude Oil Production Sumps 

EarthJustice has commented that this rule has more exemptions than other Districts and that 

SJVAPCD’s 8-hour ozone attainment plan identified the inventory as 3-60 tons of VOC per 

day. SJVAPCD’s current analysis estimates the inventory at 0.4 tpd VOC and explains why 1st

stage tanks are not necessarily better than sumps. The analysis further explains that other 

exemptions are not cost effective or have negligible emission differences. We recommend the 

analysis also clarify how the original 3-60 tpd inventory was in error. 

SJ 4570 – Confined Animal Facilities 

In light of the nature of the industry, the limited regulatory history and the additional information 

expected in the near term, the District’s draft RACT analysis may be appropriate for many CAF 

activities. However, additional analysis seems appropriate for those activities with relatively 

large emissions and potentially smaller variability, such as avian CAFs. Specifically, we 

recommend closer analysis of the avian CAF menus provided in the rule to see if specific menu 

options can be required because they are widely available, economically feasible and effective at 

reducing emissions. 

SJ 4602/4612 – Motor Vehicle and Mobile Equipment Coating Operations

We recommend the District include a brief discussion of CARB’s Suggested Control Measure 

for auto-refinishing in the RACT analysis. 
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SJ 4603 – Surface Coating of Metal Parts and Products 

Page 4-174 notes several areas where the 2008 CTG is more stringent than Rule 4603 (e.g., VOC 

limits for baked extreme performance and repair and touch up coatings, and work practice 

standards for miscellaneous metal parts and products). Rules meeting the 2008 CTGs are 

required within one year of the date the CTGs are finalized (i.e., September 30, 2009). 

SJ 4605 – Aerospace Assembly and Component Coating Operations 

The analysis states that EPA approved Rule 4605 on May 30, 2007. However, we believe that 

EPA last approved Rule 4605 on December 20, 2001 and that more detailed RACT discussion is 

therefore appropriate. 

SJ 4606 - Wood Products 

Rule 4606 exempts refinishing, replacement and custom replica furniture coating operations, 

while the CTG and rules from other Districts do not. More detailed discussion of this exemption 

in the RACT analysis seems appropriate. 

SJ 4641 - Cutback, Slow Cure and Emulsified Asphalt Paving and Maintenance Operations 

Please explain why the exemption for medium cure asphalt for ambient temperature less than 50 

degrees F is allowed. 

SJ 4651 - Soil Decontamination Operations 

Please change “Municipal Waste Disposal Sites” to “Soil Decontamination Operations” in the 

conclusion. 

SJ 4653 – Adhesives 

Page 4-294 states that the District will evaluate the September 2008 CTG for inclusion into 

District rules within one year. We note that submittal (not just evaluation) of rules (or negative 

declarations) meeting the 2008 CTGs are due by September 2009. We also note SJVAPCD’s 

determination that Rule 4653 is less stringent than some other District adhesive limits and that 

more detailed evaluation of RACT during the next amendment to the rule is appropriate. 

SJ 4682 – Polystyrene Foam, Polyethylene, and Polypropylene Manufacturing 

Additional information would be useful justifying the 93% capture/control efficiency option and 

30-day averaging. 

SJ 4684 – Polyester Resin Operations 

Page 4-338 concludes that Rule 4684 does not satisfy RACT. We appreciate the District’s 

analysis, and are available to review proposed changes to the rule. 

SJ 4694 – Wine Fermentation and Storage Tanks 

The brief discussion starting on page 4-347 provides some support for the District’s finding that 

this rule implements RACT. We note that it does not address the extensive cost-effectiveness 

analysis previously performed by the District or the alternative compliance options identified as 

concerns by EPA on October 24, 2005, and in subsequent correspondence. 
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SJ 4702 – IC Engines, Phase 2 

The District states that they did not pursue a thorough RACT analysis because EPA approved the 

rule into the SIP on May 30, 2007. We believe the correct date is January 10, 2008. 

SJ 4703 – Stationary Gas Turbines 

Page 4-353 states that a detailed RACT analysis is not needed because EPA approved the rule on 

May 30, 2007. We believe the last version approved was amended in 2002 approved by EPA in 

2004, and the RACT analysis should be revised appropriately.