3+~ED ssr UNITEDSTATES ENVIRONMENTAL PROTEC'I'ION AGENCY REGION IX 75 Hawthorne Street San Francisco, CA 941 05 June 29,2006

Mr. George Heinen, P.E. SupervisingAir Quality Engineer San Joaquin Valley Unified Air Pollution Control District 1990E. Gettysburg Ave. Fresno, CA 93726 Re: 8-hour Ozone Reasonably Available Control Technology

- State Implementation Plan (RACT SIP) Analysis, final draft staffreport dated June 15,2006 Dear Mr. Heinen: On April 18,2006, San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) submitted a draft staffreport to demonstrate their rules met Reasonably Available Control Technology (RACT) for the 8-hour ozone standard. On May 18,2006,EPA provided comments to the draft staffreport. SJVUAPCD issued a final draft staffreport on June 15,2006 which addressed several of our comments. EPA has the following comments to further strengthenthe final draft report. As mentioned in our May 18,2006 letter, because RACT SIPS are a new requirement with limited national policy or precedent, we are not yet certain which of these comments reflect approvability issues. 1. Section IV.D.3.a ofthe final draft report summarily states that rules adoptedlamended prior to January 1,2002were evaluated to determine whether the rule requirements were similarto current control technology, and therefore were deemed to fulfill RACT. No details ofthe evaluation, however, were provided. SJVUAPCD should augment the report by providing a summary analysis of selected rules, such asthe nine rules last amended 1992-1 994 and identified in table 1ofEPA's May 18,2006comment letter. This analysis should include a comparison to analogousrequirements in other ozone nonattaiment areas. 2. The District shouldprovide a summary analysis ofrules specifically identified in public comments onthe draft RACT SIP, including solid fuel boilers, glass melting furnaces and flares. 3. Section V.A. states the District will submit a number ofrules for inclusion into the SIP by March 15, 2009. These rules include certain pre-unification rules and rules not previously submitted and may be needed for RACT as discussed in table 2 of EPA's May 18,2006comment letter. These rules should be submitted promptly for SIP approval, instead ofby March 2009.4. Thereport should clarify why Rule 4652 was dropped from the final draft analysis. If there are major coatinglink manufacturing facilities in the District, Rule 4652 should be analyzed for current RACT and submittedto EPA for SIP approval. 5. In Section 1V.C.1and in other locations,the District indicates a RACT rule must be implemented by March 15,2009. Since Californiahas a year long ozone season,this date should be revised to January 1,2009. EPA understands it may be difficult to fully address all the comments received before the RACT SIP deadline, particularly in light ofrelated obligations such as the ozone attainment plan, but we encourage San Joaquin to submit as complete a RACT SIP aspossible by September 2006 and to supplement materials shortlythereafter. Ifyou have any questions regardingthese comments,please feel free to contact me or StanleyTong at (41 5) 947-4122. Sincerely,

~ndrew Steckel, Chief, Rulemaking Office

cc: Sandra Lowe-Leseth, (SJVUAPCD) Ravi Rarnalingam (CARB)