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UNITED STATES ENVIRONMENTAL PROTEC'I'ION AGENCY 
 

REGION IX 
 

75 Hawthorne Street 
 

San Francisco, CA 94105 
 

June 29,2006 

Mr. George Heinen, P.E. 

Supervising Air Quality Engineer 

San Joaquin Valley Unified Air Pollution Control District 

1990 E. Gettysburg Ave. 

Fresno, CA 93726 

Re: 	 8-hour Ozone Reasonably Available Control Technology - State Implementation Plan 

(RACT SIP) Analysis, final draft staff report dated June 15,2006 

Dear Mr. Heinen: 

On April 18, 2006, San Joaquin Valley Unified Air Pollution Control District 

(SJVUAPCD) submitted a draft staff report 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 staff report. SJVUAPCD issued a final draft staff report on June 15,2006 

which addressed several of our comments. EPA has the following comments to further 

strengthen the 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 of the final draft report summarily states that rules adoptedlamended 

prior to January 1,2002 were evaluated to determine whether the rule requirements were 

similar to current control technology, and therefore were deemed to fulfill RACT. No 

details of the evaluation, however, were provided. SJVUAPCD should augment the 

report by providing a summary analysis of selected rules, such as the nine rules last 

amended 1992-1 994 and identified in table 1 of EPA's May 18,2006 comment letter. 

This analysis should include a comparison to analogous requirements in other ozone 

nonattaiment areas. 

2. 	 The District should provide a summary analysis of rules specifically identified in public 

comments on the draft RACT SIP, including solid fuel boilers, glass melting furnaces and 

flares. 

3. 	 Section V.A. states the District will submit a number of rules 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 

18,2006 comment letter. These rules should be submitted promptly for SIP approval, 

instead of by March 2009. 
4. 	 The report 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 submitted to EPA for SIP approval. 

5. 	 In Section 1V.C. 1 and in other locations, the District indicates a RACT rule must be 

implemented by March 15,2009. Since California has 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 of related obligations such as the ozone attainment plan, 

but we encourage San Joaquin to submit as complete a RACT SIP as possible by September 

2006 and to supplement materials shortly thereafter. 

If you have any questions regarding these comments, please feel free to contact me or 

Stanley Tong at (4 1 5) 947-4 122. 

Sincerely, 

~ndrewSteckel, 

Chief, Rulemaking Office 

cc: Sandra Lowe-Leseth, (SJVUAPCD) 

Ravi Rarnalingam (CARB)