UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105 

May 18,2006 

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, draft staff report dated April 18,2006 

Dear Mr. Heinen: 

We greatly appreciate SJVUAPCD staff efforts to develop a RACT SIP submittal for the 

Valley. This is the most thorough such analysis that we have reviewed to date and, for the most 

part, we think it responds well to the RACT SIP requirements in Clean Air Act Section 182. We 

have, however, summarized several suggestions below for further improvement. 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. 

General Comments 

1. Particularly where the last RACT determination for specific source categories occurred 

many years ago, the staff report should reflect some analysis that RACT has not 

subsequently changed. At a minimum, for those rules listed in Enclosure (I), a statement 

should be included that the District is not aware of any significant changes in technology 

that affect the original RACT determination. Additional analysis may also be 

appropriate. 

2. The staff report should include a conclusion section summarizing the District's procedure 

in performing the RACT SIP certification. 

3. Appendix B lists the major sources within the District. We suggest adding a column to 

this list identifying the District rules that address the primary emissions at each facility. 

4. Please clarify the term "California state rulemaking requirements," in Appendix D. 

Negative Declaration 

5. Section III.C.l indicates that SJVUAPCD will verify that there are no sources within 

District boundaries for a given CTG source. This procedure (e.g., search of the permits 
database, emission inventory, SIC Code, yellow pages etc.,) should be described in the 

final staff report. 

District Rules 

6. Table C-5 lists four rules that have not been submitted to EPA for inclusion into the SIP. 

These rules should be submitted promptly if required for the RACT certification (i.e., if 

they control major non-CTG sources.) 

7. Some portions of the staff report identify SIP approved rules from the single-County 

Districts (e.g., Fresno, Kern) that eventually joined to form the SJVUAPCD. Many of 

these pre-unification rules were last amended around 1992 and subsequently superceded 

by analogous SJVUAPCD rules. Enclosure (2) identifies several of the updated 

SJVUAPCD rules that we believe are relied on to implement RACT and should be 

submitted promptly to EPA. 

8. Enclosure (3) lists three SIP-approved rules that do not appear in the draft staff report. 

Please review them and add to the staff report as appropriate. 

9. Rule 4622 (page A-9) should be deleted from the tank truck category. The CTG is 

applicable to Gasoline Tank Trucks and the vapor collection systems associated with the 

tank trucks while Rule 4622 is applicable to the transfer of gasoline into motor vehicle 

fuel tanks. 

Please keep in mind that RACT SIP rules and negative declarations should be submitted 

to EPA by September 15,2006. Final implementation dates should be no later than the first 

ozone season that occurs 30 months later. For San Joaquin, we believe that is January 1,2009. 

The District's complete response to public comments should be included in the SIP Submittal. 

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, 

Chief, Rulemaking Office 

Enclosures. 

cc: Sandra Lowe-Leseth, (SJVUAPCD) 

Ravi Ramalingam (CARB) 
-- 

Table 1 - Rules needing further clarification that they still represent RACT if needed for RACT 

District Rulerritle 

4402 Crude Oil Production Sumps 

4407 In-situ Combustion Well Vents 

4625 Wastewater Separators 

4641 Cutback, Slow Cure, and Emulsified Asphalt 

Paving and Maintenance Operations 

4651 Volatile Organic Compound Emissions from 

Decontamination of Soil 

4672 Petroleum Solvent Dry Cleaning Operations 

4681 Rubber Tire Manufacturing 

4682 Polystyrene Foam, Polyethylene, and 

Polypropylene Manufacturing 

4691 Vegetable Oil Processing Operations 

Amended 

-

Rule SIP FR action Staff rpt 

page # 

Approved as Rule 465.02 C3 

FR Vol. 59 pg. 64132 

FR Vol. 60 pg. 12121 

Approved as Rule 463.4 FR Vol. 58 pg. 

28354 

Approved as Rule 463.01 FR Vol57 pg 

28089 

FR Vol. 61 pg. 38571 

Approved as Rule467.02 FR Vot. 57 pg. 

15026 

FR Vol. 63 pg. 43881 

FR Vol. 60 pg. 31086 

Approved as Rule 461.2 FR Vol. 59 pg. 

2535 

Enclosure (1 ) 
Table 2 - Rules that should be submitted for SIP approval if necessary for RACT (pre-unificationhot previously in SIP) 

District Rulerritle Date Last Rule SIP FR action Staff rpt 

Adopted Amended 

4404 Heavy Oil Test Station - Kern County 5/21/1992 1211 711 992 not in SIP 

4405 Oxides of Nitrogen Emissions from Existing 5/21/1992 1211 711 992 not in SIP C4; C8 

Steam Generators Used in Thermally Enhanced 

Oil Recovery - Central and Western Kern Ctv 

4453 Refinery Vacuum Producing Devices of Systems 5/21/1992 1211 711992 Essentially identical to Kern Cty SIP A7; C4 

approved Rule 414.2 46 FR 42459); Kings 

Cty SIP-approved Rule 414.2 & San 

Joaquin Cty SIP-approved Rule 41 3.2 (47 

FR 19696) 

4454 Refinery Process Unit Turnaround 5/21/1992 1211 711 992 Essentially identical to SIP-approved, A7; C4 

Kern County Rule 414.3 FR Vol. 46 pg. 

42460 

4624 Organic Liquid Loading 1 411 111991 1 1211 111992 not in SIP C5;C8 

4652 Coatings and Ink Manufacturing 

I

1 5/21/1992 

I

1 12/17/1992 not in SIP C5;C8 

Enclosure (2) 
Table 3 - SIP approved rules that should be added to RACT analysis table if necessary 

District Rulerritle Date 1 last Rule SIP FR action I staff rpt 

I 


Adopted I Amended 

4403 Components serving light crude oil or gases at 

light crude oil and gas production facilities and 

components at natural gas processing facilities 

4451 Valves, pressure relief valves, flanges, threaded 

connections and process drains at petroleum 

refineries and chemical plants 

4452 Valves, pressure relief valves, flanges, threaded 

connections and process drains at petroleum 

refineries and chemical ~lants 

Enclosure (3)