UNITED STATES ENVIRONMENTAL PROTECTIONAGENCY 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 1990E. 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 permitsdatabase, 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 submittedto 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 eventuallyjoined 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 shouldbe 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) shouldbe 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 SIPrules 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. Ifyou have any questions regarding these comments, please feel free to contact me or Stanley Tong at (41 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 CombustionWell 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 Rule463.4 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 FRVol. 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 ifnecessary 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 1211711992 not in SIP 4405 Oxides of Nitrogen Emissions from Existing 5/21/1992 1211711992 not in SIP C4; C8 Steam Generators Used in Thermally Enhanced Oil Recovery- Central and Western Kern Ctv 4453 RefineryVacuum Producing Devices of Systems 5/21/1992 1211711992 Essentially identical to Kern Cty SIP A7;C4 approved Rule 414.2 46 FR 42459); Kings Cty SIP-approved Rule414.2 & San Joaquin Cty SIP-approved Rule413.2 (47 FR 19696) 4454 Refinery Process Unit Turnaround 5/21/1992 1211711992 Essentially identical to SIP-approved, A7;C4 Kern County Rule414.3 FR Vol. 46 pg. 42460 4624 Organic Liquid Loading 

# 1 411 111991 

# 1 1211111992 not in SIP C5;C8 4652 Coatingsand Ink Manufacturing I 

# 1 5/21/1992 I 

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

Enclosure (2)Table 

### 3 

### - SIP approvedrules that shouldbe added to RACT analysis table ifnecessary District Rulerritle Date 

# 1 last Rule SIP FR action 

# I staff rpt Adopted 

## I Amended 

### I 4403 Components serving light crude oil or gases at light crude oil and gas production facilities and componentsat 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)