UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105 

February 7, 2008 

Mr. George Heinen, P.E. 

Supervising Air Quality Engineer 

San Joaquin Valley 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 December 17,2007 

Dear Mr. Heinen: 

Thank you for the opportunity to comment on San Joaquin Valley Air Pollution Control 

District's (SJVUAPCD) draft staff report on Reasonably Available Control Technology (RACT) 

for the 8-hour ozone standard, and for the additional time to review it. The District has amended 

a number of rules since the previous August 17,2006 RACT SIP analysis. The current RACT 

analysis adjusts the major source threshold down to 10 tons per year (tpy) to match a request for 

reclassification as an extreme ozone nonattainment area. The analysis also evaluates the 

District's rules against four new Control Technique Guidelines (CTGs) which were issued in 

September 2006. EPA has the following comments on the draft report. Because RACT SIPS 

have limited national policy or precedent, we are not yet certain which of these comments might 

reflect approvability issues. 

1. The District identified 41 9 facilities which emit or have the potential to emit between 

10 - 25 tpy of NOx or VOC. A number of additional petroleum facilities were captured 

by this process. The District should re-review selected petroleum rules for RACT. For 

example, a 2007 report by the Mid-Atlantic Regional Air Management Association 

(MARAMA) provides a good assessment of control options for petroleum refineries. 

Their analysis of flares concludes that emissions from this category may be significantly 

underreported in current emission inventories and includes a comparison of controls by 

the Bay Area Air Quality Management District (BAAQIVID), South Coast Air Quality 

Management District (SCAQMD), and the Texas Commission on Environmental Quality 

(TCEQ). The report points out that SCAQMD estimates a 53% reduction in vent gases 

from amendments to their flare rule at a cost effectiveness of approximately $4,500 - 

$8,600 per ton. Further, the report summarizes that the typical payback period for flare 

gas recovery installations is 2 - 4 years. Although the purpose of the MARAMA report is 

to assist their States in developing rules to help attain the 8-hour ozone standard, and is 

not intended to define RACT, we believe it contains useful information. 
We recognize that the District plans to revisit Rule 43 1 1 - Flares, in the future. As 

pointed out in our November 20,2007 proposed approval of Rule 43 1 1, and given the . - - - 

request for reclassification to extreme ozone non-attainment, we encourage the District to 

incorporate appropriate provisions from SCAQMD and BAAQMD flare rules to 

minimize excess flaring activity. Although the refinery capacity in San Joaquin is 

smaller than that of SCAQMD and BAAQMD, even taking an initial step such as 

requiring the monitoring and reporting of flaring events will help to identify flaring 

events that may have become routine as opposed to limited events for emergency and 

plant safety actions. The District should also consider a requirement for refineries to 

develop and submit a flare minimization plan as has been done in the SCAQMD and 

BAAQMD. 

http://www.marama.org/rep0rts/O2 1907 Refinery Control Options TSD Final.pdf 

http://www.aqmd.~ov/comply/docs/l 1 18staffreport.pdf 

http://www.baaqmd.gov/pln/ruledev/12- 1 1/2003/12 1 1 sr may2003 .pdf 

http://www.baaqmd.gov/pln/ruledev/l2-12/12 12 sr 0708.pdf 

Appendix D of the RACT SIP analysis indicates Rule 43 1 1, Flares, amended on 

6/20/2002 was cited in the CAPCOA 2003 Potential All Feasible Measures meaning that 

the NOx and VOC emission limits have undergone recent BARCT analysis. Please 

include a copy of the appropriate CAPCOA page(s) in the RACT SIP analysis. 

2. Appendix E provides an analysis of the following four CTGs issued by EPA in 2006: 

Industrial Solvent Cleaning, Offset Lithographic and Letterpress Printing, Flexible 

Package Printing, and Flatwood Paneling Coatings. EPA has the following comments: 

Industrial Solvent Cleaning - The District's analysis states specific categories of solvent 

cleaning have higher limits than the 50 g/l recommended by the CTG, but technical 

assessment and cost effectiveness analysis during the District's rulemaking process 

have determined that these higher limits represent RACT for the particular solvent 

cleaning category. 

Comment - The District may want to investigate whether the categories that exceed 

the CTG recommended levels are covered under the CTG and update the analysis as 

appropriate. If the categories are covered under the CTG, the District should include 

a copy of their rulemaking analysis, highlighting the appropriate sections that lead to 

the conclusion that the higher limits represent RACT for the solvent cleaning 

category. 

Although a State or local District may be less restrictive than a CTG, a thorough 

analysis would generally be required explaining why the CTG level would not be cost 

effective for a particular area. In the past, such showings have been hard to make and 

few have been approved. If a CTG level is cost effective for the rest of the country, a 

State or local air district would have to show unusual circumstances to justify why it 

is not cost or technologically effective for that area. 
Offset Lithographic and Letterpress PrintingFlexible Package PrintingEPA understands San Joaquin is currently amending Rule 4607 - Graphic Arts, which 

covers the above two CTGs. EPA will be submitting separate comments on the draft 

amendments and whether those amendments meet the CTGs. 

Flat Wood Paneling Coatings - The RACT SIP analysis indicated District staff 

researched the District database of wood manufacturing and coating facilities and 

permits and did not identify any flat wood paneling manufacturing and coating 

facilities. 

Comment - The staff report should include a search of additional sources such as SIC 

Codes, telephone yellow pages, and an internet search. The staff report should also 

indicate District also does not anticipate these sources in the future. 

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, 

~ndrew Steckel, 

Chief, Rulemaking Office 

cc: David Welk, (SJVUAPCD) 

Sandra Lowe-Leseth, (SJVUAPCD) 

Ravi Ramalingam (C ARB)