**UNITED STA TES ENVIRONMENTA**  **L PROTECTION A GENCY**  **REGION IX A IR DIVISION** 

Technical Support Document

for EPA' s Proposed Rulemaking

for the California State Implementation Plan

EPA’s Evaluation of Imperial County Air Pollution Control Distri ct , Final 200 9 Reasonably Available Control Technology

State Implementation Plan

Dated Ju ly 13 , 20 10 Adopted Ju ly 13 , 20 10

Prepared by: James Shears Reviewed by: Andrew Steckel

Ju ly 201 5- 2 -

**RULE IDENTIFICA**

**TION** - **Ag ency**  **:** Imperial County Air Pollution Control District ( ICA PC D ) **SIP A pproved**  **Version :**  None **S ubject of this TSD:**  ICAPCD Final 20 0 9 Reasonably Available Control Technology State Implementation Plan – Dated Ju ly 13 , 20 10 (“20 0 9 RACT SIP”) Adopted Ju ly 13 , 20 10 S ubmitted December 21 , 20 10 **BA CKGROUND**  Volatile organic compounds (VOCs) and nitrogen oxides (NOx) in the presence of sunlight can lead to the formation of ground - level ozone or “smog” which can result in significant impacts to human health and the environment. Section 182 of the Clean Air Act (CAA) requires areas that are classified as moderate or above for ozone nonattainment to implement reasonably available control technology (RACT) for specific types of sources. Wi th the implementation of the 1997 8 - hour National Ambient Air Quality Standard (NAAQS) for ozone, Imperial County Air Pollution Control District (ICAPCD or the District ) was classified as a marginal nonattainment area 1 . Subsequently, EPA found that Imperial County did not meet the a ttainment deadline of June 15, 2007, and reclassified it as a moderate nonattainment area with an attainment deadline of June 15, 2010 2

. On December 3, 2009, EPA issued a final rule 3 determining that Imperial County attained the 1997 8 - hour NAAQS based on ambient air monitoring data for the years 2006 through 2008. Although the finding of attainment by EPA suspend ed certain State Implementation Plan (SIP) related requirements, it did not suspend the RACT requirements for VOCs and NOx under CAA section 1 82 . Pursuant to 40 CFR 51.912(a)( 1), the State (or local air district) must submit a SIP revision that meets the VOC and NO X RACT requirements in CAA section 182(b)(2) and (f) for each area classified moderate or higher . Therefore, ICAPC D must, at a minim um, adopt RACT - level controls for sources covered by a Control Techniques Guidelines (CTG) document and for any major stationary source of VOCs or NOx. 4 EPA defines RACT as the “lowest emissions limitation that a particular source is capable of meeting b y the application of control technology that is reasonably available considering 1 69 FR 23858 (April 30, 2004) 2 73 FR 8209 (February 13, 2008) 3 74 FR 63309 (December 3, 2009) 4 CAA § 182(b)(2) and (f) .- 3 -

technological and economic feasibility.” 5 A RACT analysis should, therefore, take into account the technological and economic feasibility of controls, and may differ from source to source and location to location. **SUBMITTA L**  **SUMMA RY**  **and EPA EVA**  **LUA**

**TION** The District adopted its 20 09 RACT SIP on Ju ly 13 , 20 10 and the California Air Resources Board (CARB) submitted it to EPA on December 21 , 20 10 . The CARB submittal included a co mpleteness checklist which indicated the package met the completeness criteria in 40 CFR Part 51, Appendix V . The submittal became complete by o peration of l aw on June 21, 20 1 1 pursuant to CAA §110(k)(1)(B) . ICAPC D ’ s 200 9 RACT SIP included the followi ng documents: a. Imperial County Air Pollution Control District Final 20 0 9 Reasonably Available Control Techn ology State Implementation Plan, Ju ly 13 , 20 10 . b. Resolution of the Imperial County Air Pollution Control District Board approving and adopting the Fina l 2009 Reasonably Available Control Technology State Implementation Plan - adopted on Ju ly 13 , 20 10 . ICAPC D ’ s analysis evaluated the following areas. Further discussion is provided below.  VOC rules for sources subject to a CTG .  Negative declarations w here there are no facilities s ubject to a CTG .  M ajor non - CTG sources of VOC or NOx . Subsequent to its adoption of the 200 9 RACT SIP, ICAPC D amended or adopted a number of rules and submitted th em to EPA for approval into the SIP. Upon SIP approval, t hese subm ittals effectively supplanted the corresponding rules, if any, in the 200 9 RACT SIP. EPA evaluated the following elements of ICAPC D ’s 20 0 9 RACT SIP and subsequent submittals :  Efforts to identify all source categories within the District requiring RACT .  N e gative declarations where there are no facilities subject to a CTG .  List of the State/local regulations that implement RACT .  T h e bases for concluding that all referenced regulations fulfill RACT . The following documents were also used to support our revie w:  “ Final Rule to Implement the 8 - Hour Ozone National Ambient Air Quality Standard – Phase 2 ” (70 FR 71612; November 29, 2005).  “ State Implementation Plans, General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990 ” (57 FR 13498; April 16, 1992).  Enforceability - Section 110(a) of the CAA requires enforceable emission limitations and other control measures. Several EPA guidance documents are used to evaluate rule 5 70 FR 71612 , 71652, n. 57 (November 29, 2005) (citing 44 FR 53761 (September 17, 1979))- 4 -

enforceability, including Issues Relating to VOC Regulation Cu tpoints, Deficiencies, and Deviations: Clarification to Appendix D of November 24, 1987 FEDERAL REGISTER, May 25, 1988 , Revised January 11, 1990 ("The Blue Book"), and EPA Region IX’s Guidance Document for Correcting Common VOC and Other Rule Deficiencies , August 21, 2001 (the "Little Bluebook").  “ State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for Implementation of Title I of the C lean Air Act Amendments of 1990 ” (57 FR 55620, November 25, 1992) ("the NOx Supplement").  “Mode l Volatile Organic Compound Rules for Reasonably Available Control Technology”, EPA (June 1992).  “Beyond VOC RACT Requirements”, EPA (April 1995).  Memorandum from W illiam T. Harnett to Regional Air Division Directors, (May 18, 2006), “RACT Qs & As – Reason ably Available Control Technology (RACT) Questions and Answers”.  RACT SIPs, Letter dated March 9, 2006 from EPA Region IX (Andrew Steckel) to CARB (Kurt Karperos) describing Region IX’s understanding of what constitutes a minimally acceptable RACT SIP.  EPA's CTGs http://www.epa.gov/groundlevelozone/SIPToolkit/ctgs.html  CARB’s emissions inventory database http://www.arb.ca.gov/app/emsinv/facinfo/facinfo.php  CARB and EPA Region IX databases of ICAPC D rules CARB: http://www.arb.ca.gov/rldb/rldb.htm EPA: http://epa.gov/region09/air/sips/index.html **1. VOC**  **R ules**  **for S**  **ources S**  **ubject to a**  **CTG** ICAPC D Action : Table 1 of the 2009 RACT SIP identifies 11 CTGs which apply to sources in Imperial County and therefore must be addressed in the RACT SIP. The 11 CTGs iden tified by ICAPCD and the corresponding ICAPCD rules are as follows: **CTG Source Category CTG Reference Document**  **ICA CPD Rule**  Gasoline Service Stations Design Criteria for Stage I Vapor Control Syste ms – Gasoline Service Stations, EPA-450/R- 75 - 102 1975/11 415 Transfer and Storage of Gasoline Tank Trucks, Gasoline Loading Terminals Control of Hydrocarbons from Tank Tr uck Gasoline Loading Terminals, EPA-450/2 - 77 - 026 1977/10 415 Transfer and Storage of Gasoline Bulk Gasoline Plants Control of Volatile Organ ic Emiss ions from Bulk Gasoline Plants, EPA-450/2 - 77 - 035 1977/12 415 Transfer and Storage of Gasoline External Floating Roof Tanks, Petroleum Liquid Storage in Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating Roof T anks, EPA450/2 - 78 - 047 1978/12 414 - Storage of Reactive Organic Compound Liquids- 5 -

**CTG Source Category CTG Reference Document**  **ICA CPD Rule**  Tank Trucks, Gasoline and Vapor Collection Systems Control of Volatile Organic Compound Leaks from Gasoline Tank Truc ks and Vapor Collection Systems, EPA-450/2 - 78 - 051 1978/1 2 415 Transfer and Storage of Gasoline Solvent Metal Cleaning Control of Volatile Organic Emissio ns from Solvent Metal Cleaning, EPA-450/2 - 77 - 022 1977/11 413 Organic Solvent Degreasing Operations Storage of Petroleum Liquids in Fixed Roof Tanks Control of Volatile Organic Emissions from Storage of Petrol eum Liquids in Fixed - Roof Tanks, EPA-450/2 - 77 - 036 1977/12 414 - Storage of Reactive Organic Compound Liquids Industrial Cleaning Solvents Control Techniques Guidelin es for Industrial Cleaning Solvents, EPA-453/R- 06 - 001 2006/09 417 Organic Solvents Cutback Asphalt Control of Volatile Organic Emissions from Use of Cutback Asphalt, EPA-450/2 - 77 - 037 1977/12 426 Cutback Asphalt and Emulsified Paving Automobile Refinishing Reduction of Volatile Organic Compo und Emissio ns from Automobile Refinishing, EPA-450/3 - 88 - 009 1988/10 413 Organic Solvent Degreasing Operations 427 Automotive Refinishing Operations Aerospace Aerospace(CTG&MACT), EPA-453/R- 97 - 004 1997/12 425 Aerospace Coating Operations Table 5 of th e 2009 RACT SIP presents a comparison of the District ’ s rules to similar rules in other air districts. Based on this analysis, ICAPCD concluded that its rules fulfill RACT requirements. EPA Evaluation : EPA reviewed the above rules, found they satisfie d RACT, and approved them into the SIP on the following dates. Weare not aware of information suggesting that additional controls are needed to fulfill RACT since our approval of these rules. Wh ere applicable, additional details and suggestions for future rule improvements are provided below. Rule 413 Organic Solvent Degreasing Operations ( 67 FR 67313, November 5, 2002); Rule 414 Storage of Reactive Organic Liquid Compounds ( 73 FR 70883, November 24, 2008); Rule 415 Transfer and Storage of Gasoline (70 FR 8520, February 22, 2005) ;- 6 -

Rule 417 Organic Solvents ( 67 FR 67313 November 5, 2002); Rule 4 2 5 6 Aerospace Coating Operations ( 76 FR 67369, November 1, 2011); Rule 426 Cutback Asphalt and Emulsified Paving Materials ( 66 FR 20084 April 19, 2001); and Rul e 427 Automobile Refinishing Operations ( 76 FR 67369, November 1, 2011). For Rule 413, subsequent to the 2009 RACT SIP submittal, ICAPCD found it had no sources of organic solvent cleaning with in the District that would be subject to the 1977 Solvent Me tal Cleaning CTG . 7 ICAPCD should formally adopt a negative declaration including a public hearing, and submit it to EPA for inclusion into t he S IP. Wealso recommend ICAPCD update Rule 413 (last amended in 2001) to more closely match VOC solvent cleaning limits adopted by nearby air districts with a similar ozone nonattainment classification. Some air districts have adopted solvent cleaning limits of 25 g/l for general solvent cleaning operations 8

. Rule 415 was approved by EPA in 2005 as meeting RACT. Although this approval occurred before ICAPCD was reclassifi ed from marginal to moderate ozone nonattainment , we believe the rule still satisfies RACT . We recommend ICAPCD consider lowering the gasoline bulk terminal emissions limit to 0.04 pounds/1000 ga llons the next time this rule is amended . 9 For Rule 417, subsequent to the 2009 RACT SIP submittal, ICAPCD found it had no sources subject to the 2006 Industrial Cleaning Solvents CTG’s nine unit operations. 7 ICAPCD should formally adopt a negative de claration with a public hearing, and submit it to EPA for inclusion in to the S IP. Wealso recommend ICAPCD update Rule 417 (last amended 1999) to more closely match VOC content limits adopted by other air districts . Some air districts have adopted solven t cleaning limits of 25 g/l for general solvent cleaning operations. 9 Regarding Rule 426, the VOC limits for cutback and emulsified asphalt are similar to South Coast Air Quality Management District ( SCAQMD ) Rule s 1108 and 11 0 8.1 , both of which are SIP - a pproved. In 2008, SCAQMD conducted a technical assessment of Rule s 1108 and 1108.1 and concluded that slow cure asphalt does not emit as much VOC as replacement emulsions do, and did not recommend making any changes to their asphalt rule s . 10 EPA reviewed S CAQMD’s technical assessment which estimated that slow cure cutback asphalt would emit 0.04 tons/day, but emissions could increase to 0.98 tons/day if emulsified asphalt (3% VOC) were substituted for slow cure (0.5% VOC) cutback asphalt. The increased 6 Wi th regard to Rule 425, we note that ICAPCD has certified that it has no sources subject to the aerospace coating CTG. Therefore, ICAPCD is not required to adopt RACT requirements for this source category . 7 ICAPCD - Sup plemental to 2009 RACT SIP - Analysis of Control Technologies Guidance (CTG) Documents, July

31, 2015. 8 See Sacramento Metropolitan AQMD Rule 466 ( http://airquality .org/rules/rule466.pdf) and South C oast AQMD Rule 1171 ( http://www.aqmd.gov/docs/default- source/rule - book/reg -xi/rule 1171.pdf?sfvrsn=4 ). 9 See Bay

Area AQMD Rule 8 - 33 section 8 - 33 - 301.2 (effecti ve 1/10/2011) 10 See South Coast Air Quality Management District, “Technical Assessment for Rule 1108 – Cutback Asphalt”, June 2008.- 7 -

emis sions would primarily be due to the higher VOC limit allowed for emulsified asphal t. EPA accepted the SCAQMD technical assessment of its asphalt rules as satisfying RACT. For the same reasons, we believe that ICAPCD Rule 426 satisfies RACT. If additional VOC/PM 2.5/ NOx reductions are needed for attainment of the NAAQS , the District may want to investigate use of warm mix asphalt as an alternative to hot mix asphalt . 11 Regarding Rule 427, automobile refinishing is not a CTG category 12 and ICAPCD does not have any major sources of automobile refinishing, so this rule is not required to meet RACT. **2. N**  **egative D**  **eclarations W**  **here T**  **here are no F**  **acilities S**  **ubject to a CTG** ICAPC D Action : Table 2 “ CTG/ACT Listing with no applicable sources ” of the ICAPC D 200 9 RAC T SIP identifies the CTG source categories for which the District has no relevant stationary sources . ICAPCD compiled this list by comparing its rules against EPA’s list of CTGs and ACTs , reviewing its permits and emissions inventory, and consulting with k nowledgeable staff of the District’s permit and enforcement divisions. For the negative declarations listed in ICAPCD ’s 20 0 9 RACT SIP Table 2, the District also indicated it does not anticipate sources in t hese categories in the future. EPA E valuation : Negative d eclarations are only required for CTG source categories where the District has no sources subject to a CTG . A negative declaration is not required for ACTs or for other non CTG source categories. T able 1 below lists the CTG source categories incl uded in ICAPCD’s 2009 RACT SIP Table 2 . Wesearched CARB’s emissions inventory database to verify there are no facilities in ICAPC D that might be subject to the se CTGs , and concur with the District’s negative declaration s . Table 1 – ICAPC D Negative Decla rations CTG Source Category CTG Reference Document Aerospace EPA- 453/R- 97 - 004 , Aerospace CTG and MACT Autom obile and Light- duty Trucks, Surface Coating of EPA- 450/2 - 77 - 008 , Control of Volatile Organic Emissions from Existing Stationary

Sources – Volum e II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light- Duty Trucks EPA- 453/R- 08 - 006, Control Techniques Guidelines for Automobile and Light- Duty

Truck Assembly

Coatings 11 See pg C - 220 http://www.valleyair.org/Air_Q uality _Plans/docs/PM25 - 2015/C.pdf 12 The document listed by ICAPCD as a CTG for Automotive Refinishing , “Reduction of Volatile Organic Compound Emissions from Automobile Refinishing, EPA-450/3 - 88 - 009 1988/10” is in fact an Alternative Control Techniques (A CT) Document.- 8 -

CTG Source Category CTG Reference Document Cans and Coils, Surface Coating of EPA- 450/2 - 77 - 008 , Control of Volatile Organic Emissions from Existing Stationary

Sources – Volum e II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light- Duty Trucks Fiberglass Boat Manufacturing EPA- 453/R- 08 - 004, Control Techniques Guidelines for Fiberglass Boat M anufacturing Flat W ood Paneling, Surface Coating of EPA- 450/2 - 78 - 032, Control of Volatile Organic Emissions from Existing Stationary

Sources – Volum e VII: Factory Surface Coating of Flat W ood Paneling EPA- 453/R- 06 - 004, Control Techniques Guidelines for Flat W ood Paneling Coatings Flexible Packing Printing EPA- 453/R- 06 - 003, Control Techniques Guidelines for Flexible Package Printing Graphic Arts – Rotogravure and Flexography EPA- 450/2 - 78 - 033, Control of Volatile Organic Emissions from Existing Stationary Sources, Volume III: Graphic Arts – Rotogravure and Flexography Large Appliances, Surface Coating of EPA- 450/2 - 77 - 034, Control of Volatile Organic Emissions from Existing Stationary

Sources – Volum e V: Surface Coating of Large Appliances EPA- 453/R- 07 - 004, Control Techniques Guidelines for Large Appliance Coatings Large Petroleum Dry

Cleaners EPA- 450/3 - 82 - 009, Control of Volatile Organic Compound Emissions

from Large Petroleum Dry Cleaners Offset Lithographic Printing and Letterpress Printing EPA- 453/ R- 06 - 002, Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing Magnet W ire, Surface Coating for Insulation of EPA- 450/2 - 77 - 033, Control of Volatile Organic Emissions from Existing Stationary

Sources – Volum e IV: Surface Coating of Insulation of Magnet W ire Metal Furniture Coatings EPA- 450/2 - 77 - 032, Control of Volatile Organic Emissions from Existing Stationary

Sources – Volum e III: Surface Coating of Metal Furniture EPA- 453/R- 07 - 005, Control Techniques Guidelines for M etal Furniture Coatings Miscellaneous Metal and Plastic Parts Coatings EPA- 453/R- 08 - 003, Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings Miscellaneous Metal Parts and Products , Surface Coating of EPA- 450/2 - 78 - 015, Control of Volatile Organic Emissions from Existing Stationary

Sources – Volum e IV: Surface Coating of Miscellaneous Metal Parts and Products Miscellaneous Industrial Adhesives EPA- 453/R- 08 - 005, Control Techniques Guidelines for Miscellaneous Industrial Adhesives Natural Gas/Gasoline Processing Plants Equipment Leaks EPA- 450/2 - 83 - 007 , Control of Volatile Organic Compound Equipment Leaks from Natural Gas/Gasoline Processing Plants Paper, Film and Foil Coatings EPA- 453R- 07 - 003, Control Techniques Guidelines for Paper, Film and Foil Coatings Petroleum Refineries EPA- 450/2 - 77 - 025, Control of Refinery Vacuum Producing Systems, Wa stewater Separators, and Process Unit Turnarounds EPA- 450/2 - 78 - 036, Control of Volatile Organic Compound Leaks from Petroleum Refinery

Eq uipm ent Pharmaceutical Products EPA- 450/2 - 78 - 029, Control of Volatile Organic Emissions from Manufacture of Synthesized Pharm aceutical Products Pneum atic Rubber Tires, Manufacture of EPA- 450/2 - 78 - 030, Control of Volatile Organic Emissions from Manufactu re of Pneumatic Rubber Tires- 9 -

CTG Source Category CTG Reference Document Polyester Resin EPA- 450/3 - 83 - 008, Control of Volatile Organic Compound Emissions from Manufacture of High - Density Polyethylene, Polypropylene, and Polystyrene Resins EPA- 450/3 - 83 - 006, Control of Volatile Organic Compound Leak s from Synthetic Organic Chemical Polyme r and Resin Manufacturing Equipm ent Shipbuilding/Repair 61 FR- 44050 8/27/96, Control Techniques Guidelines for Shipbuilding and Ship Repair Operations (Surface Coating) Synthetic Organic Chemical EPA- 450/3 - 84 - 015 , Control of Volatile Organic Compound Emissions from Air Oxidation Processes in Sy nthetic Organic Chemical Manufacturing Industry EPA- 450/4 - 91 - 031, Control of Volatile Organic Compound Emissions from Reactor Processes and Distillation Operations in Sy nth etic Organic Chemical Manufacturing Industry Wo od Furniture EPA- 453/R- 96 - 007, W ood Furniture **3. Major non**  **- CTG Sources of VOC or NOx**  CAA § 182(b)(2) and (f) require RACT for stationary source categories covered by CTG documents and all major stationary so urces of VOCs or NOx. ICAPC D was initially classified as a marginal nonattainment for the 1997 ozone NAAQS , but was subsequently reclassified as a moderate nonattainment area . 13 A major source in a moderate ozone nonattainment area is defined as a stationar

y source that emits, or has the potential to emit, at least 10 0 tons p er year of VOCs or NOx. 14 ICAPCD Action : ICAPCD’s 2009 RACT SIP, Table 3, lists nine facilities that were major sources of VOC or NOx at that time, along with the respective RACT rule s , where applicable, for each facility. Table 5 in the 2009 RACT SIP presents a comparison of each ICAPCD RACT rule for these facilities with the corresponding RACT rule in other California air districts . ICAPCD’s 2009 RACT SIP Table 3 referenced the fol lowing NOx rules for the major sources: Rule 400: Fuel Burning Equipment Rule 400.1: Stationary Gas Turbines Rule 400.2: Boilers, Process Heaters and Steam Generators Rule 403: General Limitations on the Discharge of Air Contaminants (NOx/VOC)
13 See 69 FR 23858 (April 30, 2004), and 77 FR 28424 (May 14, 2012) (codified at 40 CF R § 81.305 ( California— 1997 8 - Hour Ozone NAAQS) ). 14 See CAA §§ 182(b)(2) and (f) and 302(j).- 10 -

ICAPCD ’s 2009 RACT SIP Table 3 referenced the following VOC rules for the major sources: Rule 414: Storage of Reactive Organic Compound Liquids Rule 415: Transfer and Storage of Gasoline EPA Evaluation : We found that CalEnergy, one of the nine facilit ies listed in the 2009 RACT SIP as a major source of VOC, is currently permitted with a total annual potential to emit of 1.8 tons per year of benzene (VOC). 15 ORMAT Nevada, Inc. was also listed as a major source of VOC in the 2009 RACT SIP, but a re generative thermal oxidizer was added to the facility, and the potential to emit is now 19.6 tons per year of VOC . 16 Each facility’ s potential to emit is now well below the major source threshold , so neither is a major source . Wealso reviewed CARB’s emissions inventory for Imperial County, and did not find any additional relevant major sources that are not included in Table 3 of the RACT SIP. VOC Rules: The two remaining major sources of VOC identified i n the 2009 RACT SIP are GEM Resources (ORMESA, LLC) (Permit Number 2002 ) and SFPP, L.P. (Permit Number 2046 ). SFPP is subject to two VOC rules that EPA previously approved into the California SIP: Rule 414 17 and Rule 415 18

. Our previous approval of Rule 414 found that it fulfill ed RACT requirements. W e are not aware of information suggesting that additional controls are needed to fulfill RACT since our approval of this rule . As discussed earlier, o ur previous approval of Rule 415 concluded that it satisfied RACT. GEM Resources is not currently subject to any V OC prohibitory rules. GEM Resources is subject to permit conditions which limits its annual potential to emit to 28.29 tons/year for VOCs and 9.94 tons/year for benzene. 19 T he emissions are below the major source threshold, so the facility is not a major source. NOx Rules: ICAPCD identified five major sources of NOx: Imperial Irrigation District (Rockwood) (Permit Number 1365 ), Holly Sugar (Permit Number 1697 ), Imperial Valley Resource Recovery (Permit Number 1929 ), Imperial Irrigation District (ECGS) (P ermit Number 2152 ) and USG (Permit Number 2834 ). The District also identified the NOx rules that apply to 15 Imperial County

Air Pollution Control District, Authority to Construct and Permit to Operate Review, Permit #2000H - 9 (March 4, 2015) Table 8. 16 Imperial County Air Pollution Control District, Sy nthetic Minor Permit Review, Permit 1641B - 3 (September 23, 2 010) page 7. 17 Approved in 73 FR 70883 (November 24, 2008) . 18 Approved in 70 FR 8520 (February 22, 2005) . 19 Imperial County

Air Pollution Control District, Condi tions for Authority to Construct and Permit to Operate #2002 I -4 (April 1 , 2014) .- 11 -

one or more of these sources and that EPA has approved into the California SIP : Rule 400 20 Fuel Burning Equipment – Oxides of Nitrogen, R ule 400.1 21 Sta tionary Gas Turbines – Reasonably Available Control Technology , and Rule 400.2 22 Boilers , Process Heaters and Steam Generators. Table 3 of the 2009 RACT SIP indicates that four of the five major NOx sources (Imperial Irrigation District (Rockwood), Holly Su gar, Imperial Valley Resource Recovery, and Imperial Irrigation District (ECGS) are subject to Rules 400, 400.1 and 400.2. Our previous approvals of Rule s 400.1 and 400.2 found that they fulfilled RACT requirements. Weare not aware of information suggesti ng that additional controls are needed to fulfill RACT since our approval of these rules. Our approval of Rule 400 did not include an evaluation of ozone RACT requirements . However, since each of the NOx sources subject to Rule 400 is also subject to at le ast one additional NOx rule that EPA has found to fulfill RACT requirements , it is not necessary to determine w hether Rule 400 fulfill s RACT requirements at this time. Subsequent to the 2009 RACT SIP submittal, ICAPCD adopted Rule 400.4 23 , Emissions of Oxi des of Nitrogen from W allboard Kilns to ensure USG, the last major NOx source listed in Table 3 of the 2009 RACT SIP, is subject to RACT . EPA approved it into the California SIP ( 79 FR 60070, October 6, 2014). As part of th is approval, we found that R ule 400.4 fulfil led RACT requirements. W e are not aware of information suggesting that additional controls are needed to fulfill RACT since our approval of th is rule. **RECOMMENDA**

**TIONS** The following rules have recommendation s that are provided for future consideration the next time the rules are open for amendment. None of these recommendations listed in the referenced EPA technical support documents justify less than full approval of ICAPC D’s 2009 RACT SIP demonstration at this time. 1. Rule 400.1 Station ary Gas Turbine(s) – Reasonably Available Control Technology (RACT) – Refer to EPA’s technical support document for ICAPCD Rule 400.1, December 2011, page 4 for the suggested rule improvements for the next time the rule is revised. 2. Rule 400.2 Boilers, Process Heaters and Steam Generators – Refer to EPA’s technical support document for ICAPCD Rule 400.2, April 20 12 , page 5 for the suggested rule improvements for the next time the rule is revised. 3. Rule 400.4 Emissions of Oxides of Nitrogen from W allb oard Kilns – Refer to EPA’s technical support document for ICAPCD Rule 400.4, June 2014, page 4 for the added rule recommendations for the next time the rule is revised. 20 Approved in 68 FR 14161 (March 24, 2003) 21 Approved in 77 FR 2469 (November 18, 2012) 22 Approved in 78 FR 896 (January 7, 2013) 23 Approved in 79 FR 60070 (October 6, 2014)- 12 -

4 . Rule 413 Organic Solvent Cleaning and Rule 417 Organic Solvents – Adopt and submi t for SIP approval a negative declaration for the 1977 Solvent Metal Cleaning and 2006 Industrial Solvent Cleaning CTGs. Consider adopting a VOC content limit of 25 g/l for cleaning solvents similar to other air districts. 5 . Rule 415 Transfer and Storag e of Gasoline – If additional VOC reductions are needed, consider lowering the bulk gasoline terminal emissions limit to 0.0 4 pounds/1000 gallons loaded . See Bay Area AQMD Rule 8 - 33 section 8 - 33 - 301.2 (effective 1/10/2011) . 6 . Rule 425 Aerospace Coating O perations – Refer to EPA’s technical support document for ICAPCD Rule 425, January 2011, page 4 for the added rule recommendations for the next time the rule is revised. 7 . Rule 426 Cutback Asphalt and Emulsified Paving Materials – If additional VOC/NOx/ PM 2.5 reductions are needed, consider use of warm mix asphalt as an option to hot mix asphalt. See pg C - 220 http://www.valleyair.org/Air_Quality_Plans/docs/PM25 - 2015/C.pdf . 8 . Rule 427 Automotive Refinishing Operations – Refer to EPA’s technical support document for ICAPCD Rule 427, February 2011, page 3 for the added rule recommendations for the next time the rule is revised. 9 . If additional VOC reductions are needed, consi der adopting controls for composting operations similar to South Coast Rule 1133 (series) or San Joaquin Rule 4566 . **SUMMA RY**  We concur with ICAPC D’s 200 9 RACT SIP certification , including rule s that were amended or adopted after 200 9 as they fulfill the requirements for RACT for the 1997 8 - hour ozone standard , and recommend the 2009 RACT SIP be approved. **REFERENCES** 1. Imperial County Air Pollution Control District, Final 20 0 9 Reasonably Available Control Technology State Implementation Plan Dated Ju ly 1 3 , 20 10 , Adopted Ju ly 13 , 20 10 ; s ubmitted December 21, 20 10 . 2 . “ Final Rule to Implement the 8 - Hour Ozone National Ambient Air Quality Standard – Phase 2” 70 FR 71612; November 29, 2005). http://www.gpo.gov/fdsys/pkg/FR- 2005 - 11 - 29/pdf/05 - 22698.pdf 3. ICAPCD - Supplemental to 2009 RACT SIP - Analysis of Control Technologies Guidance (CTG) Documents, July 31, 2015.- 13 -

4. “Air Quality Designations and Classifications for the 8 - Hour Ozone National Ambient Air Qua lity Standards; Early Action Compact Areas W ith Deferred Effective Dates” – Final Rule ( 69 FR 23858 ; April 30, 2004) . 5 . “ Fin al Rule to Implement the 1 997 8 - Hour Ozone National Ambient Air Quality Standard: Classification of Areas That W ere Initially Classified Under Subpart 1; Revision of the Anti Backsliding Provisions to Address 1 - Hour Contingency Measure Requirements; Deletion of Obsolete 1 - Hour Ozo ne Standard Provision ” – Final Rule ( 77 FR 28424 ; May 14, 2012) 6 . “ State Implementation Plans, General Preamble for the Implementation of Title I of the Clean Air Act Amendme nts of 1990 ” (57 FR 13498; April 16, 1992). 7 . Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations: Clarification to Appendix D of November 24, 1987 FEDERAL REGISTER, May 25, 1988 , Revised January 11, 1990 ("The Blue Book") . http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf 8 . EPA Region IX’s Guidance Document for Correcting Common VOC and Other Rule Deficiencies , August 21, 2001 (the "Littl e Bluebook"). http://epa.gov/region9/air/sips/littlebluebook2001.pdf 9 . “ State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for the Implementation of Tit le I of the Clean Air Act Amendments of 1990 ” (57 FR 55620, November 25, 1992) (“the NOx Supplement” ). 10 . “Model Volatile Organic Compound Rules for Reasonably Available Control Technology”, EPA (June 1992). http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_modelrules.pdf 1 1 . EPA-453/R- 95 - 010 , “Beyond VOC RACT Requirements”, EPA (April 1995). http://www.epa.gov/ttncatc1/dir1/byndract.pdf 1 2 . RACT Qs & As – Reasonably Available Control Technology (RACT): Questions and Answers, May 18, 2006 Memorandum from W illiam T. Harnett, Director, Air Quality Policy Division, to Regional Air Division Directors. http://www.epa.gov/ttn/caaa/t1/memoranda/ractqanda.pdf 1 3 . RACT SIPs, Letter dated March 9, 2006 from EPA Region IX (Andrew Steckel) to CARB (Kurt Karperos) describing Region IX’s understanding of what constituted a minimally acceptable RACT SIP. 1 4 . EPA's CTGs and ACTs http://www.epa.gov/groundlevelozone/SIPToolkit/ctgs.html . 1 5 . CARB’s emissions inventory database http://www.arb.ca.gov/app/emsinv/facinfo/facinfo.php . 1 6 . CARB and EPA Region IX databases of ICAPC D rules CARB: http://www.arb.ca.go v/drdb/imp/cur.htm .- 14 -

EPA: http://epa.gov/region09/air/sips/index.html . ICAPCD: http://www.co.i mperial.ca.us/AirPollution/W eb%20Pages/RULES%20AND%20REGULATIONS .htm 1 7 . ICAPCD Synthetic Minor Permit Review, 1641B - 3 ORMAT Nevada Inc., September 23, 2010. 1 8 . ICAPCD Authority to Constrct and Permit To Operate Review, 2002I - 3 Ormesa, LLC., April 1, 2014. 1 9 . ICAPCD Authority to Construct and Permit to Operate Review Review, #2000H - 9 CalEnergy Operating Corporation, March 4, 2015 . 20 . South Coast Air Quality Management District, “Technical Assessment for Rule 1108 – Cutback Asphalt”, June 2008.