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 1990E. Gettysburg Ave. Fresno, CA 93726

Re: 8-hour Ozone Reasonably Available Control Technology 

### - State Implementation Plan (RACT SIP) Analysis, draft staffreport dated December 17,2007

Dear Mr. Heinen:

Thank you for the opportunity to comment on SanJoaquin Valley Air Pollution Control District's (SJVUAPCD)draft staffreport on Reasonably Available Control Technology (RACT) for the 8-hour ozone standard, and for the additional time toreview it. The District has amended a number of rules sincethe previous August 17,2006RACT SIP analysis. The current RACT analysis adjusts the major source threshold down to 10tonsper 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 onthe draft report. Because RACT SIPS have limited national policy or precedent, we are not yet certain which ofthese commentsmight reflect approvability issues.

1. The District identified 419 facilities which emit orhave the potential to emit between 10

### - 25 tpy ofNOx orVOC. 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 optionsfor 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

- $8,600per 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 ourNovember 20,2007proposed 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 SanJoaquin is smaller than that of SCAQMD and BAAQMD, even taking an initial step such as requiring the monitoring and reporting offlaring 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 refineriesto develop and submit a flare minimization plan as has been done in the SCAQMD and BAAQMD. http://www.marama.org/rep0rts/O21907 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 inthe CAPCOA 2003 Potential All Feasible Measures meaning that the NOx and VOC emission limits have undergone recent BARCT analysis. Please include a copy ofthe appropriate CAPCOApage(s) inthe RACT SIP analysis.

2. Appendix E provides an analysis ofthe 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. Ifthe categories are covered under the CTG, the District should include a copy oftheir 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 ofthe country, a State or local air district would have to showunusual circumstances tojustify why it is not cost or technologically effective for that area.

### Offset Lithographic and Letterpress PrintingFlexible Package PrintingEPA understands SanJoaquin 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 ofwood 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 doesnot anticipate these sources in the future. If you have any questions regarding these comments, please feel free to contact me or Stanley Tong at (415)947-4122.

Sincerely,

~ndrew Steckel, Chief, Rulemaking Office

cc: David Welk, (SJVUAPCD) Sandra Lowe-Leseth, (SJVUAPCD) Ravi Ramalingam (C

### ARB)