SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX C: RACT Analysis June 16, 2011 

Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4605 

 

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APPENDIX C 

Reasonably Available Control Technology 

(RACT) Analysis 

June 16, 2011 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX C: RACT Analysis June 16, 2011 

Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4605 

 

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SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX C: RACT Analysis June 16, 2011 

Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4605 

 

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I. REQUIREMENTS OF ANALYSIS 

The Clean Air Act (CAA) Section 182(b)(2) states that ozone attainment plans shall 

assure that RACT for volatile organic compounds (VOC) is applied at certain sources. 

A RACT analysis requires an examination of a rule against Federal rules, regulations, 

and technology guidelines as well as comparing it against rules from other Districts in 

California. District Rule 4605 was compared to federal and state regulations and 

guidance. The following is a discussion of that analysis. 

II. ANALYSIS 

EPA – Control Technique Guidelines (CTG) 

1. The CTG EPA-453/R-97-004 1997/12 applies to Surface Coating Operations at 

Aerospace Manufacturing and Rework Operations located in marginal, moderate, 

serious or severe ozone nonattainment areas that has the potential to emit greater than 

or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of VOC for 

extreme ozone nonattainment areas. District Rule 4605 is more stringent than the CTG 

limits for 34 categories. The proposed amendments to Rule 4605 will make it as 

stringent as the CTG in the 19 remaining categories. As such, District staff concludes 

that District Rule 4605 is more stringent than the CTG. 

2. The CTG EPA-450/2-77-034 1977/12 applies to Surface Coating of Large 

Appliances operations located in marginal, moderate, serious or severe ozone 

nonattainment areas that have the potential to emit greater than or equal to 25 tons/year 

of VOC, and equal to greater than 10 tons/year of VOC for extreme ozone 

nonattainment areas. 

Since this CTG applies to large appliance coating; therefore, it will not be compared to 

SJVAPCD Rule 4605 which covers aerospace coating. 

3. The CTG EPA-450/2-77-022 1977/11 applies to VOC Emissions from Solvent 

Metal Cleaning operations located in marginal, moderate, serious or severe ozone 

nonattainment areas that have the potential to emit greater than or equal to 25 tons/year 

of VOC, and equal to greater than 10 tons/year of VOC for extreme ozone 

nonattainment areas. 

This CTG applies to the use of the following degreasing equipment: cold cleaners, open 

top vapor degreasers, and conveyorized degreasers. Identified in the CTG are design 

and work practice standards for cold cleaners, open top vapor degreasers, and 

conveyorized degreasers, for example: cover the solvent tank, have a facility for waste 

solvent and draining cleaned parts, permanent labels on operating parts, close 

degreaser when not in use, drain parts until dripping ceases, no excessive splashing if 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX C: RACT Analysis June 16, 2011 

Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4605 

 

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solvent is sprayed. The CTG also identifies add-on controls such as refrigeration 

chillers and carbon control. 

SJVACPD Rule 4605 identifies solvent VOC content limits or a control system with 

efficiencies of at least 90% capture and 95% control, and that would not allow more 

emissions than if compliant materials were utilized. The general solvent limit is 200 g/L; 

the coating stripper solvent limit is currently 300 g/L. 

Since the CTG does not identify control requirements any more stringent than 

SJVACPD Rule 4605, District staff considers Rule 4605 at least as stringent as the 

CTG. 

EPA – Alternative Control Technology (ACT) 

There is no ACT for this source category. 

Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS for this source category. 

National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

NESHAPs and MACTs are requirements contained in 40 Code of Federal Regulations 

(CFR) Part 61 and 40 CFR Part 63. Since EPA has delegated the authority to 

implement NESHAP requirements to the District, NESHAPs and MACTs promulgated 

by EPA are usually incorporated by reference into District Rule 4002 (National Emission 

Standards for Hazardous Air Pollutants). It is important to mention that the District 

implements NESHAPs and MACTs by incorporating the emission standards as 

conditions of the Permits to Operate issued to affected sources. 

1. 40 CFR 63 Subpart GG (National Emission Standards for HAPs: Aerospace 

Manufacturing and Rework Facilities) 

The requirements in this subpart are not directly comparable to the District Rule 4605 

VOC limits. The NESHAP HAP emission limits which are expressed in terms of percent 

HAP, HAP emission concentration, and mass (kg) of HAP per mass (kg) of solids are 

not directly comparable to the coatings VOC limit which is expressed in terms of grams 

(or lb) of VOC per liter (or gallons) of coatings, less water and exempt compounds, as 

applied. In addition, some HAPs may be exempt VOCs, and some VOCs may be 

HAPs; therefore, there is no direct correlation between the NESHAP limit versus District 

Rule 4605 VOC limits. 

How does District Rule 4605 compare to rules in other air districts? 

District staff compared District Rule 4605 with the rules of other California ozone 

nonattainment air districts’ rules (listed below) for aerospace operations in the 2009 

RACT SIP, Chapter 4. The other major California nonattainment areas with similar 

rules are as follows: 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX C: RACT Analysis June 16, 2011 

Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4605 

 

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A. South Coast Air Quality Management District (SCAQMD) Rule 1124 - Aerospace 

Assembly and Component Manufacturing Operations (Amended September 21, 

2001) 

B. Bay Area Air Quality Management District (BAAQMD) Regulation 8 Rule 29 - 

Adhesive and Sealant Products (Amended December 20, 1995) 

C. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 456 - 

Aerospace Assembly and Component Coating Operations (Amended October 

23, 2008) 

D. Ventura County Air Pollution Control District (VCPCD) Rule 74.13 - Aerospace 

Assembly and Component Manufacturing Operations (Amended November 11, 

2003) 

No rule amendments have occurred since the 2009 RACT Analysis was conducted. The 

2009 analysis concluded that the District rule meets RACT compared to other districts’ 

aerospace coating rules. The EPA TSD also concluded that Rule 4605 imposes very 

similar requirements to those in other large California nonattainment areas. Even 

though Rule 4605 varies in stringency when compared to other Districts’ adhesive 

requirements, District staff concludes that Rule 4605 is as stringent as or more stringent 

than the other District Rules. 

III. RESULTS OF ANALYSIS 

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4605 

satisfies RACT for aerospace assembly and component coating operations. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX C: RACT Analysis June 16, 2011 

Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4605 

 

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