UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

The EPA’s Notice of Proposed Rulemaking

for the

California State Implementation Plan

The EPA’s Evaluation of

South Coast Air Quality Management District, 

2016 AQMP Reasonably Available Control Technology (RACT) Demonstration – Adopted 

June 6, 2014

Prepared by: James Shears and Stanley Tong

Reviewed by: Andrew Steckel

June 2016
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RULE IDENTIFICATION -

Agency: South Coast Air Quality Management District (SCAQMD)

SIP Approved Version: There is no previous SIP approved SCAQMD RACT SIP for the 

2008 8-hour ozone standard, but we previously approved the 

following document for the 1997 8-hour ozone standard:

SCAQMD Reasonably Available Control Technology Analysis 

(2006 RACT SIP)

Adopted - July 14, 2006

Submitted - January 31, 2007

Approved - December 18, 2008 (73 FR 76947)

Subject of this TSD: SCAQMD 2016 AQMP Reasonably Available Control Technology 

(RACT) Demonstration 

Adopted – June 6, 2014

Submitted – July 18, 2014

BACKGROUND -

Volatile organic compounds (VOC) 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. The South Coast Air Quality 

Management District (SCAQMD or the District) falls under this requirement as the South Coast 

Air Basin (Basin) is classified as an extreme ozone nonattainment area and the Coachella 

Valley located in Riverside County is classified as a severe-15 nonattainment area under the 

2008 8-hour national ambient air quality standard (NAAQS) for ozone (40 CFR 81.305).

Under CAA § 182(b)(2) and (f), SCAQMD must, at a minimum, adopt RACT level controls for 

sources covered by a Control Techniques Guidelines (CTG) document and for any major 

stationary source of VOC or NOx. The EPA defines RACT as the “lowest emissions limitation 

that a particular source is capable of meeting by the application of control technology that is 

reasonably available considering technological and economic feasibility.” 44 FR 53761 

(September 17, 1979). 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.

SUBMITTAL SUMMARY –

The District adopted its RACT SIP certification for the 2008 ozone standard on June 6, 2014 

and the California Air Resources Board (CARB) submitted it to EPA on July 18, 2014. 

SCAQMD performed its RACT SIP analysis based on an ozone non-attainment classification 
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of “extreme”. This classification defines a major stationary source as those facilities that emit 

or have the potential to emit at least 10 tons per year (tpy) of VOC or NOx.

SCAQMD’s submittal included the following documents:

a. “SCAQMD 2016 AQMP Reasonably Available Control Technology (RACT) 

Demonstration”, dated May 22, 2014 [hereinafter “2016 AQMP RACT SIP”].

b. Resolution No. 14-14: “A Resolution of the South Coast Air Quality Management District 

(SCAQMD) Board certifying that the SCAQMD’s current air pollution rules and 

regulations fulfill the 8-hour ozone Reasonably Available Control Technology (RACT) 

requirements and adopting the RACT SIP revision.”

SCAQMD’s analysis included the following areas. Further discussion is provided below.

• Review of previous RACT demonstrations from its 2007 and 2012 Air Quality 

Management Plans (AQMP)

• Further evaluation of selected SCAQMD Rules and Regulations

• New major sources identified since its 2006 RACT SIP certification

• Negative declarations

EPA EVALUATION –

The EPA evaluated the following elements of SCAQMD’s 2016 AQMP RACT Analysis:

• The bases for concluding local rules implement RACT

• Efforts to identify new major sources within the District

• Negative declarations where there are no facilities subject to a CTG

The following documents were also used to support our review:

• “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); 57 FR 18070 (April 

28, 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 

enforceability, including “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and 

Deviations,” EPA, May 25, 1988 (The Blue Book), and “Guidance Document for 

Correcting Common VOC & Other Rule Deficiencies,” EPA Region 9, August 21, 2001 

(the Little Bluebook).

• “State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for 

the Implementation of Title I of the Clean Air Act Amendments of 1990” (57 FR 55620, 

November 25, 1992) (“the NOx Supplement”).

• Memorandum from William T. Harnett to Regional Air Division Directors, (May 18, 2006), 

“RACT Qs & As – Reasonably 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.
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• Letter dated April 4, 2006 from EPA Region IX (Andrew Steckel) to CARB (Kurt 

Karperos) listing the EPA’s current CTGs, ACTs, and other documents which may help 

to establish RACT.

• “Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State 

Implementation Plan Requirements’’ (80 FR 12264; March 6, 2015).

• EPA’s CTGs and ACTs: https://www.epa.gov/ozone-pollution/control-techniquesguidelines-and-alternative-control-techniques-documents-reducing

• CARB’s emissions inventory database 

http://www.arb.ca.gov/app/emsinv/facinfo/facinfo.php

• SCAQMD, CARB, and EPA Region IX databases of SCAQMD rules

SCAQMD: http://www.aqmd.gov/home/regulations/rules/scaqmd-rule-book

CARB: http://www.arb.ca.gov/rldb/rldb.htm

EPA: http://www.epa.gov/approved-sips/approved-sips-region-9

The following summarizes SCAQMD actions to address RACT requirements and the EPA’s 

evaluation of those actions.

1. The bases for concluding local rules implement RACT 

RACT is required for source categories covered by an EPA Control Techniques Guidelines 

document (“CTG sources”) and all sources that are not covered by a CTG document but are 

“major sources” (i.e., for SCAQMD, “non-CTG sources” that emit or have the potential to 

emit at least 10 tons per year of VOCs or NOx.)

SCAQMD action (2006 RACT SIP and 2007 AQMP):

SCAQMD’s 2016 AQMP RACT SIP (submitted July 18, 2014) summarizes its past RACT 

certifications and states that its previous RACT analyses are incorporated as components of 

its 2007 and 2012 Air Quality Management Plan (AQMP) Reasonably Available Control 

Measures (RACM)/RACT Demonstrations.1 The District’s 2007 and 2012 AQMP 

RACM/RACT analysis supplements and updates its “2006 RACT SIP” certification.

SCAQMD’s 2006 RACT SIP certified that all sources subject to a CTG and all major nonCTG VOC and NOx sources implemented RACT for the 1997 8-hour ozone standard. 

Appendices 2 – 4 contain the District’s analysis that its rules implement RACT and 

 

1 2016 AQMP RACT SIP, Attachment B, Regulatory History, page 1: http://www.aqmd.gov/docs/defaultsource/Agendas/Governing-Board/2014/2014-jun6-031.pdf?sfvrsn=2; 

2007 AQMP Appendix VI: Reasonably Available Control Measures (RACM) (June 2007) 

http://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality-management-plans/2007-air-qualitymanagement-plan/2007-aqmp-appendix-vi.pdf?sfvrsn=2; 

2012 AQMP Appendix VI: Reasonably Available Control Measures (RACM) Demonstration (February 2013) 

http://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality-management-plans/2012-air-qualitymanagement-plan/final-2012-aqmp-(february-2013)/appendix-vi-final-2012.pdf 
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Appendix 5, Table 5-1 lists the District’s major sources with Title V permits. EPA approved 

SCAQMD’s 2006 RACT SIP certification in December 2008.2

The District’s 2007 AQMP is an integrated plan to address both the 1997 PM2.5 and the 

1997 8-hour ozone NAAQS. Table 3 of the SCAQMD 2007 AQMP contains a brief analysis 

of 82 source-specific rules and a summary of requirements from other air districts if 

SCAQMD concluded that the requirements in other jurisdictions were more stringent. The 

AQMP reviews four new CTGs issued by EPA in September 2006 and concludes that its 

rules implement the recommendations in the new CTGs with the exception of the fountain 

solution VOC concentration limits for sheet-fed presses and heat-set web presses in Rule 

1130 – Graphics Arts. SCAQMD amended Rule 1130 on May 2, 2014 to implement the 

recommendations in the CTG. The 2007 AQMP states that in general, SCAQMD’s current 

rules and regulations are equivalent or more stringent than rules in other air districts.3

EPA Evaluation

The District’s 2007 AQMP was submitted on November 28, 2007 and approved into the SIP 

77 FR 12674 (March 1, 2012). EPA approved the May 2, 2014 amendments to Rule 1130 in 

80 FR 40915 (July 14, 2015) as implementing RACT. We are not aware of any information 

that would alter our prior determination that the SCAQMD 2006 RACT SIP updated and 

supplemented by the District’s 2007 AQMP demonstrates the District’s rules implement 

RACT.

SCAQMD action (2012 AQMP):

The District’s 2012 AQMP focuses primarily on PM2.5 and its precursors including NOx, 

VOC and SOx and is designed to address the federal 2006 24-hour PM2.5 standard.

Table VI-4 of the 2012 AQMP contains a brief analysis of nine District rules that are subject 

to CTGs that EPA promulgated between 2006 – 2008. The 2012 AQMP concludes that the 

following rules are either equivalent to, or are more stringent than the corresponding CTGs, 

and that no further action is needed: Rule 1104, Wood Flat Stock Coating Operations; Rule 

1171, Solvent Cleaning Operations; Rule 1107, Coating of Metal Parts and Products; Rule 

1128, Paper, Fabric, and Film Coatings; Rule 1145, Plastic, Rubber, Glass Coatings; Rule 

1162, Polyester Resin Operations. Also listed in Table VI-4 is Rule 1130, Graphic Arts,

which states a rule update will be pursued. As mentioned above, EPA approved the May 2, 

2014 amendments to Rule 1130 to implement the recommendations in the CTG.

The AQMP states Rule 1115, Motor Vehicle Assembly Line Coating Operations, has less 

stringent limits than the CTG for various primers, and it exempts certain coatings that are 

not exempted by the CTG. It also states that Rule 1115 has a small inventory (~ 0.01 tpd)

and concludes that no action is needed. The AQMP also indicates that a rule update may 

be pursued for Rule 1168, Adhesives and Sealants, since it has less stringent limits than 

the CTG for certain adhesives.

 

2 Approval of SCAQMD 2006 RACT SIP: 73 FR 76947 (December 18, 2008).

3 2007 AQMP page VI-5, http://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality-managementplans/2007-air-quality-management-plan/2007-aqmp-appendix-vi.pdf?sfvrsn=2.
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EPA Evaluation

The District’s 2012 AQMP was submitted on February 13, 2013 and approved into the SIP 

in 79 FR 52526 (September 3, 2014). We agree with the District that Rules 1104, 1171, 

1107, 1128, 1145, and 1162 implement RACT. 

For Rule 1115, we determined there are potentially four coating operations for new heavyduty vehicles and that these facilities are subject to the 2008 CTG for Miscellaneous Metal 

and Plastic Parts Coatings and not the 2008 CTG for Automobile and Light-Duty Truck 

Assembly Coatings. We also conclude that Rule 1107, Coating of Metal Parts and 

Products, implements the 2008 CTG for Miscellaneous Metal and Plastic Parts Coating.

For Rule 1168, we disagree with the District’s conclusion that it has less stringent limits than 

the CTG for certain adhesives and conclude the rule implements EPA’s 2008 CTG for 

Miscellaneous Industrial Adhesives. We discuss these rules and our evaluation in greater 

detail later in this TSD. We are not aware of any information that would alter our prior 

determination that the SCAQMD 2006 RACT SIP updated and supplemented by the 

District’s 2007 and 2012 AQMPs demonstrates the District’s rules implement RACT.

2. Efforts to identify new major sources within the District

SCAQMD action:

SCAQMD’s 2016 AQMP RACT SIP does not contain a listing of major sources similar to 

that contained in Appendix 5 of its 2006 RACT SIP. Subsequent to the 2016 AQMP RACT 

SIP submittal, the EPA requested and received SCAQMD’s list of new major VOC/NOx

sources that have received Title V permits since the 2006 RACT SIP.4 SCAQMD indicated 

there are 26 new Title V facilities, one facility is major for CO, one facility is major for PM10

and three are covered under the District’s Regional Clean Air Incentives Market program 

(RECLAIM). The remaining 21 major sources are listed below.

 

4 Email dated January 29, 2016, from Kalam Cheung (SCAQMD) to Stanley Tong (USEPA), RE: “New Title V 

Facilities since 2006”.
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EPA evaluation:

The EPA reviewed SCAQMD’s list of equipment emitting greater than 5 tpy at the above 

facilities and agree the emission sources are subject to rules that implement RACT. In 

addition, SCAQMD indicates that all new major sources since 2006 are required to have 

Best Available Control Technology (BACT), which exceeds RACT, as a condition of permit.5

The District’s efforts to identify all new major sources appears to be thorough.

3. Submit negative declarations where there are no facilities subject to a CTG.

SCAQMD action:

In lieu of adopting RACT rules, Districts can adopt negative declarations for CTG source 

categories if there are no sources in the District covered by the CTG. 

 

5 Id.

SCAQMD New Major Sources 

Title V Permits Since 2006

Permit Permitted Facility

3513

3704

10966

11245

14871

51475

69081

104806

139808

139938

140373

148236

148568

151798

152707

153992

157152

173108

174406

800428

800436

Irvine Ranch Water District

All American Asphalt, Unit No. 01

Weber Metals Inc.

Hoag Hospital

Sonoco Products Co.

Southern California Edison Co.

Baxter Healthcare Corp., Hyland Division

MM Lopez Energy LLC

Inland Empire Regional Composting Authority

Sunshine Gas Producers LLC

Ameresco Chiquita Energy LLC

Air Liquide Large Industries U.S., LP

Southwest Mill and Lumber

Tesoro Refining and Marketing Co., LLC

Sentinel Energy Center LLC

Canyon Power Plant

Bowerman Power LFG, LLC

Silver Creek Industries, Inc.

Arlon Graphics LLC

Lamps Plus Inc./Pacific Coast Lighting

Tesoro Refining and Marketing Co., LLC
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In its 2016 AQMP RACT SIP, SCAQMD did not claim any negative declarations. At that 

time, the District indicated it had sources that are subject to all of the CTGs.

EPA evaluation:

Subsequent to its 2016 AQMP RACT SIP submittal, EPA had several discussions with 

SCAQMD and concluded there may be two CTG categories where the District has no 

sources applicable to the CTGs. For the 2007 CTG for Paper, Film and Foil coatings, it

appears from a review of the SIC codes applicable to the CTG, CARB’s emissions 

inventory, and discussion with SCAQMD permit engineer, that SCAQMD has no sources 

with coating lines exceeding the CTG threshold of 25 tons/year VOC per coating line (EPA 

453/R-07-003). 

For the Surface Coating Operations at Shipbuilding and Repair Facilities CTG (61 FR44050, August 27, 1996 and EPA-453/R-94-032), SCAQMD indicates it only has one active 

Title V shipyard facility that is subject to Rule 1106, Marine Coating Operations. The one 

coating category in Rule 1106 that exceeds the CTG’s VOC content limit is inorganic zinc

and the District indicates inorganic zinc coating is not used at the facility.6 Consequently, the 

EPA recommends that SCAQMD evaluate and adopt where appropriate, negative 

declarations for these two CTG categories. The EPA concurs that there is no need for other 

negative declarations.

4. Review of specific rules and whether they implement RACT

SCAQMD action:

The 2016 AQMP RACT SIP analysis evaluated more than 30 rules recently developed 

and/or amended by other ozone nonattainment air districts from September 2012 to March 

20147. The air districts in California included the Bay Area Air Quality Management District 

(BAAQMD), San Joaquin Valley Air Pollution Control District (SJVAPCD), Mojave Desert Air 

Quality Management District (MDAQMD), Antelope Valley Air Quality Management District 

(AVAQMD), Sacramento Metropolitan Air Quality Management District (SMAQMD), and 

Ventura County Air Pollution Control District (VCAPCD), and state agencies for ozone 

impacted areas in Texas, Maryland and Delaware.

SCAQMD concluded that its rules exceeded or closely matched those of other agencies, 

with the following rules requiring further evaluation.

1) Rule 462 Organic Liquid Loading

SCAQMD Rule 462 limits organic vapor emissions from facilities that load 20,000 

gallons or more in a day of organic liquids into any tank truck, trailer, or railroad tank car 

to 0.08 pounds/1000 gallons. BAAQMD Rule 8-33 limits bulk gasoline terminal 

 

6 Email dated February 4, 2016, from Kalam Cheung (SCAQMD) to Stanley Tong (USEPA), RE: “2014 Ozone 

RACT SIP- Rule 1106 and Rule 1128”.

7 SCAQMD June 6, 2014 Board meeting, Agenda No. 31, page 2 and the 2016 AQMP RACT SIP, Table 1. 

http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board/2014/2014-jun6-031.pdf?sfvrsn=2
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emissions to a maximum of 0.04 pounds/1000 gallons of organic liquid loaded. The 

2016 AQMP RACT SIP states “Fugitive VOC emissions monitoring protocols between 

the BAAQMD and the SCAQMD gasoline bulk terminal and cargo tank operations need

to be evaluated to determine whether the provisions of SCAQMD Rule 462 apply to 

BAAQMD’s Section 8-Rule 33.”8

EPA Evaluation

Supplemental information provided by SCAQMD for Rule 462 indicates it has 23 major 

source bulk loading terminals. Source tests for 9 bulk terminals showed emissions from

0.0004 to 0.029 lbs/1000 gallons.9 We note that BAAQMD adopted its 0.04 lb/1000 

gallons VOC limit for gasoline bulk terminals in 2009 with an effective date of January 

10, 2011. We were unable to identify any other air district with this lower limit in a SIP 

rule. Accordingly, we agree that Rule 462 currently implements RACT for this category.

We recommend the District evaluate adopting a 0.04 pounds/1000 gallons limit for 

gasoline bulk terminals subject to the outcome of its evaluation of differences in bulk 

terminal and cargo tank monitoring protocols between the BAAQMD and the SCAQMD.

2) Rule 1148.1 Oil and Gas Production Wells, and 

Rule 1173 Control of Volatile Organic Compound Leaks and Releases from 

Components at Petroleum Facilities and Chemical Plants

SCAQMD action:

VCAPCD Rule 71.5 regulates VOC emissions from glycol dehydrators which are used to 

remove water from natural gas. In response to the EPA’s query whether the SCAQMD 

regulated emissions from glycol dehydrators, the District’s 2016 AQMP RACT SIP states 

it needs to determine if existing SCAQMD Rules 1148.1 and 1173 already cover these 

emissions.

SCAQMD provided a November 2014 Supplemental Analysis10 stating VCAPCD Rule 

71.5 requires VOC emissions from glycol dehydrators to be controlled by at least 95%. 

SCAQMD’s November 2014 Supplemental Analysis also states emissions from glycol 

dehydrators are regulated under Rule 1148.1, which also requires a 95% control 

efficiency and is as stringent as the VCAPCD rule. SCAQMD also states that Rule 1173 

covers VOC leaks from petroleum and chemical plants and that both Rules 1148.1 and 

1173 were SIP approved in 2011 and 2010 respectively by the EPA as fulfilling RACT.

EPA Evaluation

 

8 SCAQMD June 6, 2014 Board meeting, Agenda No. 31, page 2.

http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board/2014/2014-jun6-031.pdf?sfvrsn=2

9 Email dated November 25, 2014, from Joe Cassmassi (SCAQMD) to Stanley Tong (USEPA), RE: “SCAQMD 

RACT Analysis Draft 20141119(2) hereinafter “November 2014 Supplemental Analysis”. 

10 Id.
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The EPA has reviewed SCAQMD’s November 2014 Supplemental Analysis and agrees 

that glycol dehydrators are covered by Rule 1148.1 and that Rules 1148.1 and 1173 

implement RACT for this category.

3) Rule 1118 Control of Emissions from Refinery Flares

SCAQMD action:

Rule 1118 applies to all flares used at petroleum refineries, sulfur recovery plants and

hydrogen production plants and Rule 1150.1 applies to landfill flares. However, neither 

rule covers other flares such as those used in wastewater treatment plants or oil and 

gas production facilities. SCAQMD’s 2016 AQMP RACT SIP states potential flare 

emissions from other District sources need to be evaluated to determine the local 

applicability of SJVAPCD Rule 4311 since San Joaquin’s rule regulates flares emitting 

greater than 10 tpy of VOC or NOx regardless of source category.11

EPA Evaluation

Discussions with SCAQMD revealed flares at two source categories (wastewater 

treatment facilities and oil and natural gas production facilities) are not covered under 

Rule 1118 and may need further investigation to determine if they are major non-CTG 

sources requiring RACT.

SCAQMD’s November 2014 Supplemental Analysis of flaring emissions at wastewater 

treatment plants indicated the largest VOC emissions was from the Hyperion Treatment 

Plant at 10,269 lbs/year (5.1 tpy) in 201212 with the potential to emit 40 tpy total for the 

six flares at the facility. SCAQMD indicated that Hyperion’s digester gas goes through 

successive processes that reduce the volume of gas before it reaches a flare. The 

District indicated most of the digester gas first goes to Scattergood Generating Station 

to generate electricity. Next, any residual gas is combusted in a boiler, and finally any 

remaining gas from the boiler would go to the flares. Consequently, SCAQMD staff 

indicated any remaining VOC reaching the flare would be well below 10 tpy, and so the 

flares would not be considered a major source. We agree that VOC emissions are 

reduced when combusted to generate electricity.

CARB’s emissions inventory website shows Tidelands Oil Production Company (Facility 

ID 800325) in Long Beach has NOx emissions of 14.7 tpy in 2012; 12.1 tpy in 2013; 

and 4.3 tpy in 2014 and 2015. The draft Title V permit13 for this facility indicates it has 

two small boilers and a 58 MMBtu/hr ground flare. The flare is designated as an 

emergency flare and has permit conditions requiring a minimum flare temperature and 

a non-resettable totalizing fuel meter.

 

11 2016 AQMP RACT SIP page 3.

12 SCAQMD November 2014 Supplemental Analysis, dated November 18, 2014, page 2

13 Facility Permit to Operate, Tidelands Oil Production Co, 949 Pier G Ave, Long Beach, CA, Facility ID 800325 

Draft, April 14, 2015.
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While Tidelands’ NOx emissions show a decreasing trend such that it is no longer a 

major source of NOx, the District should evaluate regulating non-refinery / non-landfill 

flares similar to San Joaquin Rule 4311 which requires flares greater than or equal to 

5.0 MMBtu/hr to submit a flare minimization plan for APCO approval. If additional

reductions are needed, the District may also want to evaluate whether increased flaring 

(e.g., routine use of emergency flares) at oil production or wastewater treatment 

facilities are occurring due to more stringent gas constituent limits imposed by pipeline 

gas companies or power plants.

4) Rule 1130 Graphic Arts

SCAQMD action:

SCAQMD’s 2016 AQMP RACT SIP states Rule 1130 is more stringent than AVAQMD 

Rule 1130 for flexographic specialty inks for facilities emitting more than 10 tons per 

year. It further states that for facilities that emit less than 10 tons per year and that use 

less than 2 gallons per day and less than 120 gallons per year, AVAQMD Rule 1130 

has more restrictive VOC content limits for flexographic specialty inks used for flexible 

package printing (383 g/l). In contrast, SCAQMD Rule 1130 allows 460 g/l for metallic 

ink and 535 g/l for matte finish ink for no more than 2 gallons per day and less than 125 

gallons per year.

14 The 2016 AQMP RACT SIP further states that the emission 

reduction potential for this category is de minimis based on the number of affected 

facilities (0.006 tpd), but will analyze the viability of creating a new sub-category.

EPA Evaluation

The EPA’s original concern with Rule 1130 was it did not meet the recommended 

fountain solution VOC limits in the 2006 CTG for offset lithographic printing and 

letterpress printing. SCAQMD amended Rule 1130 on May 2, 2014 to conform to the 

CTG and on July 14, 2015, the EPA approved it into the SIP as implementing RACT.

To determine whether AVAQMD Rule 1130’s flexographic specialty ink VOC content 

limit is more stringent than the SCAQMD limit, we found that AVAQMD further limits 

flexographic specialty inks to no greater than 300 g/l for facilities with the potential to 

emit or with actual emissions of at least 10 tpy (AVAQMD Rule 1130 (C)(2)(b) - SIP 

approved on October 5, 2015). However, discussion with AVAQMD indicates they have 

no flexographic printers.15 We therefore continue to believe SCAQMD Rule 1130 

implements current RACT and we are not aware of any information that would alter our 

prior determination. No further action is required for RACT.

5) Rule 1112 Emissions of Oxides of Nitrogen from Cement Kilns and

Rule 2002 Allocations for Oxides of Nitrogen (NOx) and Oxides of Sulfur (SOx)

 

14 2016 AQMP RACT SIP page 3.

15 Email dated April 30, 2015, from Tracy Walters (AVAQMD) to Vanessa Graham (USEPA), RE: “AVAQMD Rule 

1130 – Graphic Arts”.
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Portland cement is manufactured by mixing together raw materials at high temperatures 

in a rotary kiln. The intermediate product that exits the kiln is called “clinker”, which is 

then ground up to make cement.16

SCAQMD action:

SCAQMD determined its NOx emissions rate limit for cement kilns is slightly higher 

(2.73 vs 2.3 lbs/ton of clinker) than the limit in BAAQMD Regulation 9, Rule 13. 

SCAQMD further notes that the averaging time for its NOx limit is one year using a 

continuous emissions monitoring system, while the BAAQMD allows a 30 day averaging 

period. The 2016 AQMP RACT SIP states it will assess the feasibility of reducing NOx 

emissions from cement kilns through its RECLAIM program and will compare the 

impacts of alternate averaging periods.17

EPA Evaluation

Subsequent to the 2016 AQMP RACT SIP submittal, SCAQMD determined that both 

cement plants in the District (Cal Portland Cement and Riverside Cement) are no longer 

producing clinker.18 Specifically, SCAQMD stated the permits for the two cement kilns 

at Cal Portland Cement have been inactive and all permits at Riverside Cement have 

been inactivated and the facility is officially shut down. EPA Region 9 Air Enforcement 

staff also confirmed that the cement kilns are shutdown. Consequently, the EPA 

concludes there are currently no major NOx sources of Portland cement kilns in the 

District and this source category is no longer subject to RACT since there are no major 

source cement kilns operating in the District.

Nonetheless, we note that the District amended its RECLAIM rule on December 4, 

2015 to lower the NOx emission factor for cement kilns to 0.5 lb per ton of clinker. 

6) Rule 1128 Paper, Fabric, and Film Coating Operations 

SCAQMD action:

Rule 1128 is not discussed in the SCAQMD’s 2016 AQMP RACT SIP. The District’s 

2007 AQMP (Table 3) compares Rule 1128’s 15% VOC limit or 85% capture and 

control against the Midwest Regional Planning Organization (RPO)’s proposed limit of 

100% capture and 90-95% control efficiency for existing sources and 97% control for 

 

16 EPA 530-R-08-007, Study on Increasing the Usage of Recovered Mineral Components in Federally Funded 

Projects Involving Procurement of Cement or Concrete; Appendix A: Overview of Portland Cement and Concrete. 

https://www.epa.gov/sites/production/files/2016-03/documents/report4-08.pdf

17 2016 AQMP RACT SIP page 3 and SCAQMD Board Meeting June 6, 2014, Agenda No. 31 page 3.

18 Email dated January 15, 2016, from Sang-Mi Lee (SCAQMD) to Stanley Tong (USEPA), RE: “FW Cal Portland 

Cement and Riverside Cement Permit Status”.
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new/reconstructed sources.

19 SCAQMD’s 2007 AQMP states the “incremental increase 

from 85% to 90-97% in control efficiency is not cost-effective for the existing sources in

the South Coast air basin.” The District’s January 2015 Supplement to the 24-Hour 

PM2.5 State Implementation Plan states the District’s rule is more stringent than the 

2007 CTG and the incremental increase in control efficiency is not cost-effective.20

EPA Evaluation

Rule 1128, amended March 8, 1996, specifies a maximum VOC content of 265 grams 

per liter for coatings or allows compliance using an approved emissions control system 

meeting 90% capture and 95% control for any coating in any paper, fabric or film 

coating application process. Cleaning materials are limited to 15% or less VOC or 85% 

capture and control efficiency.

The CTG for Paper, Film and Foil Coatings (EPA 453/R-07-003) recommends an 

overall VOC control efficiency of 90 percent for each coating line. Alternatively, the CTG 

allows emission limits that are equivalent to 90 percent overall control. The CTG applies 

to individual surface coating lines with a potential to emit, prior to controls, of at least 25 

tpy of VOC. 

For cleaning materials, the 2007 CTG does not recommend add-on controls. It states 

“Add-on controls would be a costly alternative for reducing VOC emissions from 

cleaning materials because the area to be controlled is quite large and a large volume 

of air would be captured and directed to a control device.” The CTG also states it does 

not recommend the use of a VOC content or VOC composite vapor pressure limit for 

cleaning materials. 

Subsequent discussion with SCAQMD indicated it does not have any paper coating 

facilities subject to the CTG’s applicability threshold of at least 25 tpy of VOC, prior to 

controls for individual coating lines.

21 We therefore conclude SCAQMD does not have 

sources subject to the paper coating portion of the CTG for Paper, Film, and Foil 

coatings. Also see the earlier discussion on negative declarations.

7) Motor Vehicle Assembly Line Coatings Rule 1115

SCAQMD action:

 

19 The 2007 AQMP does not provide a citation to the RPO proposal. We found Identification and Evaluation of 

Candidate Control Measures, April 14, 2005 (http://www.ladco.org/reports/control/bart/final_report_mactec.pdf

p.21) which lists potential recommendations to tighten RACT, but it appears these recommendations have not 

been adopted. e.g., Illinois’ paper coating limits were effective 6/19/1998. See Section 215.204 

http://www.ipcb.state.il.us/documents/dsweb/Get/Document-11924

20 Supplement to the 24-Hour PM2.5 State Implementation Plan for the South Coast Air Basin, Board Meeting 

Date February 6, 2015, Agenda No. 22, page D-33. http://www.aqmd.gov/docs/defaultsource/Agendas/Governing-Board/2015/2015-feb6-022.pdf?sfvrsn=2

21 Email dated February 4, 2016, from Kalam Cheung (SCAQMD) to Stanley Tong (USEPA), RE: “2014 Ozone 

RACT SIP- Rule 1106 and Rule 1128”.
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SCAQMD’s 2016 AQMP RACT SIP does not address coatings from automobile 

assembly line coatings, but its 2012 AQMP for the 24-hour PM2.5 standard states the 

Auto and Light-Duty Truck Assembly Coatings “CTG has more stringent limits for 

electro-deposition primer at 84 g/L (145 g/L in Rule 1115); sprayable primer, primersurfacer, and topcoat at 144 g/L (180 g/L in Rule 1115); and trunk coatings, interior 

coatings, sealers, and deadeners at 650 g/L (Rule 1115 exempts these categories). 

The District’s 2012 AQMP states that Rule 1115 has a small inventory of about 0.01 

tpd, thus no action is needed.”22 The District’s November 2014 Supplemental Analysis

to the 2016 AQMP RACT SIP further states that Rule 1171, Solvent Cleaning 

Operations, has strict VOC emissions limits (25 grams/liter) on solvent cleaning 

procedures and therefore Rules 1115 and 1171 combined meets federal RACT 

requirements.

EPA Evaluation

CAA §182(b)(2) requires CTG sources and major non-CTG sources to implement 

RACT. RACT under section 182(b)(2) differs from RACM/RACT under section 172(c) in 

that section 182(b)(2) is a technology control-based requirement and is not obviated 

because the emissions inventory for a particular stationary source category is very 

small and will not advance attainment. 

SCAQMD’s November 2014 Supplemental Analysis indicates the following facilities are

subject to Rule 1115 – Motor Vehicle Assembly Line Coatings:

AMREP Inc, Ontario, CA - 9906 lbs/yr; 4.9 tpy

manufactures refuse trucks23

The Paint Department, Chino, CA - 6919 lbs/yr; 3.5 tpy

refinishes recreational and commercial vehicles24

Not subject to RACT as vehicle refinishing is not a CTG and this is not a major source

El Dorado National – Riverside, CA – 5897 lbs/yr; 2.9 tpy

manufactures buses

On further discussion with SCAQMD and EPA’s Office of Air Quality Planning and 

Standards, it was determined that the coating of heavier duty vehicles are covered by 

the CTG for Miscellaneous Metal and Plastic Parts Coatings and not the CTG for Auto 

 

22 Final 2012 AQMP for 24-hour PM2.5, February 2013, Appendix VI: Reasonably Available Control Measures 

(RACM) Demonstration, page VI-10. http://www.aqmd.gov/docs/default-source/clean-air-plans/air-qualitymanagement-plans/2012-air-quality-management-plan/final-2012-aqmp-%28february-2013%29/appendix-vi-final2012.pdf

23 The company’s web site states its assembly line produces 500 reuse trucks per year. 

http://www.amrepinc.com/assemblyline.htm

24 The Paint Department refinishes recreation and commercial vehicles and is not subject to the CTG for 

Automobile and Light Duty Truck Assembly Coatings. http://www.thepaintdepartment.com/
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and Light-Duty Truck Assembly Coatings. Therefore, Rule 1107, Coating of Metal Parts 

and Products, and not Rule 1115, Motor Vehicle Assembly Line Coating Operations, is 

the appropriate rule to compare against EPA’s 2008 CTG for Miscellaneous Metal and 

Plastic Parts Coatings. We agree that Rule 1107 implements RACT for heavier duty 

vehicles. No further SCAQMD action is required to demonstrate RACT for this category.

8) Marine Coating Operations Rule 1106

SCAQMD action:

Rule 1106 is not discussed in the SCAQMD’s 2016 AQMP RACT SIP. The District’s 

2012 AQMP for the 24-hour PM2.5 standard states its VOC content limits are generally 

similar to those in Ventura Rule 74.24 and Bay Area 8-43, except Bay Area has a lower 

limit for pretreatment wash primer at 420 g/L (780 g/L in Rule 1106) and recommends 

to further study the potential of lowering the emission standards.

25

Subsequent to submitting its 2016 AQMP RACT SIP, SCAQMD’s web site indicated the 

District plans to revise Rule 1106 to subsume the requirements of Rule 1106.1 –

Pleasure Craft Coatings Operations and to revise the VOC content limits for 

pretreatment wash primers, antenna, repair and maintenance thermoplastic, inorganic 

zinc, and specialty marking coatings in order to align the limits with the EPA’s CTG and 

other California air districts.26

EPA Evaluation

The EPA’s CTG for shipbuilding and repair facilities states “the NESHAPS can be used 

as a ‘model rule’ ”.27 We reviewed the VOC content limits in 40 CFR Part 63 subpart II 

National Emission Standard for Shipbuilding and Ship Repair (Surface Coating) against 

Rule 1106 and agree with SCAQMD’s assessment that Rule 1106’s VOC content limit 

is consistent with the NESHAPs with the exception of inorganic zinc (650 g/L vs 340 

g/L). ‘

The Shipbuilding and Ship Repair (Surface Coating) NESHAP applies to major source 

facilities. The provisions do not apply to coatings used in volumes <52.8 gallons / year 

provided the total volume of coatings exempted does not exceed 264 gallons per year 

at any facility.28 Subsequent to the 2016 AQMP RACT SIP submittal, SCAQMD 

 

25 Final 2012 AQMP for 24-hour PM2.5, February 2013, Appendix VI: Reasonably Available Control Measures 

(RACM) Demonstration, page VI-33. http://www.aqmd.gov/docs/default-source/clean-air-plans/air-qualitymanagement-plans/2012-air-quality-management-plan/final-2012-aqmp-%28february-2013%29/appendix-vi-final2012.pdf. 

26 Draft Staff Report, Proposed Amended Rule 1106 – Marine and Pleasure Craft Coating Operations, September 

2015, p. 1-1. http://www.aqmd.gov/docs/default-source/rule-book/Proposed-Rules/1106/par-1106-draft-staffreport-09-01-15.pdf?sfvrsn=6

27 61 FR 44050, 44052 (August 27, 1996) https://www3.epa.gov/airquality/ctg_act/61_FR_1996-08-27_44050.pdf

28 40 CFR 63.781 http://www.ecfr.gov/cgi-bin/textidx?SID=ff727d5f02984f37f4e253eb13951517&mc=true&node=se40.11.63_1781&rgn=div8
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determined that it only has one Title V shipyard, Willard Marine, and the shipyard does 

not use inorganic zinc coatings.29 CARB’s 2013 emissions inventory shows the total 

VOC emissions was 2 tpy for this facility and the facility does not appear in CARB’s 

2014 or 2015 inventory. 

The District may want to evaluate adopting a negative declaration for this category 

since it doesn’t appear there are facilities that exceed the CTG’s applicability threshold, 

9) Adhesive and Sealant Applications Rule 1168

SCAQMD action

In its 2012 AQMP, Table VI-4, SCAQMD indicates Rule 1168 does not fully meet the 

2008 CTG, and it may pursue a rule update. SCAQMD states the following categories 

are not consistent with EPA’s 2008 CTG for Miscellaneous Industrial Adhesives: 1) 

reinforced plastic composite VOC limit: CTG 200 g/l, Rule 250 g/l, 2) single-ply roof 

membrane adhesive primer: CTG 250 g/l, Rule 450 g/l, 3) other adhesive primers: 

CTG 250 g/l, Rule 420 g/l, 4) VOC control efficiency: CTG 85%, Rule 80%.

 EPA evaluation

EPA considers the 2008 CTG reinforced plastic composite category (200 g/l) to be the 

same as Rule 1168’s fiberglass category (80 g/l) and find that the SCAQMD rule is more 

stringent than the CTG. For the single-ply roof membrane adhesive and adhesive primer 

category, the 2008 CTG recommends a limit of 250 g/l. Rule 1168 matches these 

limits.30 Rule 1168 limits single ply roof membrane sealants to 450 g/l while the CTG 

does not regulate this category. SCAQMD should update its 80% control efficiency limit 

to meet the 85% CTG recommendation.

10)Cutback Asphalt Rule 1108 and Emulsified Asphalt Rule 1108.1

If additional emissions reductions are needed beyond RACT, the District may want to 

investigate Warm Mix asphalt as an option to hot mix asphalt – See San Joaquin 2015 

DRAFT Warm Mix Asphalt Further Study Report 

http://www.valleyair.org/notices/Docs/2015/12-01-15_%28WMA%29/WMA.pdf and 

EPA’s December 23, 2015 comments on the draft report.

11)Newer versions of rules not submitted for SIP approval

The following table lists SCAQMD amended rules that have not been submitted to the 

EPA for SIP approval. The May 1, 2009 amendment to Rule 1171 extends an exemption

for cleaning of application equipment used to apply solvent-borne fluoropolymer coatings

 

29 Email dated February 4, 2016, from Kalam Cheung (SCAQMD) to Stanley Tong (USEPA), RE: “2014 Ozone 

RACT SIP- Rule 1106 and Rule 1128”.

30 Rule 1168 has a category called architectural non porous sealant primers which we believe correlates to the 

2008 CTG’s adhesive primer category. 
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which expired on December 31, 2008 in the SIP approved version of the rule (February 

1, 2008). This creates a SIP gap where the local rule allows this exemption, but the SIP 

rule does not and could leave a facility vulnerable as EPA would enforce the SIP rule 

requirements. 

12)NOx RECLAIM

The EPA first approved SCAQMD’s RECLAIM program into the California SIP in June 

1998 based in part on a conclusion that the NOx emission caps in the program satisfied 

the RACT requirements of CAA section 182(b)(2) and (f) for covered NOx emission 

sources in the aggregate.31 In 2005 and 2010, the District adopted revisions to its 

RECLAIM program, which the EPA approved on August 29, 2006 and August 12, 2011, 

respectively, based in part on conclusions that the revisions continued to satisfy RACT 

requirements at the time of the rule revisions.32 However, based on new information 

contained in SCAQMD’s December 2015 Draft Final Staff Report (“2015 staff report”) 

revising Rule 2002 “Allocations for Oxides of Nitrogen (NOx) and Oxides of Sulfur (SOx)”,

additional NOx reductions are now required to achieve RACT, as evidenced by the lack of 

controls on some refinery boiler units and the District’s proposal to reduce the NOx

RECLAIM emissions cap.33

A more detailed discussion about RECLAIM and the requirement that the program 

ensures, in the aggregate, NOx emissions reductions equivalent to RACT-level controls 

can be found in our partial approval/disapproval of the South Coast Moderate Area Plan 

for the 2006 PM2.5 NAAQS.34 We propose to partially approve and partially disapprove the 

2016 AQMP RACT SIP certification because the District’s 2015 staff report states that 

some refinery boilers/heaters were expected to, but did not install controls such as 

selective catalytic reduction that the District considers available, achieved-in-practice and 

 

31 See EPA’s partial approval / disapproval of SCAQMD Moderate Area Plan for the 2006 PM2.5 NAAQS at 81 FR 

22025, 22027 (April 14, 2016) citing 61 FR 57834 (November 8, 1996) and 63 FR 32621 (June 15, 1998)

32 71 FR 51120 (August 29, 2006) and 76 FR 50128 (August 12, 2011).

33 Draft Final Staff Report, Proposed Amendments to Regulation XX Regional Clean Air Initiatives Market 

(RECLAIM) NOx RECLAIM, December 4, 2015 http://www.aqmd.gov/docs/default-source/Agendas/GoverningBoard/2015/2015-dec4-030.pdf?sfvrsn=9

34 81 FR 22025, 22027 and 22028 (April 14, 2016) discussing an absence of a demonstration that the 2010 

RECLAIM program ensures, in the aggregate, NOx emission reductions equivalent to RACT-level controls.

Rule Current SC

Version

Submitted Current SIP Approved 

version 

1122 Solvent Degreasers 5/1/09 No 10/1/04

2/8/06 (71 FR 6350)

1171 Solvent Cleaning 

Operations

5/1/09 No 2/1/08

9/29/11 (76 FR 60376)
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cost effective and that a new revised NOx RECLAIM cap is needed to ensure RACT is 

being achieved.35

On December 4, 2015, SCAQMD adopted a new NOx emissions cap for RECLAIM which 

reflects a best available retrofit control technology level of 2 ppmv NOx for refinery 

boilers/heaters >40 MMBtu/hr indicating that controls “are either commercially available, 

achieved-in-practice and/or can be designed to achieve 2 ppmv NOx in a cost-effective 

manner.”36 The EPA will evaluate the December 4, 2015 RECLAIM Rule amendment for 

RACT when it is submitted for SIP approval.

Public Comments

SCAQMD’s 2016 AQMP RACT SIP was made available for public comment. The Board 

hearing package states one comment was received during the 30-day public notice period 

“pertaining to reduction of methane and related gases emanating from oil and gas wells.” The 

District’s response stated “such emission reductions may be suited for a future control measure 

investigation, since a RACT analysis is restricted only to adopted rules and regulations.” No 

comments were receive during the Board hearing.

Summary

With the exception of Rule 2002, SCAQMD’s 2016 AQMP RACT SIP as supplemented by its

2007, 2012 AQMPs and November 2014 Supplemental Analysis largely supports the District’s 

certification that its regulations meet or exceed RACT.

Rule 2002 (November 5, 2010) does not implement RACT as evidenced by the lack of 

controls on some refinery boiler units and the District’s proposal to reduce the NOx RECLAIM 

emissions cap. 

We propose to approve SCAQMD’s certification that its rules satisfy RACT, with the exception 

of Rule 2002’s NOx emissions cap. We propose to disapprove SCAQMD’s determination that 

the November 5, 2010 SIP version of Rule 2002 continues to implement NOx RACT in the 

aggregate for certain NOx sources.

Final disapproval will result in offset and highway sanctions unless EPA approves a SIP 

revision amending Rule 2002 as fulfilling NOx RACT for refinery boilers within 18 months of 

the effective date of the disapproval. See CAA section 179(b) and 40 CFR 52.31. We will not 

finalize this partial disapproval, however, if we fully approve a rule fulfilling NOx RACT for 

refinery boilers before finalizing action on the 2016 AQMP RACT SIP. EPA is committed to 

working with CARB and the District to resolve this RACT deficiency, and we encourage the 

State and District to submit a SIP revision correcting the identified deficiency as expeditiously 

as practicable. A revised 2016 AQMP RACT SIP demonstration will not be necessary if the 

submitted rule amendments correct the identified deficiency. 

 

35 Draft Final Staff Report, Proposed Amendments to Regulation XX Regional Clean Air Initiatives Market 

(RECLAIM) NOx RECLAIM, December 4, 2015 (p. 78, 92, 267-268)

36 Id. (p. 92)
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In addition, CAA section 110(c)(1) provides that EPA must promulgate a Federal 

Implementation Plan (FIP) within two years after finding that a State has failed to make a 

required submission or disapproving a SIP submission in whole or in part, unless EPA 

approves a SIP revision correcting the deficiencies within that two-year period. 

Suggestions for Improvement

1) Negative Declarations – evaluate adopting negative declarations for the paper coating 

portion of the Paper, Film, and Foil coating CTG and for the Shipbuilding and Ship 

Repair (Surface Coating) CTG or amending the associated rules.

2) Rule 1118 Flares – Evaluate expanding the rule to include non-refinery / non-landfill 

flares (e.g., oil and gas production and wastewater flares) similar to San Joaquin Rule 

4311 which requires a flare minimization plan for all flares >5 MMBTU/hr. If additional 

reductions are needed, evaluate whether increased flaring (e.g., routine use of 

emergency flares) at oil production facilities or wastewater treatment facilities are

occurring due to more stringent gas constituent limits imposed by pipeline gas 

companies or power plants.

3) Rule 462 Organic Liquid Loading – Evaluate adopting a VOC limit of 0.04 pounds/1000 

gallons of organic liquid transfer subject to the outcome of the District’s evaluation of 

differences in bulk terminal and cargo tank monitoring protocols between BAAQMD and 

SCAQMD.

REFERENCES -

1. SCAQMD 2016 AQMP Reasonably Available Control Technology (RACT) 

Demonstration, dated May 22, 2014, Adopted June 6, 2014; Submitted – July 18, 2014.

http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board/2014/2014-jun6-

031.pdf?sfvrsn=2

2. 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.

3. RACT SIPs, Letter dated April 4, 2006 from EPA Region IX (Andrew Steckel) to CARB 

(Kurt Karperos) listing EPA’s current CTGs, ACTs, and other documents which may 

help to establish RACT.

4. RACT Qs & As – Reasonably Available Control Technology (RACT): Questions and 

Answers, May 18, 2006 Note from William T. Harnett, Director, Air Quality Policy 

Division, to Regional Air Division Directors. 

https://www3.epa.gov/ttn/caaa/t1/memoranda/ractqanda.pdf

5. “Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard –

Phase 2” (70 FR 71612; November 29, 2005).

https://www.gpo.gov/fdsys/pkg/FR-2005-11-29/pdf/05-22698.pdf
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6. “Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State 

Implementation Plan Requirements’’ (80 FR 12264; March 6, 2015).

https://www.gpo.gov/fdsys/pkg/FR-2015-03-06/pdf/2015-04012.pdf

7. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” (a.k.a., 

Bluebook) EPA OAQPS, May 25, 1988

http://archive.epa.gov/ttn/ozone/web/pdf/voc_bluebook.pdf

8. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” (a.k.a., 

Little Bluebook), EPA Region 9, August 21, 2001 

http://www.arb.ca.gov/drdb/lbb2001.pdf

9. “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); (57 FR 18070; April 

28, 1992).

10. “State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for 

the Implementation of Title I of the Clean Air Act Amendments of 1990” (57 FR 55620, 

November 25, 1992) (“the NOx Supplement”).

11. EPA’s CTGs and ACTs https://www.epa.gov/ozone-pollution/control-techniquesguidelines-and-alternative-control-techniques-documents-reducing

12. CARB’s emissions inventory database 

http://www.arb.ca.gov/app/emsinv/facinfo/facinfo.php

13. SCAQMD, CARB, and EPA Region IX databases of SCAQMD rules

SCAQMD: http://www.aqmd.gov/home/regulations/rules/scaqmd-rule-book

CARB: http://www.arb.ca.gov/rldb/rldb.htm

EPA: http://www.epa.gov/approved-sips/approved-sips-region-9

14. EPA Region 9 December 23, 2015 comments on San Joaquin Valley APCD’s 2015 

DRAFT Warm Mix Asphalt Further Study Report.

15. 2007 AQMP Appendix VI: Reasonably Available Control Measures (RACM) (June 

2007) http://www.aqmd.gov/docs/default-source/clean-air-plans/air-qualitymanagement-plans/2007-air-quality-management-plan/2007-aqmp-appendixvi.pdf?sfvrsn=2; 

16. 2012 AQMP Appendix VI: Reasonably Available Control Measures (RACM) 

Demonstration (February 2013) http://www.aqmd.gov/docs/default-source/clean-airplans/air-quality-management-plans/2012-air-quality-management-plan/final-2012-

aqmp-(february-2013)/appendix-vi-final-2012.pdf 
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17. San Joaquin Valley APCD, 2015 DRAFT Warm Mix Asphalt Further Study Report, 

December 1, 2015 http://www.valleyair.org/notices/Docs/2015/12-01-

15_%28WMA%29/WMA.pdf

18. Draft Final Staff Report, Proposed Amendments to Regulation XX Regional Clean Air 

Initiatives Market (RECLAIM) NOx RECLAIM, December 4, 2015 

http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board/2015/2015-dec4-

030.pdf?sfvrsn=9

19. Email dated November 25, 2014, from Joe Cassmassi (SCAQMD) to Stanley Tong 

(USEPA), RE: “SCAQMD RACT Analysis Draft 20141119(2) hereinafter “November 

2014 Supplemental Analysis”. 

20. Email dated April 30, 2015, from Tracy Walters (AVAQMD) to Vanessa Graham 

(USEPA), RE: “AVAQMD Rule 1130 – Graphic Arts”.

21. Email dated January 15, 2016, from Sang-Mi Lee (SCAQMD) to Stanley Tong 

(USEPA), RE: “FW Cal Portland Cement and Riverside Cement Permit Status”.

22. Email dated January 29, 2016, from Kalam Cheung (SCAQMD) to Stanley Tong 

(USEPA), RE: “New Title V Facilities since 2006”.

23. Email dated February 4, 2016, from Kalam Cheung (SCAQMD) to Stanley Tong 

(USEPA), RE: “2014 Ozone RACT SIP- Rule 1106 and Rule 1128”.