R. Corey 

June 12, 2014 

Page 2 

Attachments: 

 I. SIP Completeness Checklist 

 II. A Resolution of the Ventura County Air Pollution Control Board Approving and 

Adopting the 2014 Reasonably Available Control Technology State 

Implementation Plan Revision

 III. Final 2014 Reasonably Available Control Technology State Implementation Plan 

Revision

 IV. June 10, 2014 Ventura County Air Pollution Control Board Packet for the 2014 

Reasonably Available Control Technology State Implementation Plan Revision

 V. Certificate of Publication – Public Notice 

 VI. Notice of Exemption from California Environmental Quality Act 

cc (electronic): Andy Steckel, EPA Region IX (w/attachments) 

 Stanley Tong, EPA Region IX (w/attachments) 

 Kurt Karperos, ARB (w/attachments) 

 Sylvia Vanderspek, ARB (w/attachments) 
ATTACHMENT I

SIP COMPLETENESS CHECKLIST
Attachment I

SIP COMPLETENESS CHECKLIST

Agency: Ventura County Air Pollution Control District 

669 County Square Drive, 2nd Floor 

Ventura, California 93003 

Plan Submitted: 2014 Reasonably Available Control Technology State Implementation 

Plan Revision (2014 RACT SIP Revision) 

Adoption Date: June 10, 2014 

 1. Evidence That the District Adopted the Plan and That the District Followed All 

of the Requirements of its Administrative Procedures Act:

Attachment II is a signed resolution from the Ventura County Air Pollution Control Board 

adopting the 2014 Reasonably Available Control Technology State Implementation Plan 

Revision. Attachment II also certifies that the 2014 RACT SIP Revision was adopted after 

holding a public hearing. 

 2. District Authority for Adoption: 

California Health & Safety Code, Part 3, Chapter 1, Section 40001.

 3. Copy of Adopted Plan: 

The 2014 Reasonably Available Control Technology State Implementation Plan Revision is 

included as Attachment III.

 4. Compilation of Public Comments and the District's Responses:

No written comments were received on the 2014 RACT SIP Revision. Attachment IV is the 

June 10, 2014 Ventura County Air Pollution Control Board Packet for the 2014 Reasonably 

Available Control Technology State Implementation Plan Revision which includes all 

materials presented at the public hearing. 

 5. Evidence that Public Notice Was Given of the Proposed Adoption of the Plan:

Attachment V is a copy of the Certificate of Publication for the Public Notice. The Public 

Notice was published at least 30 days prior to the public hearing. In addition, Attachment VI 

is a copy of the public posting of the 2014 RACT SIP Revision Notice of Exemption from 

the California Environmental Quality Act which was filed and posted the day of the public 

hearing. 

LIST OF ATTACHMENTS 

 I. SIP Completeness Checklist (this document) 

 II. A Resolution of the Ventura County Air Pollution Control Board Approving and 

Adopting the 2014 Reasonably Available Control Technology State Implementation Plan 

Revision

 III. Final 2014 Reasonably Available Control Technology State Implementation Plan 

Revision

 IV. June 10, 2014 Ventura County Air Pollution Control Board Packet for the 2014 

Reasonably Available Control Technology State Implementation Plan Revision

 V. Certificate of Publication – Public Notice 

 VI. Notice of Exemption from the California Environmental Quality Act 
ATTACHMENT II

A RESOLUTION OF THE VENTURA COUNTY AIR POLLUTION CONTROL 

BOARD APPROVING AND ADOPTING THE 2014 REASONABLY AVAILABLE

TECHNOLOGY STATE IMPLEMENTATION PLAN REVISION


ATTACHMENT III

2014 REASONABLY AVAILABLE CONTROL TECHNOLOGY STATE 

IMPLEMENTATION PLAN REVISION
VENTURA COUNTY AIR POLLUTION CONTROL DISTRICT 

2014 REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) 

STATE IMPLEMENTATION PLAN (SIP) REVISION 

JUNE 10, 2014 

BACKGROUND 

The federal Clean Air Act Amendments 

(CAAA) of 1990 give the states primary 

responsibility for achieving the national 

ambient air quality standards (NAAQS). The 

NAAQS are set by the U.S. Environmental 

Protection Agency (EPA) as the maximum 

concentrations in the atmosphere for specific 

air contaminants to protect public health and 

welfare. 

The principal mechanism at the state and local 

level for complying with the CAAA is the State 

Implementation Plan (SIP). A SIP outlines the 

programs, actions, and commitments a state 

will carry out to implement its responsibilities 

under the CAAA. 

The EPA must approve all SIPs before they can 

be implemented by state and local 

governments. Once approved by the EPA, a 

SIP becomes a legally binding document under 

both state and federal law, and may be enforced 

by either government. 

Since its formation in 1968, the Ventura 

County Air Pollution Control District has 

prepared numerous air quality planning 

documents to meet state and federal clean air 

mandates. The most important of these are the 

air quality management plans (AQMPs). These 

documents outline the District’s long-range 

strategy for providing clean, healthful air to the 

citizens and businesses of Ventura County and, 

once approved by EPA, become components of 

the California SIP. 

The AQMPs are not one-time documents, but 

periodically get updated and revised in 

accordance with changes in governing law and 

air pollution control science and technology. 

Moreover, each successive AQMP builds on its 

predecessor. The last major Ventura County 

AQMP was the 2007 AQMP. It was prepared 

to satisfy requirements of the CAAA for the 

1997 federal 8-hour ozone standard. 

Central to Ventura County’s AQMPs are 

stationary source control measures. Stationary 

source control measures are techniques and 

equipment for reducing ozone precursor 

emissions, reactive organic compounds (ROC) 

and nitrogen oxides (NOx), from stationary 

sources in the county. Examples of stationary 

source control measures include gasoline 

station vapor recovery systems, landfill gas 

recovery systems, and catalytic emission 

control systems on engines and various other 

combustion devices. 

Stationary source control measures provide the 

framework from which enforceable rules that 

reduce harmful air emissions and improve air 

quality are developed. The District's rules 

apply to many activities including open 

burning, incineration, gasoline storage, paint 

and solvent use, dry cleaning, screen printing, 

asphalt paving, chrome plating, fuel 

combustion, and landfills. 

The CAAA require that states achieve the 

NAAQS by specified dates based on the 

severity of an area’s air quality problem. 

Ventura County is currently designated a 

serious ozone nonattainment area for the 2008 

federal 8-hour ozone standard. As a serious 

nonattainment area, Ventura County is required 
2014 RACT SIP 

June 10, 2014 

Page 2 of 43 

by the CAAA to attain the federal 8-hour ozone 

standard by December 31, 2021. 

Sections 182(b)(2) and 182(f) of the federal 

Clean Air Act (42 U.S.C. §7511a) require that 

ozone nonattainment areas implement 

reasonably available control technology 

(RACT) for sources that are subject to Control 

Techniques Guidelines (CTG) issued by EPA 

and for “major sources” of VOC and NOx, 

which are ozone precursors. RACT is defined 

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 53762; 

September 17, 1979). 

RACT requirements are included in the Clean 

Air Act to assure that significant source 

categories of ozone precursor emissions are 

controlled to a “reasonable” extent, but not 

necessarily to the more stringent best available 

control technology (BACT) or “lowest 

achievable emission rate” (LAER) levels 

expected for new or modified major stationary 

sources. CTGs define RACT for existing 

sources of air pollution. Emission sources 

covered by CTGs are known as CTG sources. 

DISTRICT’S RACT SIP EVALUATION 

INTRODUCTION 

According to the EPA’s Proposed Rule to 

Implement the 2008 8-Hour Ozone 

NAAQS (78 FR 34178; June 6, 2013), areas 

classified as moderate nonattainment or higher 

must submit a demonstration that their current 

rules fulfill 8-hour ozone RACT for all CTG 

categories and all major, non-CTG sources as 

a revision to their ozone SIPs. 

RACT SIPs must contain adopted RACT 

regulations, certifications where appropriate 

that existing provisions are RACT, and/or 

“negative declarations” that there are no 

sources in the nonattainment area covered by a 

specific CTG source category. States must 

provide notice and opportunity for public 

comment on their RACT submission even 

where the state determines to certify that the 

existing provisions remain RACT or where the 

state submits a negative declaration. States 

must also submit appropriate supporting 

information for their RACT demonstrations. 

RACT demonstrations can be made with either 

a RACT determination or by certifications that 

previously required RACT controls represent 

RACT for the 8-hour ozone standard. A 

RACT determination includes a description of 

the RACT emission limit for the source 

category with technical and economic 

feasibility analysis and a commitment to adopt 

such an emission limit in an enforceable 

regulation by the regulatory deadline. If 

existing regulations that are already part of the 

SIP meet current RACT requirements, the 

agency may include certifications to that effect 

in their RACT SIP updates. Alternatively, air 

pollution control agencies in nonattainment 

areas may adopt negative declarations 

documenting that the area has no stationary 

sources subject to RACT requirements. 

Areas should use current EPA guidance and 

any other information available in making 

RACT determinations. EPA has recognized 

that existing CTGs and ACTs for many source 

categories have not been updated in a number 

of years. However, in most cases, more recent 

technical information is available in other 

forms, such as EPA’s RACT/BACT/LAER 

Clearinghouse; SIPs for other nonattainment 

areas, in particular those areas with higher 

classifications; the ‘‘Menu of Control 

Measures’’ for NOX and VOC; and emissions 

standards developed under CAA section 

111(d) and new source review 
2014 RACT SIP 

June 10, 2014 

Page 3 of 43 

(NSR)/prevention of significant deterioration 

(PSD) settlement agreements. As part of their 

RACT SIP submission, areas should provide 

adequate documentation that they have 

considered control technology that is 

economically and technologically feasible. 

The analysis of economic and technological 

feasibility should be based on information that 

is current as of the time of development of the 

RACT SIP for the 2008 ozone NAAQS. In 

other words, it is not sufficient for areas to rely

on previous RACT determinations without 

considering more recent information. Where 

public commenters submit specific 

information about controls that are alleged to 

be reasonably available in light of 

technological and economic feasibility, the 

area should consider such information in 

developing its RACT SIP. The EPA generally 

considers controls that have been achieved in 

practice by other existing sources in the same 

source category to be technologically and 

economically feasible. 

EPA Headquarters released official guidance 

for preparing RACT SIPs on May 18, 2006. 

The guidance is in a question and answer 

format and is titled Questions Related to RACT 

in 8-hour Ozone Implementation (May 18, 

2006). In addition, EPA Region 9 issued a 

basic framework for the RACT SIPs. That 

framework was contained in a letter 

(March 9, 2006) from EPA Region 9 to the 

California Air Resources Board (CARB) and is 

presented below: 

• Describe efforts to identify all source 

categories within the District requiring 

RACT, including CTG sources (i.e., 

covered by an EPA Control Techniques 

Guideline document) and major non-CTG 

sources. 

• Submit Negative Declarations where there 

are no facilities (major or minor) within the 

District subject to a CTG. 

• For all categories needing RACT, list the 

state/local regulation that implements 

RACT. It may also be helpful to list the 

date EPA approved these regulations as 

fulfilling RACT. 

• Describe the basis for concluding that the 

regulations fulfill RACT. Documents 

useful in establishing RACT include CTGs, 

Alternative Control Techniques (ACT) 

guidance, Maximum Achievable Control 

Technology (MACT) standards, New 

Source Performance Standards (NSPS), 

California Suggested Control Measures 

(SCM) and RACT/Best Available Retrofit 

Control Technology (BARCT) 

determinations, regulations adopted in other 

Districts, and guidance and rules developed 

by other state and local agencies. 

• Some Districts may use the California Air 

Pollution Control Officers Association 

(CAPCOA) September 2003 Potential All 

Feasible Measures (AFM) Report to 

help demonstrate RACT. If so, the RACT 

SIP should certify that local regulations are 

equivalent to AFM, justify the assumption 

that the AFM fulfilled RACT in 2003, and 

include some sort of certification or 

demonstration that no additional controls 

have become more reasonably available 

since then. 

DETERMINATION OF RACT 

CTG Sources 

The EPA has issued CTGs defining RACT for 

existing facilities that emit air pollutants. A 

list of CTGs and ACT documents are posted at 

http://www.epa.gov/glo/SIPToolkit/ctgs.html. 
2014 RACT SIP 

June 10, 2014 

Page 4 of 43 

District staff reviewed the list and, for those 

source categories with a CTG, compared the 

sources covered by the CTG to each District 

rule. 

Table B-1 presents the source categories, 

reference documents, applicable District rules, 

and the date the rules were adopted and most 

recently revised. 

Table B-2 presents CTG source categories 

without sources subject to the CTGs in the 

District. In most such cases, there are no 

applicable District rules because there are no 

sources in the county. This was determined 

through the District’s permit system, 

emissions inventory systems, and 

knowledgeable staff of the District’s permit 

and enforcement divisions. In some cases, 

District rules applicable to the CTG source 

category were written for sources that no 

longer exist in the district or cover sources 

with emissions below the applicability 

threshold of the CTG. 

There is one source category listed in Table B2 that is a special case: Agricultural 

Pesticides. Ventura County has a substantial 

agricultural industry and agricultural pesticide 

use is a substantial source of ROCs in the 

county. However, agricultural pesticide use is 

not defined as a stationary source. Moreover, 

agricultural pesticide usage is regulated by the 

State of California and therefore is not under 

the District’s jurisdiction. 

Major Non-CTG Sources 

Sources not subject to CTGs, but for which 

RACT may still be required, are referred to as 

non-CTG sources. For this evaluation, District 

staff examined non-CTG sources that have the 

potential to emit 50 tons or more per year of 

either NOx or VOC. Twenty-five tons per year 

is the District’s current definition of “major 

source” in District Rule 26.1 (New Source 

Review). However, under EPA’s 8-hour ozone 

regulations for serious ozone nonattainment 

areas, the District’s major source threshold is 

50 tons per year of either ROC or NOx for 

major stationary sources. There are fifteen 

sources in Ventura County with ROC and/or 

NOx emissions of 50 tons per year or more. 

Table B-3 lists all of the 50 tons per year or 

greater “major source” ROC and NOx facilities 

in Ventura County. Table B-3 gives each 

facility’s permit number and facility name. 

Table B-3 also presents each District rule 

evaluated for the RACT SIP that applies to 

each facility. 

HOW DISTRICT RULES WERE 

DETERMINED TO MEET RACT 

REQUIREMENTS 

District staff started its RACT SIP evaluation 

by reviewing all available CTGs and ACTs and 

comparing them to District rules and sources. 

For each source category, District staff 

identified applicable sources and District rules. 

This was accomplished through the District’s 

permit and emissions inventory systems, and 

knowledgeable staff of the District’s permit and 

enforcement divisions. 

Following identification of District rules to be 

evaluated for the RACT SIP, District staff 

made determinations as to whether the rules 

meet RACT. The determinations were 

primarily based on comparing the rules with 

similar rules adopted by air districts with higher 

or “worse” ozone nonattainment classifications, 

pursuant to EPA’s June 2013 Proposed Ozone 

Implementation Regulation and EPA Region 

9’s March 2006 framework for the RACT SIPs 

(both discussed above). District staff also 

considered the District’s 2006 and 2009 RACT 

SIP evaluations. 

Staff included cost effectiveness in the 

evaluations as well. The District’s 2014 RACT 
2014 RACT SIP 

June 10, 2014 

Page 5 of 43 

SIP evaluations are presented starting on page 

21. The evaluations provide a determination 

whether each rule meets RACT as written or if 

updates are needed. 

RACT SIP EVALUATION FINDINGS 

Table B-4 presents all of the District rules 

evaluated for the 2014 RACT SIP. Given for 

each rule is the rule name, whether there is a 

corresponding CTG or ACT applicable to each 

rule, the original rule adoption date, and date of 

last rule revision. 

All rules applicable to CTG source categories 

were determined to meet or exceed the CTG 

requirements during the 2006 and 2009 RACT 

SIP updates, so the rules were not compared to 

CTG requirements again.1

 However, since 

many CTGs have not been updated for many 

years, staff compared District rules to rules 

adopted by districts with higher or “worse” 

ozone nonattainment classifications. 

Staff included cost effectiveness in the 

evaluations. In cases where rules in air districts

with higher ozone nonattainment classifications 

contain stricter requirements than District rules 

for similar sources, staff evaluated the cost 

effectiveness of those rules for application as 

RACT in Ventura County. EPA defines RACT 

as the lowest emission limitation that a 

particular source is capable of meeting by the 

application of control technology that is 

reasonably available considering technological 

and economic feasibility. Therefore, if the 

cost, in dollars per ton of pollutant removed, 

exceeded certain thresholds the control 

requirements were considered beyond RACT 

for Ventura County. 

 

1

 Ventura County APCD's 2006 RACT SIP certified the 

District's rules met RACT and the 2009 RACT SIP 

Revision certified the District's rules met EPA's CTGs 

issued between 2006 and 2008 and re-certified that all 

major non-CTG sources of VOC or NOx were covered 

by RACT rules. 

For NOx, staff used the inflation-adjusted cost 

threshold for NOx discussed by EPA in the 

Final Rule to implement the 8-hour Ozone 

National Ambient Air Quality Standard on 

page 71654 of the Federal Register Vol. 70, 

No. 228 published Tuesday, November 29, 

2005. A range of $160–1,300 per ton of NOx 

removed was considered RACT in 1994. 

Adjusting for inflation, staff used a cost 

effectiveness threshold of $1,990 per ton of 

NOx removed for RACT determinations for the 

2014 RACT SIP. 

For VOC, staff considered the BACT cost 

effectiveness threshold of $9 per pound 

($18,000 per ton) beyond RACT by definition. 

Therefore, any technology with costs greater 

than $18,000 per ton of VOC removed was 

considered not economically feasible as RACT. 

Since EPA has not provided guidance for VOC 

RACT cost-effectiveness, staff used $4,500 per 

ton of VOC controlled as a starting point to 

determine if a technology was economically 

feasible for application as RACT in Ventura 

County. This number was considered 

reasonable based on records of emission 

reduction credit trading in 2012 (the most 

recent data available). 

RACT Findings - CTG Sources & Major Non - 

CTG Sources 

Based on the foregoing, District staff finds that 

all District rules that apply to ozone precursor 

emissions fulfill RACT requirements for the 8-

hour ozone NAAQS. At a minimum, the rules 

meet RACT or, more commonly, significantly 

exceed RACT. Moreover, District staff finds 

that all CTG sources and major non-CTG 

sources under its jurisdiction are controlled to 

RACT or better standards. It should be noted 

that historically, the District has been very 

progressive and has consistently adopted rules 

that are much stricter than RACT. Therefore, 

even rules that have not been revised for a 
2014 RACT SIP 

June 10, 2014 

Page 6 of 43 

decade or more are often still effective as 

RACT or beyond. 

RACT Findings – Negative Declarations 

For any CTG/ACT source category where the 

District has no sources to which the CTG/ACT 

applies, the District must submit a finding to 

that effect called a Negative Declaration. The 

District has reviewed its permit and emissions 

inventory systems and consulted with 

knowledgeable District staff to determine if 

sources exist within the District for each CTG 

source category. For each CTG/ACT source 

category listed in Table B-2, the District has 

determined one or more of the following 

situations exist: 

• There are no sources or emitting facilities 

within the District for the specified 

CTG/ACT source category. 

• There are no sources or emitting facilities 

within the District with emissions 

exceeding the specific applicability 

threshold for the CTG/ACT source category 

(i.e. major sources or sources above the 

threshold specified in CTG/ACT 

document), before consideration of 

controls. 

• All sources within the District for the 

CTG/ACT source category were 

constructed with BACT so they are by 

definition subject to controls beyond RACT 

and the CTG/ACT does not apply. 

This constitutes the District’s Negative 

Declarations for the 2014 RACT SIP. If 

sources in any of the CTG/ACT categories 

locate within the District in the future, they will

be subject to the District’s New Source Review 

requirements, which are more stringent than 

RACT. 

CALIFORNIA ENVIRONMENTAL 

QUALITY ACT (CEQA) 

The 2014 RACT SIP Revision is an evaluation 

of current District air pollution rules and will 

neither result in new or revised District rules or 

regulations nor any physical change in the 

environment. Therefore, adoption of the 

proposed 2014 RACT SIP Revision is not a 

“Project” as defined in Section 15378(a) of the 

CEQA Guidelines and therefore is not subject 

to CEQA review pursuant to CEQA Guidelines 

Section 15060(c)(3).
2014 RACT SIP 

June 10, 2014 Page 7 of 43 Table B-1, Source Categories, CTG/ACT List, and Applicable District Rules 

Source Category Reference Document * Applicability VCAPCD Rule 

Coatings and SolventsAerospace Manufacturing and Rework Operations & Coating Operations 

Control of VOC Emissions from Coating Operations at Aerospace Manufacturing and Rework Operations (EPA-453/R-97-004, 1997/12), See also Aerospace MACT (59 FR-29216 6/06/94, 1994/06) 

Applies to aerospace coatings and cleaning solventsused at aerospace manufacturing and rework operations 

including contractors and subcontractors. 

Rule 74.13 - AerospacAssembly and Component Manufacturing Operatio

Supersedes the applicable parts of the Miscellaneous Metal Part and Products CTG. Does not apply to manufacturing or rework operations involving space vehicles; rework operations performed on antique aerospace vehicles or components; or research and development, quality control, laboratory testing, and 

electronic parts and assemblies (except for cleaning and coating of completed assemblies). 

Rule 74.12 - Surface Coating of Metal Parts and Products 

Automobile Refinishing Reduction of Volatile Organic 

Compound Emissions from Automobile Body Refinishing (EPA453/R-94-031, 1994/04) 

Applies to automobile refinishing operations. Rule 74.18 – Motor 

Vehicle and Mobile Equipment Coating Operations 

Automobile Refinishing (EPA-450/3-88-009, 1988/10) 

Applies to automobile refinishing operations. Rule 74.18 – Motor 

Vehicle and Mobile Equipment Coating Operations 

Paper and Fabric, Surface Coating of 

Control of Volatile Organic Emissions from Existing Stationary Sources - Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks (EPA-450/2-77-008, 1977/05) 

For fabric and paper coating, applies to all coatings put 

on paper, fabric, or plastic film, and includes decorative coatings on metal foil such as gift wrap and packaging. 

Rule 74.3 - Paper, Faband Film Coating Operations 

Graphic Arts ACT - Control of Volatile Organic 

Emissions from Existing Stationary Sources, Volume VIII: Graphic Arts - Rotogravure and Flexography (EPA450/2-78-033, 1978/12) 

Applies to graphic arts operations that use the flexographic and rotogravure printing processes as applied to both publication and packaging printing.

Rule 74.19 - Graphic A

Offset Lithography Printing (EPA453/R-94-054, 1994/06) Applies to graphic arts operations that use the offset lithographic printing process. Rule 74.19 - Graphic AOffset Lithographic Printing and Letterpress Printing (EPA-453/R-06-002, 2006/09) 

Applies to graphic arts operations that use the offset lithographic printing or letterpress printing process. 

Rule 74.19 - Graphic A
2014 RACT SIP 

June 10, 2014 Page 8 of 43 Table B-1, Source Categories, CTG/ACT List, and Applicable District Rules (cont’d) 

Source Category Reference Document * Applicability VCAPCD Rule 

For fabric coating, applies to all types of coatings applied 

to fabric and any decorative or protective topcoat applied over vinyl coated fabric or vinyl sheets. Does not apply to the application of vinyl plastisol to the fabric. 

Rule 74.3 - Paper, Faband Film Coating Operations 

For paper coatings, applies to all coatings put on paper, pressure sensitive tapes regardless of substrate (e.g. paper fabric or plastic film), and related web coating 

processes on plastic film such as typewriter ribbons, photographic film, or magnetic tape. Also includesdecorative coatings on metal foil such as gift wrap and packaging. 

Rule 74.3 - Paper, Faband Film Coating Operations 

Metal Furniture, Surface Coating of 

Control of Volatile Organic Emissions from Existing Stationary Sources, Volume III: Surface Coating of Metal Furniture (EPA-450/2-77-032, 1977/12) 

Applies to surface coating of metal furniture by metal furniture manufacturers. 

Rule 74.12 - Surface Coating of Metal Parts and Products 

Metal Furniture Coatings (EPA 453/R-07-005, 2007/09) 

Applies to metal surface coating units at facilities where 

the total actual VOC emissions from all metal furniture coating operations, including cleaning activities, are at least 6.8 kg/day (15 lb/day) of VOC before consideration of controls. 

Rule 74.12 - Surface Coating of Metal Parts and Products 

Metal Parts and Products, Surface Coating of Miscellaneous 

Control of Volatile Organic Emissions from Existing Stationary Sources, Volume VI: Surface Coating of Miscellaneous Metal Parts and Products (EPA-450/2-78-015, 1978/06) 

Applies to industries that are not covered by specific CTG 

documents (Specific CTGs have been published for can, coil, automobile and light duty truck, metal furniture, magnet wire, and large appliances.) 

Rule 74.12 - Surface Coating of Metal Parts and Products 

Miscellaneous Metal and Plastic Parts Coatings (EPA 453/R-08-003, 2008/09) 

Applies to industries that are not covered by specific CTG 

documents where the total actual VOC emissions from all metal and/or plastic parts coating operations, including cleaning activities, are at least 6.8 kg/day (15 lb/day) of VOC before consideration of controls. 

Rule 74.12 - Surface Coating of Metal Parts and Products 

Shipbuilding Shipbuilding and Ship Repair 

Operations (Surface Coating) (61 FR 44050 8/27/96, 1996/08) 

Applies to coatings and solvents used for building or maintaining metal marine or fresh-water metal hulled 

vessels used for military or commercial operations,including self-propelled vessels and those towed by other craft (barges). This definition includes, but is not limited to, all military vessels, commercial cargo and passenger (cruise) ships, ferries, barges, tankers, container ships, patrol and pilot boats, and dredges. 

Rule 74.24 - Marine Coating Operations 
2014 RACT SIP 

June 10, 2014 Page 9 of 43 Table B-1, Source Categories, CTG/ACT List, and Applicable District Rules (cont’d) 

Source Category Reference Document * Applicability VCAPCD Rule 

Rule 74.24.1 – PleasurCraft Coating and Commercial Boatyard Operations 

Surface Coating Operations at Shipbuilding and Ship Repair Facilities (EPA-453/R-94-032, 1994/04) 

Applies to any marine or fresh-water metal hulled vessel used for military or commercial operations, including selfpropelled vessels and those towed by other craft. This 

definition includes, but is not limited to, all military vessels, commercial cargo and passenger ships, ferries, barges, tankers, container ships, patrol and pilot boats, and dredges. Pleasure craft, such as recreational boats and yachts, are not included. 

Rule 74.24 - Marine Coating Operations 

Rule 74.24.1 – PleasurCraft Coating and Commercial Boatyard Operations 

Solvent Metal Cleaning Control of Volatile Organic Emissions 

from Solvent Metal Cleaning (EPA450/2-77-022, 1977/11) 

Applies to cold cleaners, open top vapor degreasers, and 

conveyorized degreasers which use volatile solvents to clean metal parts. 

Rule 74.6 - Surface Cleaning and Degreas

ACT - Halogenated Solvent Cleaners (EPA-450/3-89-030, 1989/08) 

Applies to cleaning machines that use halogenated solvents. 

Rule 74.6.1 - Batch Loaded Vapor Degreasers 

ACT - Industrial Cleaning Solvents, ACT: (EPA-453/R-94-015, 1994/02), CTG: (EPA-453/R-06-001, 2006/09) 

Applies to industrial cleaning with organic solvents. Rule 74.6 - Surface 

Cleaning and DegreasRule 74.6.1 - Batch Loaded Vapor Degreasers 

Traffic Markings Reduction of VOC Emissions from 

the Application of Traffic Markings (EPA-450/3-88-007, 1988/08) 

Applies to application of highway traffic markings. 74.2 – Architectural 

Coatings 

Wood Furniture Manufacturing 

Control of VOC Emissions from Wood Furniture Manufacturing Operations (EPA-453/R-96-007, 1996/04) 

Applies to any facility that finishes wood furniture, or 

performs cleaning or wash-off associated with wood furniture finishing operations. 

Rule 74.30 - Wood Products Coatings 

Petroleum Bulk Gasoline Plants Control of Volatile Organic Emissions 

from Bulk Gasoline Plants (EPA450/2-77-035, 1977/12) 

Applies to bulk plants with daily throughputs of 76,000 liters (20,077 gal.) gasoline or less. 

Rule 70 - Storage and Transfer of Gasoline 
2014 RACT SIP 

June 10, 2014 Page 10 of 43 Table B-1, Source Categories, CTG/ACT List, and Applicable District Rules (cont’d) 

Source Category Reference Document * Applicability VCAPCD Rule 

External Floating Roof Tanks, Petroleum Liquid Storage in 

Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating Roof Tanks (EPA450/2-78-047, 1978/12) 

Applies to external floating roof tanks larger than 150,000 

liters (~40,000 gal. or 950 bbls.) storing petroleum liquids. 

Rule 71.2 - Storage of Reactive Organic Compound Liquids 

Volatile Organic Liquid Storage in Floating and Fixed Roof Tanks (EPA 453/R-94-001, 1994/01) 

Rule 74.26 - Crude Oil Storage Tank DegassiOperations 

Fixed Roof Tanks, Storage of Petroleum Liquids in 

ACT - Control of Volatile Organic Emissions from Storage of Petroleum Liquids in Fixed Roof Tanks (EPA-450/2-77-036, 1977/12) 

Applies to storage vessels with capacities greater than 150,000 liters containing petroleum liquids with a true 

vapor pressure greater than 10.5 KPa. Exempts fixedroof tanks with capacities less than 1,600,000 liters used to store produced crude or condensate prior to lease custody transfer. 

Rule 71.2 - Storage of Reactive Organic Compound Liquids 

Volatile Organic Liquid Storage in Floating and Fixed Roof Tanks (EPA453/R-94-001, 1994/01) 

Applies to storage tanks in all industries, but primarily in 

the petroleum refineries, pipelines, chemical plants, liquid terminals. 

Rule 71.2 - Storage of Reactive Organic Compound Liquids Rule 74.26 - Crude Oil Storage Tank DegassiOperations 

Natural Gas/Gasoline Processing Plants, Equipment Leaks from 

Control of VOC Equipment Leaks from Natural Gas/Gasoline Processing Plants (EPA-450/3-83-007, 1983/12) 

Applies to facilities engaged in the separation of natural gas liquids from field gas and/or fraction of the liquids into 

natural gas products, such as ethane, propane, butane and natural gasoline. It is not applicable to compressor stations, dehydration units, sweetening units, field treatment, underground storage facilities, liquefied natural gas units and field gas gathering systems unless they are located at a gas plant. 

Rule 74.10 - Componeat Crude Oil and NaturGas Production and Processing Facilities 

Gasoline Dispensing Stage II Vapor Recovery 

Stage II Gasoline Dispensing Facilities (EPA-450/3-91-022a, 1991/12) † 

Applies to gasoline dispensing into motor vehicles at gasoline dispensing facilities. 

Rule 70 - Storage and Transfer of Gasoline 

Gasoline Service Stations Design Criteria for Stage I Vapor 

Control Systems - Gasoline Service Stations (EPA-450/R-75-102, 1975/11) 

Applies to filling of gasoline storage tanks from gasoline tanker trucks. 

Rule 70 - Storage and Transfer of Gasoline 

Organic Liquid Storage Volatile Organic Liquid Storage in 

Floating and Fixed Roof Tanks (EPA/453 R-94-001, 1994/01) 

Applies to storage tanks in all industries, but primarily in 

petroleum refineries, pipelines, chemical plants, liquid terminals 

Rule 71.2 - Storage of Reactive Organic Compound Liquids 
2014 RACT SIP 

June 10, 2014 Page 11 of 43 Table B-1, Source Categories, CTG/ACT List, and Applicable District Rules (cont’d) 

Source Category Reference Document * Applicability VCAPCD Rule Petroleum Refinery Equipment, Leaks from 

Control of VOC Leaks from Petroleum Refinery Equipment (EPA-450/2-78-036, 1978/06) 

Applies to leaks from equipment such as pumps, compressors, flanges, valves, and pressure relief devices. 

Rule 74.7 - Fugitive Emissions of Reactive Organic Compounds (ROC) at Petroleum Refineries and ChemicPlants 

Refinery Vacuum Producing Systems, Wastewater Separators, and Process Unit Turnarounds 

Control of Refinery Vacuum Producing Systems, Wastewater Separators, and Process Unit Turnarounds (EPA-450/2-77-025, 1977/10) 

Applies to non-condensables from vacuum producing systems, wastewater separators, and all pressurizedprocess units. 

Rule 74.8 - Refinery Vacuum Producing Systems, Wastewater Separators and ProcesTurnarounds Rule 74.7 - Fugitive Emissions of Reactive Organic Compounds (ROC) at Petroleum Refineries and ChemicPlants 

Synthetic Organic Chemical and Polymer Manufacturing Equipment, Equipment Leaks from 

Control of VOC Fugitive Emissions from Synthetic Organic Chemical Polymer and Resin Manufacturing Equipment (EPA-450/3-83-006, 1984/03) 

Applies to leaks of process fluids (gaseous or liquid) from plant equipment such as pumps, compressors, in-line

process valves, pressure relief devices, open-endedvalves, sampling connections, flanges, agitators, and cooling towers. 

Rule 74.7 – Fugitive Emissions of Reactive Organic Compounds aPetroleum Refineries aChemical Plants 

Tank Trucks, Gasoline Loading Terminals 

Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals (EPA-450/2-77-026, 1977/10) 

Applies to tank truck terminals with daily throughputs greater than 76,000 liters (20,077 gal.). 

Rule 70 - Storage and Transfer of Gasoline 

Tank Trucks, Gasoline, and Vapor Collection Systems 

Control of VOC Leaks from Gasoline Tank Trucks and Vapor Collection Systems (EPA-450/2-78-051, 1978/12) 

Applies to gasoline tank trucks that are equipped with 

vapor collection systems and the vapor collection systems at bulk terminals, bulk plants and service stations. 

Rule 70 - Storage and Transfer of Gasoline 

Stationary Source NOx Electric Utility Boilers NOx Emissions from Utility Boilers 

(EPA-453/R-94-023, 1994/03) 

Applies to electric utility boilers. Rule 59 - Electrical Pow

Generating Equipment Oxides of Nitrogen Oxi
2014 RACT SIP 

June 10, 2014 Page 12 of 43 Table B-1, Source Categories, CTG/ACT List, and Applicable District Rules (cont’d) 

Source Category Reference Document * Applicability VCAPCD Rule 

Industrial Commercial Boilers 

ACT – NOx Emissions from Industrial Commercial & Institutional Boilers (EPA-453/R-94-022, 1994/03) 

Applies to boilers used in industrial facilities. Rule 74.15 - Boilers, 

Steam Generators and Process Heaters 

Rule 74.15.1 - Boilers, Steam Generators, and Process Heaters 

Process Heaters ACT – NOx Emissions from Process 

Heaters (EPA-453/R-93-034, revised 1993/09) 

Applies to direct-fired heaters used primarily in the 

petroleum industry. 

Rule 74.15 - Boilers, Steam Generators and Process Heaters Rule 74.15.1 - Boilers, Steam Generators, and Process Heaters 

Stationary Gas Turbines ACT - NOx Emissions from 

Stationary Combustion Turbines (EPA-453/R-93-007, 1993/01) 

Applies to stationary gas turbines used in various applications and operations. 

Rule 74.23 - Stationary Gas Turbines 

Stationary Reciprocating Internal Combustion (IC) Engines 

ACT - NOx Emissions from Stationary IC Engines (EPA-453/R93-032, 1993/07, updated September 2000) 

Applies to stationary reciprocating internal combustion 

engines. 

Rule 74.9 - Stationary Internal Combustion Engines 

Other Cutback Asphalt Control of VOC from Use of Cutback 

Asphalt (EPA-450/2-77-037, 1977/12) 

Applies to use of cutback asphalt used for roadway paving. 

Rule 74.4 - Cutback Asphalt 

Ethylene Oxide - Sterilization and Aeration 

ACT - Ethylene Oxide Sterilization/Fumigation Operations (EPA-450/3-89-007, 1989/03) 

Applies to ethylene oxide used as a sterilant/fumigant in production of medical equipment supplies, in miscellaneous sterilization and fumigation operations, 

and at hospitals. 

Rule 62.6 - Ethylene Oxide - Sterilization anAeration 

Industrial Adhesives Control Techniques Guidelines for 

Miscellaneous Industrial Adhesives (EPA-453/R-08-005) 

Applies to each miscellaneous industrial adhesive application process at facilities where the total actual VOC emissions from all industrial adhesive operations, 

including cleaning activities, are at least 6.8 kg/day (15 lb/day) of VOC before consideration of controls. 

Rule 74.20 – Adhesiveand Sealants 

Large Petroleum Dry Cleaners 

Control of VOC Emissions from Large Petroleum Dry Cleaners, (EPA-450/3-82-009, 1982/09) 

Applies to petroleum solvent dry cleaning facilities that 

consume 123,000 liters or more of petroleum solvent per year. 

Rule 74.5.1 - Petroleum Solvent Dry Cleaning 

* EPA reference document numbers correspond to EPA Report column in table of Control Measures Guidance Documents found at 

http://www.epa.gov/glo/SIPToolkit/ctg_act/, accessed March 13, 2014 

† Report not listed on web page cited above. Report number taken from actual reference document title page. Document obtained Marc

http://www.epa.gov/airquality/ozonepollution/SIPToolkit/ctg_act/199111_voc_epa450_3-91-022a_stage2_gasoline_dispensing%28v1%2
2014 RACT SIP 

June 10, 2014 Page 13 of 43 Table B-2, CTG/ACT Source Categories for Which There Are No Subject District Sou

Source Category Reference Document * Applicability 

Ventura 

County 

Sources? 

Coatings and Solvents Aerospace Manufacturing and Rework Operations & Coating Operations 

Control of VOC Emissions from Coating Operations at Aerospace Manufacturing and Rework Operations (EPA-453/R-97-004, 1997/12), See also Aerospace MACT (59 FR-29216 6/06/94, 1994/06) 

Applies to aerospace coatings and cleaning solvents use at aerospace manufacturing and rework operations that have the potential to emit greater than or equal to 25 tons per year of VOCs including contractors and subcontractors. 

Yes 

Automobile and Lightduty Trucks, Surface Coating of 

Control of Volatile Organic Emissions from Existing Stationary Sources - Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks (EPA-450/2-77-008, 1977/5), Control 

Techniques Guidelines for Automobile and Light-Duty Truck Assembly Coatings (EPA 453/R-08-006, 2008/09)

For automobile & light truck coating, applies to all objects surface coated in automotive and light duty truck assembly plants. Does not apply to customizers, body shops or other repainters. 

No 

Auto, Transport, Business Machine Plastic Coatings 

ACT – Surface Coating of Automotive/Transportation and Business Machine Plastic Parts, (EPA-453/R-94-017, 1994/02) 

Applies to surface coating of plastics used in motor vehicles and business machines. 

No 

Cans and Coils, Surface Coating of 

Control of Volatile Organic Emissions from Existing Stationary Sources - Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks (EPA-450/2-77-008, 1978/06) 

For cans, applies to sheet basecoat and over varnish, two-piece can exterior basecoat and over varnish, two and three-piece can interior body spray, two-piece can exterior end spray or roll coat, three piece can side seam spray, and end sealing compound. 

No 

For coil coating, applies to prime and topcoat or single coat operation. 

No 

Flat Wood Paneling, Surface Coating of 

Control of Volatile Organic Emissions from Existing Stationary Sources, Volume VII: Factory Surface Coating of Flat Wood Paneling (EPA-450/2-78-032, 1978/06), Control Techniques Guidelines for Flat Wood Paneling Coatings (EPA-453/R-06-004, 2006/09)

Applies to interior paneling made of wood products. No 

Flexible Packaging Printing 

Control Techniques Guidelines for Flexible Packaging Printing (EPA-453/R-06-003, 2006/09) 

Applies to flexible packaging printing operations that emit at least 6.8 kg/day (15 lb/day) of VOC before consideration of controls. 

No 

Ink and Paint Manufacturing 

Control of VOC from Ink and Paint Manufacturing (EPA-450/3-92-013, 1992/04) † 

Applies to products of the paint manufacturing industry, including architectural coatings, product coating for original equipment manufacturers, and special-purpose coatings. Also applies to ink manufacturing, including letterpress inks, lithographic and offset inks, gravure inks, and flexographic inks. 

Yes 
2014 RACT SIP 

June 10, 2014 Page 14 of 43 Table B-2, CTG/ACT Source Categories for Which There Are No Subject District Sou

Source Category Reference Document Applicability 

Ventura 

County 

Sources? 

Large Appliances, Surface Coating of 

Control of Volatile Organic Emissions from Existing Stationary Sources, Volume V: Surface Coating of Large Appliances (EPA450/2-77-034, 1977/12), Control Techniques Guidelines for Large Appliance Coatings (EPA 453/R-07-004, 2007/09) 

Applies to the coating of large appliances, such as doors, cases, lids, panels and interior support parts of residential and commercial washers, dryers, ranges, refrigerators, freezers, water heaters, dishwashers, trash compactors, air conditioners, and similar products. 

No 

Magnet Wire, Surface Coating for Insulation of 

Control of Volatile Organic Emissions from Existing Stationary Sources, Volume IV: Surface Coating for Insulation of Magnet Wire (EPA-450/2-77-033, 1977/12)

Applies to wire coating curing ovens. No 

Metal Furniture Coatings 

Control of Volatile Organic Emissions from Existing Stationary Sources, Volume III: Surface Coating of Metal Furniture (EPA450/2-77-032, 1977/12) 

Applies to surface coating of metal furniture by metal furniture manufacturers. 

No 

Control Techniques Guidelines for Metal Furniture Coatings (EPA 453/R-07-005, 2007/09) 

Applies to metal surface coating units at facilities where the total actual VOC emissions from all metal furniture coating operations, including cleaning activities, are at least 6.8 kg/day (15 lb/day) of VOC before consideration of controls. 

No 

Paper, Film and Foil Coatings 

Control Techniques Guidelines for Paper, Film and Foil Coatings (EPA 453/R-07-003, 2007/09) 

Applies to facilities where the total actual VOC emissions from all paper, film and foil coating operations, including cleaning activities, are at least 6.8 kg/day (15 lb/day) of VOC before consideration of controls. 

No 

PetroleumPetroleum Refineries Control Techniques for VOC Emissions 

from Stationary Sources (EPA-453/R-92-018, 1992/12) 

Applies to petroleum refineries. No 

Control of Refinery Vacuum Producing Systems, Wastewater Separators and Process Unit Turnarounds (EPA 450/2-77-025, 1977/10) 

Applies to metal surface coating units at facilities where the total actual VOC emissions from all metal furniture coating operations, including cleaning activities, are at least 6.8 kg/day (15 lb/day) of VOC before consideration of controls. 

No 

Control of VOC Leaks from Petroleum Refinery Equipment (EPA-450/2-78-036, 1978/06) 

Applies to leaks equipment such as pumps, compressors, flanges, valves, and pressure relief devices. 

No 

Stationary Source NOxCement Manufacturing 

NOx Emissions from Cement Manufacturing (EPA-453/R-94-004, 1994/03, and update EPA-457/R-00-002, 2000/09) 

Applies to the kilns used in cement manufacturing. No 

Glass Manufacturing NOx Emissions from Glass Manufacturing 

(EPA-453/R-94-037, 1994/06)

Applies to glass manufacturing. No 

Iron and Steel NOx Emissions from Iron and Steel (EPA453/R-94-065, 1994/9) Applies to iron and steel manufacturing. No 
2014 RACT SIP 

June 10, 2014 Page 15 of 43 Table B-2, CTG/ACT Source Categories for Which There Are No Subject District Sou

Source Category Reference Document Applicability 

Ventura 

County 

Sources? 

Nitric and Adipic Acid Manufacturing Plants 

NOx Emissions from Nitric and Adipic Acid Manufacturing Plants (EPA-453/3-91-026, 1991/12) 

Applies to nitric and adipic acid manufacturing operations. No 

OtherAgricultural Pesticides Control of VOC from the Application of 

Agricultural Pesticides (EPA-453/R-92-011, 1993/3) 

Applies to pesticides used for agricultural purposes. Yes 

Batch Processes Control of VOC Emissions from Batch 

Processes (EPA-453/R-93-020, 1994/2, a.k.a. EPA-453/R-93-017) 

Applies to plastic materials and resins, pharmaceuticals, gum and wood chemicals, cyclic crudes and intermediates, industrial organic chemicals, and agricultural chemicals. 

Yes 

Commercial Bakeries Bakery Ovens (EPA-453/R-92-017, 1992/12) Applies to commercial bakery operations. Yes Ethylene Oxide - Sterilization and Aeration 

Ethylene Oxide Sterilization (EPA-450/3-89-007, 1989/03) 

Applies to ethylene oxide used as a sterilant/fumigant in production of medical equipment supplies, in miscellaneous sterilization and fumigation operations, and at hospitals. 

Yes 

Fiberglass Boat Manufacturing 

Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials (EPA 453/R-08-004, 2008/09) 

Applies to facilities that manufacture hulls or decks of boats from fiberglass, or build molds to make fiberglass boat hulls or decks, where the total actual VOC emissions from all fiberglass boat manufacturing operations, including cleaning activities, covered by the CTG are at least 6.8 kg/day (15 lb/day) of VOC before consideration of controls. 

No 

Industrial Adhesives Control Techniques Guidelines for 

Miscellaneous Industrial Adhesives (EPA453/R-08-005, 2008/09) 

Applies to each miscellaneous industrial adhesive application 

process at facilities where the total actual VOC emissions from all industrial adhesive operations, including cleaning activities, are at least 6.8 kg/day (15 lb/day) of VOC before consideration of controls. 

Yes 

Industrial Wastewater Industrial Wastewater CTG (Draft) EPA453/D-93-056, 1992/9); ACT (1994/4) Applies to emissions from the collection and treatment of industrial wastewater from: the organic chemicals, plastics, and 

synthetic fibers industry; the pesticides manufacturing industry; the pharmaceuticals manufacturing industry; and the hazardous waste treatment, storage, and disposal facilities industry. 

No 

Leather Tanning and Finishing Operations 

Leather Tanning and Finishing Operations (EPA-453/R-93-025) ‡ 

Applies to leather finishing operations. No 

Organic Waste ACT - Organic Waste Process Vents (EPA450/3-91-007, 1990/12) Applies to process vents including those on waste management units at TSDF treating wastes with total organics concentration of 

less than 10 ppmw and those on treatment units that are part of a waste management system exempt from RCRA permitting. 

No 

Pharmaceutical Products 

Control of Volatile Organic Emissions from Manufacture of Synthesized Pharmaceutical Products (EPA-450/2-78-029, 1978/12)

Applies to facilities and operations that synthesize pharmaceutical products. 

No 
2014 RACT SIP 

June 10, 2014 Page 16 of 43 Table B-2, CTG/ACT Source Categories for Which There Are No Subject District Sou

Source Category Reference Document Applicability 

Ventura 

County 

Sources? 

Plywood Veneer Dryers 

Control Techniques for Organic Emissions from Plywood Veneer Dryers (EPA-450/3-83-012, 1983/05) 

Applies to softwood plywood manufacturing operations. No 

Pneumatic Rubber Tires, Manufacture of 

Control of Volatile Organic Emissions from Manufacture of Pneumatic Rubber Tires (EPA-450/2-78-030, 1978/12) 

Applies to manufacturing processes; undertread cementing, tread-end cementing, bead dipping, and green tire spraying. 

No 

Polyester Resin Control of VOC Emissions from 

Manufacture of High - Density Polyethylene, Polypropylene, and Polystyrene Resins (EPA-450/3-83-008, 1983/11) 

Applies to the manufacturing of high-density polyethylene, polypropylene, and polystyrene. 

No 

Control of VOC Emissions from Synthetic Organic Chemical Polymer and Resin Manufacturing Equipment (EPA-450/3-83-006, 1984/03 

Applies to emissions from equipment used in synthetic organic chemical polymers and resins. 

No 

Control of VOC Emissions from Polystyrene Foam Manufacturing (EPA-450/3-90-020, 1990/09)

Applies to polystyrene foam manufacturing Yes 

Synthetic Organic Chemical Manufacturing 

Control of VOC Emissions from Air Oxidation 

Processes in Synthetic Organic Chemical Manufacturing Industry (EPA-450/3-84-015, 1984/12) 

Applies to air oxidation processes used in the synthetic organic 

chemical manufacturing industry. 

No 

SOCMI Distillation and Reactor Processes (EPA-450/4-91-031, 1983/08) 

Applies to reactor processes that chemically change feed stocks into products or intermediate chemicals and distillation processes used to separate chemicals in the synthetic organic chemical manufacturing industry. 

No 

Petroleum Solvent Dry Cleaners 

Control of VOC Emissions from Large Petroleum Dry Cleaners (EPA-450/3-82-009, 1982/09) 

Applies to petroleum solvent dry cleaning facilities that consume 

123,000 liters or more of petroleum solvent per year. 

No 

* Report Numbers correspond to EPA Report column in table of Control Measures Guidance Documents found at http://www.epa.gov/glo/

March 13, 2014. 

** Not applicable † Report not listed on web page cited above. Report number taken from actual reference document title page. Document obtained Marc

http://www.epa.gov/ttncatc1/dir1/ink_paint.pdf. 

‡ Report not listed on web page cited above. Report number taken from actual reference document title page. Document obtained March 

http://nepis.epa.gov/Exe/ZyNET.exe/2000HJFP.TXT?ZyActionD=ZyDocument&Client=EPA&Index=1991+Thru+1994&Docs=&Query=&T

d=1&TocRestrict=n&Toc=&TocEntry=&QField=&QFieldYear=&QFieldMonth=&QFieldDay=&IntQFieldOp=0&ExtQFieldOp=0&XmlQuery=ata\91thru94\Txt\00000014\2000HJFP.txt&User=ANONYMOUS&Password=anonymous&SortMethod=h|-&MaximumDocuments=1&FuzzyDegree=0&ImageQuality=r75g8/r75g8/x150y150g16/i425&Display=p|f&DefSeekPage=x&SearchBack=ZckDesc=Results%20page&MaximumPages=1&ZyEntry=1&SeekPage=x&ZyPURL 
2014 RACT SIP 

June 10, 2014 Page 17 of 43 Table B-3, Major Sources in Ventura County 

Rules Evaluated that Apply to Ventura County Major Source Facilities

APCD Permit No. Facility Name 59 70 71.1 71.3 71.4 71.5 74.2 74.4 74.6 00004 Vintage Production California LLC          00008 Vintage Production California LLC          00012 Tenby Production Facility          00013 Mandalay Generating Station          00015 Procter & Gamble Paper Products          00036 Trinity ESC - Frazier Park          00041 Aera Energy, LLC          00053 Vintage Production California LLC          00061 Southern California Gas Company          00065 Ormond Beach Gen. Station          00157 New-Indy Oxnard, LLC          00990 Seneca Resources Corporation          01207 Naval Base Ventura County          01492 Platform Gilda          01494 Platform Gail          
2014 RACT SIP 

June 10, 2014 Page 18 of 43 Table B-3, Major Sources in Ventura County (cont’d)

Rules Evaluated that Apply to Ventura County Major Source Facilities

APCD Permit No. Facility Name 74.11.1 74.13 74.15 74.15.1 74.16 74.19 74.22 74.23 74.26 00004 Vintage Production California LLC          00008 Vintage Production LLC          00012 Tenby Production Facility.          00013 Mandalay Generating Station          00015 Procter & Gamble Paper Products          00036 Trinity ESC - Frazier Park          00041 Aera Energy, LLC          00053 Vintage Production California LLC          00061 Southern California Gas Co.          00065 Ormond Beach Generating Station          00157 New-Indy Oxnard, LLC          00990 Seneca Resources Corporation          01207 Naval Base Ventura County          01492 Platform Gilda          01494 Platform Gail          
2014 RACT SIP 

June 10, 2014 

Page 19 of 43 

Table B-4, District Rules Evaluated for 2014 RACT SIP 

VCAPCD 

Rule Rule Name CTG/ACT? 

Date First 

Adopted 

Date Last 

Revised 

EPA 

Approval* 

59

Electrical Power Generating 

Equipment Oxides of Nitrogen 

Emissions Yes 10/6/1969 7/15/1997 7/20/1999

62.6

Ethylene Oxide - Sterilization and 

Aeration Yes 7/16/91 N/A 8/4/1994

63

Separation and Combustion of 

Emissions No 5/3/1972 11/21/1978 5/23/1979

69 Asphalt Air Blowing No 5/23/1972 7/5/1983 4/17/1987

70 Storage and Transfer of Gasoline Yes 6/25/1974 3/10/2009 1/31/2011

71.1

Crude Oil Production and 

Separation No 6/20/1978 6/16/1992 8/4/1994

71.2

Storage of Reactive Organic 

Compound Liquids Yes 6/20/1978 9/26/1989 12/5/1993

71.3

Transfer of Organic Reactive 

Compound Liquids Yes 6/20/1978 6/16/1992 9/7/1995

71.4

Petroleum Sumps, Pits, Ponds, 

and Well Cellars No 10/4/1988 6/8/1993 8/4/1994

71.5 Glycol Dehydrators No 12/13/1994 N/A 2/29/1996

74.2 Architectural Coatings No 6/19/1979 1/12/2010 7/6/2011

74.3

Paper, Fabric and Film Coating 

Operations Yes 5/29/1979 12/10/1991 9/7/1995

74.4 Cutback Asphalt Yes 6/19/1979 7/5/1983 4/17/1987

74.5.1 Petroleum Solvent Dry Cleaning Yes 12/4/1990 N/A 3/24/1992

74.6 Surface Cleaning and Degreasing Yes 5/29/1979 11/11/2003 10/25/2005

74.6.1 Batch Loaded Vapor Degreasers Yes 5/29/1979 11/11/2003 10/25/2005

74.7

Fugitive Emissions of ROC at 

Petroleum Refineries and 

Chemical Plants (VOC) Yes 5/29/1979 10/10/1995 7/25/1996

74.8

Refinery Vacuum Producing 

Systems, Wastewater Separators, 

and Process Turnarounds Yes 6/19/1979 7/5/1983 4/17/1987

74.9

Stationary Internal Combustion 

Engines Yes 7/21/1981 11/8/2005 7/30/2008

74.10

Components at Crude Oil and 

Natural Gas Producing and 

Processing Facilities Yes 9/29/1981 3/10/1998 8/19/1999

74.11

Natural Gas-Fired Residential 

Water Heaters No 4/9/1985 5/11/2010

Submitted 

to EPA †

74.11.1

Large Water Heaters and Small 

Boilers Yes 9/14/1999 9/11/2012

Submitted 

to EPA †

74.12

Surface Coating of Metal Parts 

and Products Yes 11/19/1985 4/8/2008 5/24/2011

74.13

Aerospace Assembly and 

Component Manufacturing 

Operations Yes 4/15/1986 9/11/2012

Submitted 

to EPA †

74.11.1

Large Water Heaters and Small 

Boilers Yes 9/14/1999 9/11/2012

Submitted 

to EPA †
2014 RACT SIP 

June 10, 2014 

Page 20 of 43 

Table B-4, District Rules Evaluated for 2014 RACT SIP (cont’d) 

VCAPCD 

Rule Rule Name CTG/ACT? 

Date First 

Adopted 

Date Last 

Revised 

EPA 

Approval* 

74.11.1

Large Water Heaters and Small 

Boilers Yes 9/14/1999 9/11/2012

Submitted 

to EPA †

74.12

Surface Coating of Metal Parts 

and Products Yes 11/19/1985 4/8/2008 5/24/2011

74.13

Aerospace Assembly and 

Component Manufacturing 

Operations Yes 4/15/1986 9/11/2012

Submitted 

to EPA †

74.14

Polyester Resin Material 

Operations Yes 11/24/1987 4/12/2005 2/1/2006

74.15

Boilers, Steam Generators and 

Process Heaters Yes 3/28/1989 11/8/1994 2/9/1996

74.15.1

Boilers, Steam Generators and 

Process Heaters Yes 5/11/1993 9/11/2012

Submitted 

to EPA †

74.16 Oilfield Drilling Operations No 1/8/1991 N/A 4/20/1999

74.17.1 Municipal Solid Waste Landfills No 3/10/1998 2/9/1999 9/20/2001§

74.18

Motor Vehicle and Mobile 

Equipment Coating Operations Yes 1/28/1992 11/11/2008 9/24/2013

74.19 Graphic Arts Yes 8/11/2002 6/14/2011 9/24/2013

74.19.1 Screen Printing Operations Yes 6/11/1996 11/11/2003 10/25/2005

74.20 Adhesives and Sealants Yes 6/8/1993 9/11/2012 8/30/2013

74.21 Semiconductor Manufacturing No 4/6/1993 N/A 2/29/1996

74.22

Natural Gas-Fired, Central FanType Furnaces No 11/9/1993 N/A 4/30/1996

74.23 Stationary Gas Turbines Yes 3/14/1995 1/8/2002 6/3/2003

74.24 Marine Coatings Operations Yes 3/8/1994 9/11/2012

Submitted 

to EPA †

74.24.1

Pleasure Craft Coating and 

Commercial Boatyard Operations Yes 11/10/1998 1/8/2002 8/13/2002

74.25 Restaurant Cooking Operations No 10/12/2004 N/A 10/25/2005

74.26

Crude Oil Storage Tank 

Degassing No 11/8/1994 N/A 5/6/1996

74.27

Gasoline and ROC Liquid Storage 

Tank Degassing Operations No 11/8/1994 N/A 5/6/1996

74.28 Asphalt Roofing Operations No 5/10/1994 N/A 2/29/1996

74.29 Soil Decontamination Operations No 10/10/1995 4/8/2008 10/3/2011

74.30 Wood Products Coating Yes 5/17/1994 6/27/2006 7/16/2008

74.31

Metalworking Fluids and Direct 

Contact Lubricants No 11/12/2013 N/A

Submitted 

to EPA †

* Date of EPA Federal Register Notice of final approval adding rule to SIP. 

† The most recent revisions of these rules have been submitted to EPA for inclusion in the SIP but EPA has not 

taken final action. 

§ On this date, Federal Register, Vol. 66, No. 183, page 48355 included EPA approval of Rule 74.17.1 as part of 

the California State Plan for controlling existing MSW landfills, as set forth in 40 CFR part 60, subpart Cc. The 

submitted revision to the California 111(d) Plan for controlling MSW landfill gas emissions meets all applicable 

requirements for approval. This rule was also submitted to EPA for inclusion in the SIP but EPA has taken no 

action.
2014 RACT SIP 

June 10, 2014 

Page 21 of 43 

VENTURA COUNTY AIR POLLUTION CONTROL DISTRICT 

2014 RACT ANALYSES 

BACKGROUND 

Sections 182(b)(2) and 182(f) of the federal Clean Air Act (42 U.S.C. §7511a) require that 

ozone nonattainment areas implement reasonably available control technology (RACT) for 

sources that are subject to Control Techniques Guidelines (CTG) issued by EPA and for 

“major sources” of VOC and NOx, which are ozone precursors. RACT is defined 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 53762; September 17, 1979). 

RACT requirements are included in the Clean Air Act to assure that significant emission 

source categories at major sources of ozone precursor emissions are controlled to a 

“reasonable” extent, but not necessarily to the more stringent Best Available Control 

Technology (BACT) or “lowest achievable emission rate” (LAER) levels expected of new or 

modified major stationary sources. 

On June 6, 2013, the EPA issued a proposed rule to address a range of implementation 

requirements for the 2008 National Ambient Air Quality Standards (NAAQS) for ground-level 

ozone. Among those are requirements that State Implementation Plans (SIPs) for ozone 

nonattainment areas provide for RACT. According to the ozone rule, areas classified as 

moderate or higher ozone nonattainment areas must submit revisions to their SIPs 

demonstrating that their current rules fulfill 8-hour ozone RACT for all CTG categories and 

all major, non-CTG sources.

RACT SIPs must contain adopted RACT regulations, certifications where appropriate that 

existing provisions are RACT, and/or negative declarations that there are no sources in the 

nonattainment area covered by a specific CTG source category. States must provide notice 

and opportunity for public comment on their RACT submission even where the state 

determines to certify that the existing provisions remain RACT or where the state submits a 

negative declaration. States must also submit appropriate supporting information for their 

RACT demonstrations. 

RACT demonstrations can be made with either RACT determinations or by certifications that 

previously-required RACT controls represent RACT for the 8-hour ozone standard. 

Alternatively, air agencies in nonattainment areas may adopt “negative declarations” 

documenting that the area has no stationary sources in a CTG source category. 

CTGs define RACT for existing sources of air pollution. Emission sources covered by CTGs 

are known as CTG sources. Some CTGs specify the minimum size of sources to which they 

apply. Where a CTG does not specify the minimum size of the source to which it applies, or 

there is no CTG for a source category, states are required to apply RACT to sources in 

nonattainment areas th2at exceed that area’s statutory major stationary source threshold for its 

ozone nonattainment classification. Therefore, since the Ventura County Air Pollution 

Control District (VCAPCD or “District”) is classified a “serious” ozone nonattainment area, a 
2014 RACT SIP 

June 10, 2014 

Page 22 of 43 

major source is defined as one with the potential to emit greater than 50 tons per year of 

volatile organic compounds (VOC) and/or nitrogen oxides (NOx). 

Documents useful in establishing RACT include CTGs, Alternative Control Techniques 

(ACT) guidance, Maximum Achievable Control Technology (MACT) standards, New 

Source Performance Standards (NSPS), California Suggested Control Measures (SCM) and 

RACT/Best Available Retrofit Control Technology (BARCT) determinations, regulations 

adopted in other Districts, and guidance and rules developed by other state and local 

agencies. 

RACT EVALUATIONS 

Staff evaluated all District VOC2 and/or NOx prohibitory rules that apply to CTG source 

categories and/or major sources of ozone precursors in Ventura County. All rules applicable 

to CTG source categories were determined to meet or exceed the CTG requirements during 

the 2006 and 2009 RACT SIP updates, so the rules were not compared to CTG requirements 

again.3

 However, since some CTGs have not been updated for many years, staff compared 

District rules to rules adopted by other air districts with higher or “worse” nonattainment 

classifications, namely the South Coast Air Quality Management District (SCAQMD) and the 

San Joaquin Valley Air Pollution Control District (SJVAPCD). Staff also included cost 

effectiveness in the evaluations. The summaries below discuss the comparisons and provide 

a determination whether each rule meets RACT as written or if updates are needed. 

RULE 59: ELECTRIC POWER GENERATING EQUIPMENT – OXIDES OF NITROGEN 

EMISSIONS (Last Revised 7/15/1997) 

Rule 59 reduces NOx emissions from electric power generating steam boilers with a rated 

heat input capacity of greater than three hundred (300) million Btu's per hour, and any 

auxiliary boiler with an electric power generating steam boiler not subject to Rule 74.15, 

Boilers, Steam Generators, and Process Heaters. 

Rule 59 has stricter limits than the equivalent Rule 1135 in the South Coast Air Quality 

Management District (SCAQMD), which is designated an “extreme” ozone nonattainment 

area. Although Rule 1135 is still in effect, it could be considered obsolete. SCAQMD now 

uses an emission trading system, called the RECLAIM system, to regulate NOx from 

electrical power generation. The RECLAIM system is difficult to compare directly to the 

emission reductions gained from District Rule 59. Since SCAQMD is an “extreme” 

nonattainment area, their NOx emission limitations would likely be beyond RACT in order to 

achieve attainment in a timely manner. RECLAIM credits regularly trade at values greater 

than $4,000 per ton of NOx, which significantly exceeds the inflation-adjusted RACT 

threshold of approximately $1,990 per ton of NOx emissions reduced. The April 2014, 12-

month rolling average price for one ton of NOx RECLAIM credits was $2,009 (the most 

recent data available). 

 

2

 District rules use the terms reactive organic compounds or ROC to refer to substances the EPA considers VOC. 

3

 Ventura County APCD's 2006 RACT SIP certified that the District's rules met RACT and the 2009 RACT SIP 

Revision certified that the District's rules met EPA's CTGs issued between 2006 and 2008 and re-certified that 

all major non-CTG sources of VOC or NOx were covered by RACT Rules. 
2014 RACT SIP 

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The San Joaquin Valley Air Pollution Control District (SJVAPCD) does not have a rule 

specifically limiting emissions of NOx from electric power generating equipment. The 

SJVAPCD rule that applies to boilers in general, Rule 4306, limits NOx emissions based on 

heat input rather than net power output. Conducting a unit conversion using an average 

efficiency for a steam boiler/turbine power system of 36%4

 shows that the Rule 59 limit of 

0.10 lbs NOx per Megawatt-hour output is equivalent to the SJVAPCD rule standard limit of 

0.011 lb/MMBtu heat input for boilers greater than 20 MMBtu per hour heat input. 

Therefore, Rule 59 meets RACT and no changes to the rule are required at this time. 

RULE 62.6: ETHYLENE OXIDE – STERILIZATION AND AERATION 

(Adopted 7/16/1991) 

Rule 62.6 reduces ethylene oxide emissions from sterilizers using ethylene oxide. The two 

known, permitted facilities that employ ethylene oxide sterilizers in Ventura County have 

permit limitations on usage below the RACT applicability thresholds. One source is 

permitted to consume 150 lbs of ethylene oxide per year and the second source is permitted to 

consume 88 lbs of ethylene oxide per year. Since EPA has not issued a CTG for ethylene 

oxide sterilizers, RACT is required for major sources only. The sources subject to Rule 62.6 

do not exceed the RACT threshold and therefore Rule 62.6 is not required to meet RACT 

requirements. 

RULE 70: STORAGE AND TRANSFER OF GASOLINE (Last Revised 4/1/2009) 

Rule 70 reduces reactive organic compound (ROC) emissions from the storage and transfer of 

gasoline at bulk plants, terminals, and vehicle dispensing facilities (service stations). The 

storage of gasoline in containers with more than 40,000 gallons capacity is also regulated by 

the Rule 71.2, Storage of Reactive Organic Compound Liquids. 

The California Air Resources Board (CARB) sets vapor recovery system standards and is 

responsible for certifying systems to meet those standards. California’s local air districts have 

the primary authority for regulating gasoline dispensing facilities under vapor recovery rules. 

CARB implemented enhanced vapor recovery requirements during the 10 years starting in 

2001. Bay Area Air Quality Management District (BAAQMD) amended its rules applicable 

to gasoline bulk terminals and plants, Rules 8-33 and 8-39, in April of 2009. The revised 

rules include lower emission limits (0.4 lb ROC per 1000 gallons transferred vs. 0.8 lb ROC 

per 1000 gallons transferred in Rule 70). However, the overall cost effectiveness of the 

emission reductions from the BAAQMD rule amendments is $13,200 per ton of ROC 

reductions. This is relatively high to be considered RACT and since the sources in the 

VCAPCD are smaller than those in the BAAQMD, the cost per ton would likely be higher. 

Rule 70 was last updated on March 10, 2009. The March 2009 revision added exemptions 

for fleets using onboard refueling vapor recovery as recommended by EPA. CARB stated in 

correspondence dated July 31, 2009 that they had reviewed the revised Rule 70 and had no 

comments. In addition, EPA published a direct final rule in the Federal Register (Vol. 76, 

No. 20, pages 5277-5280 dated January 31, 2011) that approved revisions to the District 

 

4

 Environmental Protection Agency Combined Heat and Power Partnership Program, “Technology 

Characterization: Steam Turbines”, December 2008, Page 8. Accessed Feb. 18, 2014 at 

http://www.epa.gov/chp/documents/catalog_chptech_steam_turbines.pdf. A lower efficiency would give a less 

conservative conversion, indicating that the Rule 59 limit is stricter than the Rule 4306 limit. 
2014 RACT SIP 

June 10, 2014 

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portion of the SIP that included the latest revisions to Rule 70. No specifications or 

performance standards with effective dates after 2009 have been issued. Therefore Rule 70 

meets RACT and no changes are required at this time. 

RULE 71.1: CRUDE OIL PRODUCTION AND SEPARATION (Last Revised 6/16/1992) 

Rule 71.1 reduces ROC emissions from equipment used in the production, gathering, storage, 

processing, and separation of crude oil and natural gas from any petroleum production permit 

unit prior to custody transfer. 

The SCAQMD has no equivalent provisions similar to the tank battery requirements of Rule 

71.1. However, SCAQMD Rule 1178 regulates tanks greater than 20,000-gallon storage 

capacity at facilities with emissions greater than 20 tons ROC per year. The provisions of 

Rule 71.1 Section B, Requirements – Storage Tanks, are stricter than the requirements of 

Rule 1178. Rule 71.1 requires a vapor recovery system on all tanks not eligible for an 

exemption, where Rule 1178 allows a variety of floating roof configurations not vented to 

vapor recovery. Only tanks storing low volatility liquids and those in temporary service are 

exempt from the vapor recovery requirements in Rule 71.1. The District’s 2006 RACT SIP 

contains additional analysis of Rule 71.1, including demonstration that fewer than 6% of over 

1,000 permitted tanks in the District are exempt from vapor recovery requirements. 

SCAQMD Rule 1148.1 requires 95% control of produced gas that is not recovered whereas 

Rule 71.1 requires only 90% control of reactive organic compound (ROC) emissions for 

produced gas not recovered or flared. SJVAPCD Rule 4623 tailors tank requirements based 

on tank size and vapor pressure of tank constituents, but the strictest requirements allow for 

vapor recovery systems similar to those allowed by Rule 71.1. 

This rule is not associated with a CTG but Ventura County has seven existing major sources 

of ROC subject to Rule 71.1. A review of the permits for these facilities showed that 

produced gas is collected into a fuel system, sales gas system, or flare at each facility. The 

90% control alternative does not apply to any existing source so the requirement has no 

effect, and a properly designed and operated flare will achieve 98% destruction efficiency or 

greater. Any new source would be subject to BACT which would require a greater ROC 

destruction efficiency than required by Rule 71.1. Therefore, Rule 71.1 does not require 

revision to meet RACT. 

RULE 71.2: STORAGE OF REACTIVE ORGANIC COMPOUND LIQUIDS 

(Last Revised 9/26/1989) 

Rule 71.2 reduces ROC emissions from equipment used to store crude oil or ROC liquids 

with a Modified Reid Vapor Pressure (MRVP) greater than 0.5 psia. The rule does not apply 

to any storage equipment subject to Rule 71.1, to any gasoline storage container with a 

capacity equal to or less than 40,000 gallons, or to any other storage container with a capacity 

equal to or less than 5,000 gallons. 

SCAQMD Rules 463 (amended 11/4/2011) and 1178 (amended 4/7/2006) and SJVAPCD 

Rule 4623 (amended 5/19/2005) apply to similar equipment as Rule 71.2. Rule 71.2 includes 

an exemption for tanks <5,000 gallons, while Rule 4623 applies to all tanks >1,100 gallons. 

Rule 463 applies to above-ground tanks >19,815 gal and above-ground gasoline tanks with 

capacities of between 251 and 19,815 gallons. Rule 1178 applies only to tanks at petroleum 
2014 RACT SIP 

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facilities with greater than 20 tons of VOC emissions reported in the year 2000 and to tanks 

with capacities greater than 19,815 gallons. The rules contain many similar provisions and 

requirements for tanks containing volatile organic liquids. The rules all have minor 

differences in the detailed requirements. The provisions for fixed roof tanks are equivalent in 

all of the above-mentioned rules – a pressure-vacuum relief valve or vapor recovery system. 

Most of the differences relate to floating roof tanks. In some cases, the floating roof tank 

requirements in Rule 71.2 are stricter than the other districts’ rules while the other districts’ 

rules have stricter requirements in other details. 

The permitted emissions of the six existing floating roof tanks in Ventura County are less 

than 14 tons ROC per year. Since they are already controlled to previously approved RACT 

levels, incremental cost effectiveness of emission reductions would be excessive. The 

District’s 2006 RACT SIP contains additional analysis of Rule 71.2, including demonstration 

that additional controls on these tanks would not be cost effective. Compliance with the 

existing rule brings emissions from each of the tanks to below the RACT de minimis

threshold of 2.74 tons per year (15 pounds ROC per day). Therefore, the existing tanks 

should be considered de minimis and not subject to RACT in this current review. Rule 71.2 

does not require revision to meet RACT. 

RULE 71.3: TRANSFER OF REACTIVE ORGANIC COMPOUND LIQUIDS 

(Last Revised 6/16/1992) 

Rule 71.3 reduces ROC emissions from equipment used to transfer ROC liquids with a 

MRVP greater than or equal to 0.5 psia. The provisions of this rule do not apply to the 

transfer of gasoline or the transfer of ROC liquids via pipeline. 

SCAQMD Rule 462 (amended 5/14/1999) and SJVAPCD Rule 4624 (amended 12/20/2007) 

apply to similar equipment as Rule 71.3. (Note: Since Rule 71.3 does not apply to the 

transfer of gasoline, the provisions of Rule 462 that apply to gasoline storage and transfer are 

covered under District Rule 70.) Although the vapor destruction efficiency requirements are 

different, all existing sources in Ventura County use vapor recovery systems that capture and 

return 100% of ROC emissions. Therefore, the vapor destruction requirements of this rule 

are irrelevant with respect to RACT. 

The throughput and vapor pressure thresholds for vapor recovery requirements are different 

but designed to capture sources where controls will be cost effective. Rules 462 and 4624 

require vapor recovery and/or disposal at facilities transferring between 4,000 and 20,000 

gallons per day. Rule 71.3 requires vapor recovery for any source that has ever exceeded 

20,000 gallons per day or 150,000 gallons per year. While there might be sources that 

occasionally transfer 4,000 gallons in a day that do not meet the 150,000 gallon annual 

threshold, it is more likely that sources with less than 4,000 gallons of daily throughput will 

get captured by the 150,000-gallon annual threshold. In addition, using an annual threshold 

ensures the annualized cost effectiveness is appropriate. The staff report for the 1990 revision 

of Rule 71.3 shows the addition of the 150,000-gallon threshold captured 20 additional crude 

oil loading facilities. The cost effectiveness at this threshold was between $3,660 and $9,240 

per ton of ROC emissions reduced (in 1990 dollars), depending if the facility used splash 

loading or submerged fill. Rule 71.3 exempts liquids with MRVP below 0.5 psia, while 

Rules 462 and 4624 exempt liquids with true vapor pressure less than 1.5 psia. Therefore, 

Rule 71.3 meets RACT and does not require revision at this time. 
2014 RACT SIP 

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RULE 71.4: PETROLEUM SUMPS, PITS, PONDS AND WELL CELLARS 

(Last Revised 6/8/1993) 

Rule 71.4 reduces ROC emissions from sumps, pits, ponds and well cellars at facilities where 

crude oil or petroleum material is produced, gathered, separated, processed, or stored. 

SCAQMD Rule 1176 (amended 9/13/1996) and SJVAPCD Rule 4402 (amended 12/15/2011) 

apply to similar equipment as District Rule 71.4. 

Rule 71.4 requires covers on allowed sumps that cover 90% of the liquid surface area. The 

SCAQMD and SJVAPCD rules both require covers on sumps that have very limited gaps at 

the edges. Otherwise they must cover the liquid completely and have no open hatches, etc. 

However, Rule 71.4 includes a provision that the cover must not leak, with a leak defined in 

Rule 71 as 10,000 ppm ROC as methane above background. This provision effectively 

restricts ROC-containing liquid exposure to the atmosphere and limits emissions by limiting 

ROC concentrations in exposed air. In addition, Rule 71.4 applies to liquids with 

significantly lower ROC concentrations (5 mg ROC/L vs 35 mg ROC/L for Rule 4402). Rule 

71.4 meets RACT and does not require revision at this time. 

RULE 71.5: GLYCOL DEHYDRATORS (Adopted 12/13/1994)

Rule 71.5 reduces ROC emissions from glycol dehydrators anywhere natural gas is dehydrated. 

SJVAPCD Rule 4408 (adopted 12/19/2002) applies to the same type of equipment as Rule 

71.5. The rules are essentially equivalent, but Rule 71.5 has a lower exemption threshold so 

it applies to all glycol dehydrators in the District. SCAQMD Rule 1148.1 (adopted 3/5/2004) 

has a similar 95% control requirement on systems handling produced gas, but SCAQMD does 

not specifically regulate glycol dehydrators. Since Rule 71.5 is equivalent to the SCAQMD 

and SJVAPCD rules, Rule 71.5 meets RACT and does not require revision at this time. 

RULE 74.2: ARCHITECTURAL COATINGS (Last Revised 1/12/2010) 

Rule 74.2 reduces ROC emissions from architectural coatings and is applicable to any person 

who supplies, sells, offers for sale, or manufactures any architectural coating for use within the 

District, as well as any person who applies or solicits the application of any architectural coating 

within the District. Since EPA has not issued a CTG for architectural coatings, RACT is 

required for major sources only. The sources subject to Rule 74.2 do not exceed the majorsource threshold of 50 tons ROC per year and therefore Rule 74.2 is not required to meet 

RACT requirements. 

RULE 74.3: PAPER, FABRIC AND FILM COATING OPERATIONS 

(Last Revised 12/10/1991) 

Rule 74.3 reduces ROC emissions from any application process involving the coating of 

paper, fabric or film. SCAQMD Rule 1128 (amended 3/8/1996) and SJVAPCD Rule 4607 

(amended 12/18/2008) apply to the same operations as District Rule 74.3. Their provisions 

compare to Rule 74.3 with a few minor differences: 

• Rule 74.3 allows a 90% overall ROC control option, while Rule 1128 allows 85.5% 

overall and Rule 4607 allows 90% overall 
2014 RACT SIP 

June 10, 2014 

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• Rule 74.3 includes a maximum equivalent emission limit of 120 g/L for high ROC 

content coatings vented to a control system, while Rule 1128 does not include 

equivalent restrictions, and Rule 4607 has a less restrictive 265 g/L maximum 

• Rule 74.3 does not include specific ROC limits for plastisol coatings but Rules 1128 

and 4607 limit plastisol to 20 g/L, however the CTG specifically excludes the 

application of vinyl plastisol (see page vi of the CTG document EPA-450/2-77-008) 

• Rule 74.3 does not restrict the application methods for subject operations but Rule 

1128 and Rule 4607 both require transfer efficiencies equivalent to High Volume Low 

Pressure (HVLP) and 65%, respectively 

Upon review of the District sources subject to Rule 74.3, only two sources were identified. 

The sources use high transfer efficiency application methods (roll and dip coating). New 

sources with significant potential emissions will be subject to the New Source Review 

process which will require BACT, including transfer efficiency requirements. Therefore Rule 

74.3 satisfies RACT for all District sources. 

RULE 74.4: CUTBACK ASPHALT (Last Revised 7/5/1983)

Rule 74.4 reduces ROC emissions from application of rapid cure cutback asphalt for highway 

or street paving or maintenance, and applies to any person who manufactures, sells, or offers 

for sale cutback asphalt for such use or application. Rule 74.4 is equivalent to the cutback 

asphalt restrictions in other air districts in California. All reviewed rules prohibit the use of 

cutback asphalts with greater than 0.5% organic compounds with boiling points less than 500 

°F. Some rules, including Rule 74.4, have exemptions for material used at temperatures less 

than 50 °F. This rule continues to satisfy RACT and does not require an update at this time. 

RULE 74.5.1: PETROLEUM SOLVENT DRY CLEANING (Last Revised 12/4/1990) 

Rule 74.5.1 reduces ROC emissions from petroleum solvent dry cleaning operations through 

emission control, filtration equipment, and operating requirements. 

SCAQMD Rule 1102 (amended 11/17/2000) and SJVAPCD Rule 4672 (amended 

12/17/1992) apply to similar equipment as District Rule 74.5.1. Rule 4672 has similar 

emission limits and operational requirements with the addition of a leak inspection and leak 

repair cycle information label requirement. Rule 1102 includes detailed leak check and repair 

requirements with time limits for repairing leaks. The Ventura County rule prohibits 

operating leaking equipment but does not include specific leak check and repair requirements 

or allowances for operating leaking equipment. 

Rule 1102 prohibits operation of transfer machines effective January 1, 2005. District Rule 

74.5.1 does not prohibit transfer machines and a review of District permits indicated one 

transfer machine remains operating in Ventura County. This machine is located in a small 

retail shop and has permitted potential emissions of less than 1.7 tons ROC per year. 

However, CTG (EPA-450/3-82-009 1982/09) only applies to large industrial facilities, i.e., 

those consuming 123,000 liters of solvent per year which is equivalent to emissions of 

approximately 106 tons of ROC per year. 
2014 RACT SIP 

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Any new petroleum solvent dry cleaning operations with significant potential emissions will 

be subject to the New Source Review process, which will require BACT and a prohibition on 

transfer machines. Therefore Rule 74.5.1 meets RACT and does not require an update at this 

time. 

RULE 74.5.2: SYNTHETIC SOLVENT DRY CLEANING (Last Revised 5/9/1995) 

Rule 74.5.2 reduces ROC emissions from synthetic solvent dry cleaning equipment that does 

not use percholorethylene through emission control, filtration equipment, and operating 

requirements. 

SCAQMD Rule 1102 (amended 11/17/2000) applies to any dry cleaning equipment not using 

perchloroethylene solvent. SJVAPCD Rule 4672 applies only to petroleum solvent dry 

cleaning equipment and so is not applicable to the same sources. Rule 1102 includes detailed 

leak check and repair requirements with time limits for repairing leaks. Rule 74.5.2 prohibits 

operating leaking equipment but does not include specific leak check and repair requirements 

or allowances for operating leaking equipment. Rule 1102 prohibits operation of transfer 

machines effective January 1, 2005. District Rule 74.5.2 prohibits installation of transfer 

machines effective December 4, 1990. A review of District permits indicated no transfer 

machines using synthetic solvent remain operating in Ventura County. Therefore Rule 74.5.2 

meets RACT and does not require an update at this time. 

RULE 74.6: SURFACE CLEANING AND DEGREASING (Last Revised 11/11/2003) 

Rule 74.6 reduces ROC emissions from surface cleaning conducted outside of degreasing 

tanks (e.g., hand wipe cleaning, cleaning with handheld spray bottles) or using cold cleaning 

apparatus. 

SCAQMD Rules 1122 and 1171 (both amended 5/1/2009) and SJVAPCD Rules 4662 and 

4663 (both amended 9/20/2007) regulate similar operations. Rule 74.6 limits general solvent 

cleaning operations to solvents with ROC content of 25 g/L or less, with higher limits for 

specific categories such as cleaning electrical and electronic components. Rules 1171, 4662, 

and 4663 have the same limit for general cleaning operations but include significantly lower 

limits on ROC content of solvents used for cleaning in specific categories without venting the 

operation to a control device. All of the rules have similar requirements for control device 

efficiency when using non-compliant solvents, except Rules 4662 and 4663, which require 

controlled emissions to be less than emissions from the operation if compliant solvents were 

used. These rules are all complex with details that vary only slightly between them but no 

other significant differences exist. 

The District’s 2009 RACT SIP submittal included a detailed evaluation of Rule 74.6. 

According to the 2009 evaluation, all of the industrial solvent cleaning operations in Ventura 

County meet CTG control recommendations, or fall within the exclusions outlined in the 

guidelines. For example, the CTG for Industrial Cleaning Solvents (EPA 453/R-06-001 

2006/09) specifically lists cleaning of electrical and electronic components as a suggested 

exclusion due to its exemption under BAAQMD Rule 8-4-116. Therefore, the higher ROC 

content limit in Rule 74.6 for cleaning electronic or electrical apparatus components does not 

affect the RACT determination. The 2009 evaluation concludes VCAPCD rules governing 

industrial solvent cleaning operations meet RACT requirements as recommended by the 
2014 RACT SIP 

June 10, 2014 

Page 29 of 43 

September 2006 CTG for industrial cleaning solvents. Therefore Rule 74.6 meets RACT and 

does not require an update at this time. 

RULE 74.6.1: BATCH LOADED VAPOR DEGREASERS (Last Revised 11/11/2003) 

Rule 74.6.1 reduces ROC emissions from batch loaded vapor degreasers by specifying 

equipment and operating practice requirements. SCAQMD Rule 1122 (amended 5/1/2009) 

and SJVAPCD Rule 4662 (amended 9/20/2007) regulate sources similar sources to those 

regulated by Rule 74.6.1. It should be noted that Rule 74.6.1 does not regulate conveyorized 

vapor degreasers but no equipment of that type is currently permitted in Ventura County. The 

rules are all essentially equivalent, although each has minor details in the requirements that 

the others do not. Therefore Rule 74.6.1 meets RACT and does not require an update at this 

time. 

RULE 74.7: FUGITIVE EMISSIONS OF REACTIVE ORGANIC COMPOUNDS (ROC) 

AT PETROLEUM REFINERIES AND CHEMICAL PLANTS (Last Revised 10/10/1995) 

Rule 74.7 reduces ROC emissions through operational and inspection requirements at 

petroleum refineries and chemical plants. Historically, only one petroleum refinery and only 

a few chemical plants have operated in Ventura County. The petroleum refinery has not 

operated since 1984. Only one facility (Facility #07519) with an SIC code meeting the 

chemical plant definition remains in the county. Facility #07519 is permitted to emit 2.5 tons 

of ROC per year from all facility sources, including but not limited to components subject to 

Rule 74.7. Therefore, Rule 74.7 does not apply to any sources above the RACT threshold of 

2.7 tons ROC per year and Rule 74.7 is not required to meet RACT. 

RULE 74.8: REFINERY VACUUM PRODUCING SYSTEMS, WASTEWATER 

SEPARATORS AND PROCESS TURNAROUNDS (Last Revised 7/5/1983) 

Rule 74.8 reduces ROC emissions from refinery vacuum producing systems, wastewater 

separators, and process turnarounds at petroleum refineries. Historically, only a single 

petroleum refinery operated in the county. The petroleum refinery has not operated since 

1984. Rule 74.8 applies only to petroleum refineries. Therefore, Rule 74.7 does not apply to 

any existing sources in the county and is not required to meet RACT. 

RULE 74.9: STATIONARY INTERNAL COMBUSTION ENGINES 

(Last Revised 11/8/2005) 

Rule 74.9 reduces NOx emissions from stationary spark-ignited or diesel internal combustion 

engines rated at 50 or more horsepower, operated on any gaseous fuel, including liquid 

petroleum gas (LPG), or liquid fuel, and not subject to the provisions of Rule 74.16. 

SCAQMD Rule 1110.2 (amended 9/7/2012) and SJVAPCD Rule 4702 (amended 

11/14/2013) regulate sources similar to those regulated by Rule 74.9. The emission limits in 

Rule 1110.2 are significantly stricter than those in Rule 74.9. The baseline NOx and ROC 

emission limits in Rule 4702 are largely equivalent to Rule 74.9, though stricter emission 

limits are becoming effective on a schedule that allows some facilities to defer full 

compliance until 2017. In addition, Rule 4702 includes a fee option for facilities unwilling to 

comply with the stricter limits. The fees are capped at the Carl Moyer cost effectiveness 

threshold which is currently a weighted cost of $17,380 per ton of combined pollutants 
2014 RACT SIP 

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reduced. Of this amount, approximately 45% is assigned to NOx emissions, meaning the 

Carl Moyer cost effectiveness for NOx is approximately $7,820 per ton. 

Rule 74.9 exempts agricultural (AG) engines and engines used in oilfield drilling operations. 

Oilfield drilling engines are not exempt from the rule requirements of Rules 1110.2 and 4702. 

Moreover, oilfield drilling engines are subject to District Rule 74.16, Oilfield Drilling 

Operations, which requires electrification where economically feasible (see discussion under 

Rule 74.16). AG engines are exempt from Rule 1110.2 only if they are not qualified for 

electrification and they have been replaced with Tier IV engines. Rule 4702 includes separate 

emission limits for spark-ignited AG engines and regulates compression-ignited AG engines 

the same as other compression-ignited engines. Although AG engines are exempt from Rule 

74.9, the District requires registration of AG engines to track compliance with the Air 

Resources Board Air Toxic Control Measure (ATCM) for diesel particulates and documents 

spark ignited engines for emissions inventory purposes. District staff evaluated the AG 

engine inventory and found no major sources of NOx. 

Equipment exempt from Rule 74.9 is covered by other District rules that are RACT 

equivalent or sources with exempt engines do not reach major source thresholds as noted 

above for oilfield and AG engines. The NOx and ROC limits for units subject to Rule 74.9 

are equivalent to Rule 4702 baseline limits and the fee option value exceeds the inflationadjusted RACT NOx threshold of approximately $1,990 per ton. Therefore, Rule 74.9 meets 

RACT and does not require an update at this time. 

RULE 74.10: COMPONENTS AT CRUDE OIL AND NATURAL GAS PRODUCTION 

AND PROCESSING FACILITIES (Last Revised 3/10/1998) 

Rule 74.10 reduces ROC emissions through operational and inspection practices and 

procedures to limit fugitive gas leaks at crude oil and gas production facilities, pipeline 

transfer stations, and natural gas processing facilities. 

SJVAPCD Rule 4409 (amended 4/20/2005) regulates sources similar to those regulated by 

Rule 74.10. Rule 4409 is essentially the same as Rule 74.10, with similar thresholds for leak 

classification and similar time requirements for repairs (74.10 is stricter in some categories 

and 4409 includes an “Extended Repair Period” which makes those categories the same as 

74.10). SCAQMD Rule 1173 also regulates similar sources; however, the vast majority of 

the emission reductions are from the leak reduction requirements in SCAQMD Rule 1173 and 

are focused on refinery leaks. Since there are no refineries in the District, this rule is not 

directly comparable to Rule 74.10. 

Rule 74.10 employs a two-pronged approach to leak emission reductions. First, sources are 

required to employ a Leak, Detection and Repair (LDAR) Program to find and fix leaking 

components. Second, the rule allows District inspectors to issue Notices of Violations when 

leaks exceeding certain thresholds are detected by PID detectors. The ability of District 

inspectors to issue NOVs for leaks found dramatically increases rule compliance and provides 

an incentive for sources to undertake a diligent LDAR program to avoid potential violations. 

Rule 74.10 therefore meets RACT and does not require an update at this time. 
2014 RACT SIP 

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RULE 74.11: NATURAL GAS-FIRED WATER HEATERS (Last Revised 1/12/2010) 

Rule 74.11 reduces NOx emissions from residential water heaters and applies to residential 

water heaters, distributers and installers. The rule’s provisions are essentially the same as 

SCAQMD Rule 1146.2 (amended 5/6/2006) and SJVAPCD Rule 4902 (amended 3/19/2009). 

There is no CTG applicable to the sources covered by Rule 74.11 and there are no known 

major sources of NOx subject to this rule in the District. Therefore Rule 74.11 is not required 

to meet RACT and does not require an update at this time. 

RULE 74.11.1: LARGE WATER HEATERS AND SMALL BOILERS 

(Last Revised 9/11/2012) 

Rule 74.11.1 is a point-of-sale rule that reduces NOx emissions from large water heaters and 

small boilers that are sold, offered for sale, or installed in Ventura County through certain 

requirements and limits. 

SCAQMD Rule 1146.2 (amended 5/5/2006) and SJVAPCD Rule 4308 (amended 

11/14/2013) apply to similar sources as Rule 74.11.1. The provisions of Rule 4308 are 

essentially the same as rule 74.11.1. All three rules have equivalent emission limits as ppm 

NOx in source exhaust, although the rules vary in expression of limits based on heat input or 

heat output. Rule 1146.2 includes additional requirements that require existing sources more 

than fifteen years old be retrofitted or replaced if they do not meet emission limits that were 

effective January 1, 2000. Moreover, since the SCAQMD is classified an “extreme” 

nonattainment area, they must go beyond RACT requirements to meet ozone standards. The 

SJVAPCD rule was amended in late 2013 and does not include provisions applicable to 

existing units. Since Rule 74.11.1 is equivalent to Rule 4308, Rule 74.11.1 meets RACT and 

does not require an update at this time. 

RULE 74.12: SURFACE COATING OF METAL PARTS AND PRODUCTS 

(Last Revised 4/8/2008) 

Rule 74.12 reduces ROC emissions by specifying ROC content limits in coatings used to coat 

metal parts and products and work practice requirements. SCAQMD Rule 1107 (amended 

1/6/2006) and SJVAPCD Rule 4603 (amended 9/17/2009) apply to similar sources as Rule 

74.12. The coating ROC content restrictions are mostly equivalent, with Rule 74.12 

including lower limits on a few specialty coatings. While minor differences in work practice 

requirements and exemptions exist, the differences do not impact the RACT determination. 

The District’s 2009 RACT SIP submittal includes a detailed evaluation of Rule 74.12 and 

includes additional details on how the rule meets the 2008 CTG for this source category. 

Rule 74.12 has equivalent or stricter requirements than Rule 1107 and Rule 4603, so Rule 

74.12 meets RACT and does not require an update at this time. 

RULE 74.13: AEROSPACE ASSEMBLY AND COMPONENT MANUFACTURING 

OPERATIONS (Last Revised 9/11/2012) 

Rule 74.13 reduces ROC emissions from the manufacturing, assembling, coating, masking, 

bonding, paint stripping, and surface cleaning of aerospace components and the clean-up of 

equipment associated with these operations. 
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SCAQMD Rule 1124 (amended 9/21/2001) and SJVAPCD Rule 4605 (amended 6/16/2011) 

apply to sources similar to those subject to Rule 74.13. Rule 74.13 limits the emissions of 

ROC from the application of coatings or adhesives on aerospace components. This rule 

contains limits on the ROC content of coatings, adhesives and cleaners used at aerospace 

component manufacturing operations. The ROC control requirements of this rule are 

equivalent to SCAQMD Rule 1124, Aerospace Assembly and Component Manufacturing 

Operation, with a few variations in limits for specialty coatings or adhesives. In addition, 

Rule 74.13 requirements exceed those of the EPA’s Air Toxic Rule 40 CFR Part 63 Subpart 

GG - National Emission Standards for Aerospace Manufacturing and Rework Facilities, 

dated December 8, 2000. 

The material ROC content limits in Rule 74.13 are equivalent to all corresponding VOC 

content limits in the CTG. District staff determined the CTG includes limits on sixteen 

additional specialty coatings not addressed in Rule 74.13. However, the CTG for aerospace 

manufacturing and rework operations applies to sources in serious nonattainment areas that 

have the potential to emit greater than or equal to 25 tons per year of ROC. There are no 

aerospace manufacturing or rework facilities in the District with permitted ROC emissions 

greater than 25 tons per year ROC. Rule 74.13 applies to sources that emit greater than 200 

pounds ROC in any consecutive twelve-month period. Therefore, Rule 74.13 exceeds RACT 

requirements and no changes are required at this time. 

RULE 74.14: POLYESTER RESIN MATERIAL OPERATIONS (Last Revised 4/12/2005) 

Rule 74.14 reduces ROC emissions from operations that manufacture products from or 

otherwise use polyester resin material. ROC emissions from this manufacturing process are 

controlled by limiting loss rate, monomer ROC content, application technique, or by requiring 

emission control equipment. Limits are also placed on the ROC content of cleaning 

materials. This rule does not apply to sources in a CTG category and there are no major 

sources of NOx or ROC in the District subject to this rule. Therefore, RACT analysis and 

RACT compliance are not required. 

RULE 74.15: BOILERS, STEAM GENERATORS AND PROCESS HEATERS 

(Last Revised 11/18/1994) 

This rule reduces NOx emissions from boilers, steam generators and process heaters used in 

all industrial, institutional and commercial operations, except utility electric power generating 

units and any auxiliary boiler used with a utility electric power generating unit and water 

heaters. 

SCAQMD Rule 1146 (amended 9/5/2008) and SJVAPCD Rule 4320 (amended 10/16/2008) 

apply to sources similar to those subject to Rule 74.15. Rule 74.15 prohibits NOx and CO 

emissions in excess of 40 ppm and 400 ppm, respectively, from all subject sources except 

those meeting a low use exemption. Both Rule 1146 and Rule 4320 include tables of NOx 

limits for different categories of combustion sources. The NOx emission limits range from 5 

ppm for larger units to 25 ppm NOx for units fired on landfill gas. The limits are all 

expressed in ppm NOx on a dry basis and corrected to 3% oxygen, so they are directly 

comparable. 

According to the SCAQMD board materials associated with the adoption of Rule 1146 in 

2008, cost effectiveness estimates range from $10,100 to $24,900 per ton for units complying 
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with the 9 ppm NOx limit (ultralow-NOx burner) and $13,000 to $30,800 per ton for units 

complying with the 5 ppm NOx limit (SCR). For atmospheric boilers, the cost effectiveness 

of complying with the 12 ppm NOx limit is estimated to range from $17,300 to $32,800. 

These cost effectiveness values are far beyond the cost effectiveness guidelines for RACT of 

approximately $1,990 per ton of NOx reduced in inflation-adjusted 2013 dollars. This 

indicates the current cost effectiveness of these technologies exceeds RACT guidelines. 

Since the baseline emission limits and compliance options are similar for all three rules, Rule 

74.15 meets RACT and does not require an update at this time. 

RULE 74.15.1: BOILERS, STEAM GENERATORS AND PROCESS HEATERS 

(Last Revised 9/11/12) 

This rule is a point-of-sale rule that reduces NOx emissions by requiring large water heaters 

and small boilers that are sold, offered for sale, or installed in Ventura County to meet certain 

requirements. 

SCAQMD Rule 1146.1 (amended 9/5/2008) and SJVAPCD Rule 4320 (amended 5/19/2011) 

apply to sources similar to those subject to Rule 74.15.1, combustion sources with maximum 

design heat input less than 5 MMBtu/hr. Rule 74.15.1 prohibits NOx and CO in excess of 

40 ppm and 400 ppm, respectively, from subject sources with annual heat input greater than 

1.8 x 109

 Btu. Both Rule 1146.1 and Rule 4320 include similar limits as baseline limits for 

all subject units not eligible for a low use exemption. All three rules include a compliance 

option for units with total annual fuel use less than 1.8 x 109

 Btu. Such units may comply 

with the rule by performing regular tune ups (twice per year, with different specific 

scheduling requirements) in accordance with rule requirements. 

Rule 1146.1 includes much stricter NOx limits on all subject sources, however the SCAQMD 

staff report associated with the adoption of those limits indicates the cost effectiveness ranges 

from $14,400 to $33,500 per ton of NOx emissions reduced. These cost effectiveness values 

are far beyond the cost effectiveness guidelines for RACT of approximately $1,990 per ton of 

NOx reduced in inflation-adjusted 2013 dollars. Rule 4320 includes similar limits for new 

units only; however they are not effective for many types of sources (schools, refineries, and 

moderate use units) until January 1, 2016. Since the baseline emission limits and compliance 

options are similar for all three rules, Rule 74.15.1 meets RACT and does not require update 

at this time. 

RULE 74.16: OILFIELD DRILLING OPERATIONS (Adopted 1/8/1991) 

Rule 74.16 reduces NOx emissions by requiring oilfield drilling rigs to be powered by electric 

utility grid power. The rule requires the District to grant an exemption from this requirement 

in cases where the cost of bringing grid power to the drilling site makes electric drilling 

economically infeasible. In cases where the District grants such an exemption, Rule 74.16 

requires the diesel engines used in oilfield drilling rigs to meet NOx limits equivalent to 

Tier 1 diesel engines. No oil well drilling rigs currently hold a District Permit to Operate. To 

obtain a Permit to Operate, oil well drilling engines would have to comply with more 

stringent BACT requirements pursuant to Rule 26, New Source Review. By definition, 

BACT for internal combustion engines is at least as stringent as RACT. 

California law adopted after adoption of Rule 74.16 preempts air districts from regulating the 

portable diesel engines used in oilfield drilling rigs if they are registered under the statewide 
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Portable Equipment Registration Program (PERP). As a result, all oil well drilling rigs 

operating in Ventura County have opted to comply with the PERP regulation instead of 

obtaining a District air permit. Therefore, for all practical purposes, the requirements of Rule 

74.16 do not apply and the rule is not necessary to implement RACT at oilfield drilling 

operations. 

RULE 74.17.1: MUNICIPAL SOLID WASTE LANDFILLS (Last Revised 2/9/1999) 

Rule 74.17.1 reduces fugitive ROC emissions from municipal solid waste landfills by means 

of landfill gas collection and control systems. All municipal solid waste landfills in Ventura 

County are subject to either the federal New Source Performance Standard (40 CFR part 60 

subpart WWW) or Rule 74.17.1, as applicable. SCAQMD Rule 1150.1 (amended 4/1/2011) 

and SJVAPCD Rule 4642 (amended 4/16/1998) do not contain more stringent requirements. 

Therefore, Rule 74.17.1 meets RACT and no changes are required at this time. 

RULE 74.18: MOTOR VEHICLE AND MOBILE EQUIPMENT COATING OPERATIONS 

(Last Revised 11/11/2008) 

Rule 74.18 limits ROC emissions from the application of automotive refinish coatings. This 

rule contains limits on the ROC content of refinish coatings used to coat both repaired auto 

bodies and entire vehicles, and contains ROC content limits on cleaners used for surface 

preparation and application equipment cleanup. 

The California Air Resources Board amended the statewide Suggested Control Measure 

(SCM) for Automotive Coatings on October 20, 2005. On November 11, 2008, the District 

adopted the SCM. The vast majority of the emission reductions from this SCM results from 

auto body shops switching from solvent-based color base coats to new waterborne color base 

coats. Other provisions of the SCM and Rule 74.18 include new ROC limits of primer 

sealers, specialty coatings, and cleaning solvents used for cleaning application equipment. 

Therefore, Rule 74.18 meets RACT and no changes are required at this time. 

RULE 74.19: GRAPHIC ARTS (Last Revised 6/14/2011) 

Rule 74.19 reduces ROC emissions from the use of inks, fountain solutions, coatings, 

adhesives, and cleaners used at graphic arts operations through limits on the ROC content of 

inks, coating, adhesives, fountain solutions, and solvent cleaners. The District’s 2009 RACT 

SIP submittal includes a detailed evaluation of Rule 74.19 and includes additional details on 

how the rule meets the 2006 CTG for this source category. On June 14, 2011, the District 

adopted new lower ROC content limits in Rule 74.19 for some fountain solutions and 

cleaning solutions used in this source category. The new limits are equivalent to or stricter 

than limits in SCAQMD Rule 1130 (amended 10/8/1999), SJVAPCD Rule 4607 (amended 

12/18/2008) and, for the solvent cleaning aspects of the rule, SCAQMD Rule 1171 (amended 

5/1/2009). The requirements of Rule 74.19 meet RACT and no further changes are required. 

RULE 74.19.1: SCREEN PRINTING OPERATIONS (Last Revised 11/11/2003) 

Rule 74.19.1 reduces ROC emissions from the use of inks, coatings, adhesives, and cleaners 

used at screen printing operations. The rule specifies limits on the ROC content of inks, 

coating, adhesives and fountain solutions, whereas ROC emissions from cleaning solvents are 

limited by ROC content and ROC composite vapor pressure requirements. There is no CTG 
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for this source category and there are no major sources in Ventura County. Therefore, RACT 

analysis and RACT compliance for this rule are unnecessary. 

RULE 74.20: ADHESIVES AND SEALANTS (Last Revised 9/11/2012) 

Rule 74.20 reduces ROC emissions from the use of adhesives, sealants, adhesive primers, 

sealant primers and cleaning solvents used at bonding operations. Rule requirements limit 

ROC emissions by limiting the ROC content of adhesives, sealants, primers, and cleaners. 

The ROC control requirements of this rule are equivalent to SCAQMD Rule 1168 (amended 

1/7/2005) and SJVAPCD Rule 4653 (Amended 9/16/2010) with some minor differences. For 

example, the SCAQMD and SJVAPCD rules list a number of different or additional 

categories of adhesives, sealants and primers with limits in the range of 500 to 850 g/L. 

Those materials would be subject to the general limit of 250 g/L in Rule 74.20. The 

SCAQMD and SJVAPCD rules include stricter limits on a few material categories, however 

the differences are minor, such as ABS welding limits of 400 g/L in Rule 74.20 vs 325 g/L in 

the other rules or Plastic Welding Primer limits of 650 g/L in Rule 74.20 vs 550 g/L in Rule 

1168. Rule 74.20 allows the use of non-compliant materials if the source uses add-on 

controls with overall removal efficiency of 85%, which is equivalent to or stricter than the 

control requirement for Rule 1168 (80% overall control) and Rule 4653 (85% overall 

control). 

There are no major sources in this source category in Ventura County. The District’s 2009 

RACT SIP submittal includes a detailed evaluation of Rule 74.20 and demonstrates that all 

sources in the District using industrial adhesives have emissions below the CTG applicability 

threshold of 15 pounds ROC per day or 2.74 tons ROC per year. Any sources that were 

constructed in the District after that analysis would be subject to new source review and 

BACT requirements, which are stricter than RACT by definition. Therefore, RACT analysis 

and RACT compliance for this rule are unnecessary. 

RULE 74.21: SEMICONDUCTOR MANUFACTURING (Adopted 4/6/1993) 

Rule 74.21 reduces ROC emissions from semiconductor manufacturing operations through 

various operational requirements and solvent concentration limits. This rule does not apply to 

sources in a CTG category and there are no major sources of ROC in Ventura County subject 

to this rule. Therefore, RACT analysis and RACT compliance for this rule are unnecessary. 

RULE 74.22: NATURAL GAS-FIRED, FAN TYPE CENTRAL FURNACES 

(Adopted 11/9/1993) 

Rule 74.22 reduces ROC emissions by prohibiting the sale and installation of forced air space 

heaters that do not meet specified NOx limits. There is no CTG for this equipment and there 

are no major sources in Ventura County. Therefore, RACT analysis and RACT compliance 

for this rule are unnecessary. 

RULE 74.23: STATIONARY GAS TURBINES (Last Revised 1/8/2002) 

Rule 74.23 reduces NOx emissions from stationary turbines with rated output greater than 0.3 

MW fueled with gaseous or liquid fuels. This applicability limit is the same as SCAQMD 

Rule 1134 (amended 8/8/1997) and SJVAPCD Rule 4703 (amended 9/20/2007). There are 
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18 existing turbines in the District subject to Rule 74.23. Half of the existing turbines are 

exempt based on a limit of less than 200 annual hours of operation. Eight (8) of the 

remaining turbines are limited by air permit conditions to BACT emission levels. The final 

remaining unit has a specific permit limit due to its configuration and inability to costeffectively install add-on controls such as selective catalytic reduction. This unit is required 

to use water injection, and the facility agreed to over control the other, larger turbine on site 

to achieve additional NOx reductions beyond RACT on average. Since all other existing 

units subject to Rule 74.23 are controlled at BACT levels and any new sources would be 

required to install BACT emission controls, Rule 74.23 meets RACT and no update is 

required at this time. 

RULE 74.24: MARINE COATING OPERATIONS (Last Revised 9/11/2012) 

Rule 74.24 reduces ROC emissions from coating and cleaning solvents used to coat marine or 

fresh water vessels, excluding boatyard repair facilities and marinas. Rule requirements limit 

ROC emissions by limiting the ROC content of topcoats and primers. Emissions of ROC 

from cleaners are also controlled by limiting the ROC content of surface prep cleaners and 

application equipment cleaners. 

The ROC control requirements of this rule are equivalent to South Coast AQMD Rule 1106 

(amended 1/13/1995) with some minor differences. Rule 74.24 also meets the requirements 

for the 1996 CTG for Ship Building and Ship Repair Operations. This rule therefore meets 

RACT and no update is needed at this time. 

RULE 74.24.1: PLEASURE CRAFT COATING AND COMMERCIAL BOATYARD 

OPERATIONS (Last Revised 1/8/2002) 

Rule 74.24.1 reduces ROC emissions from the use of coatings and cleaning solvents used to 

coat marine or fresh water vessels at commercial boatyard repair facilities and marinas. This 

rule also contains a sales prohibition for noncomplying coatings sold at marine stores that sell 

pleasure craft coatings. Rule requirements limit ROC emissions through ROC content limits 

on topcoats and primers. Emissions of ROC from cleaners are also controlled by limits on 

the ROC content of surface prep cleaners, the ROC composite vapor pressure of cleaning 

solvents, and requiring the use of enclosed spray gun washers. Also, this rule requires use of 

high transfer efficiency spray equipment such as HVLP spray equipment. 

The ROC control requirements of this rule are equivalent to South Coast AQMD Rule 1106.1 

(amended 2/12/1999) with some minor differences. Some of the operations subject to this 

rule are included in the 2008 CTG for Miscellaneous Metal and Plastic Parts Coatings, and 

one or two sources in Ventura County exceed the CTG applicability threshold. The number 

of sources subject to the CTG is unclear since the sources in question also coat pleasure craft 

hulls and/or topside structures made of wood so emissions from those operations are not 

subject to the CTG. 

Staff analysis of Rule 74.24.1 identified several coating types, antifoulant coatings and certain 

high gloss topcoats, where the Rule 74.24.1 maximum ROC content exceeds the maximum in 
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CTG Table 5. However, EPA acknowledged in a June 1, 2010 memorandum5 that the ROC 

content limits in the CTG might be unacceptable to the regulated industry and states have 

flexibility in determining RACT. In discussions with EPA Region 9 staff about the RACT 

determination for this rule, Region 9 staff indicated they believed coatings meeting the CTG 

limits are now readily available and strongly recommended revising Rule 74.24.1 to meet the 

CTG limits to ensure the rule meets RACT for the 2008 ozone NAAQS. 

District staff examined inspection reports for the pleasure craft coating operations potentially 

subject to the CTG in the District. The inspection reports listed the coatings on site at the 

facilities and the ROC content of the coatings. The inspection reports indicated both of the 

facilities currently use a mix of antifoulant coatings and one facility uses a mix of gloss 

topcoat coatings, some compliant with the CTG limits and some not compliant with the CTG 

limits. 

For the antifoulant coatings on aluminum substrates, District staff believes the limit of 580 

grams ROC per liter of coating less water and exempt compounds (hereafter referred to 

merely as g/L) is a typographical error from the original adoption of the rule. The CTG limit 

for this coating category is 560 g/L and it would be difficult to consistently discern the 

difference between coatings with these two VOC contents using EPA Test Method 24. 

For antifoulant coatings on other substrates, the CTG limit is 330 g/L and the Rule 74.24.1 

limit is 400 g/L. One boatyard in the district used six different antifoulant coatings and all 

were compliant with the CTG limit according to the labels on the containers. The other, 

larger boatyard used five different antifoulant coatings, three of which were compliant with 

the CTG limit and two of which were compliant only with the Rule 74.24.1 limit. Staff 

contacted the boatyard operator that uses the high-ROC antifoulant coatings. He stated the 

higher solvent coatings are ablative coatings and such coatings that comply with the 330 g/L 

limit are not available. If the District lowers the limit, he believes the commercial boat 

operators that use the ablative coatings would take their boats elsewhere to avoid the 

additional cost to strip the ablative coating and apply a compliant hard antifoulant. The 

additional labor would add up to $20,000 to the cost of recoating the boat. In addition, the 

ablative antifoulant coatings are self-polishing, resulting in a smoother hull for the boat and 

therefore reduced fuel use. 

Topcoats are classified differently in the Rule 74.24.1 and the CTG. Rule 74.24.1 includes 

separate ROC content limits for one-component topcoats (490 g/L) and two component 

topcoats (650 g/L). The CTG includes separate limits for high gloss topcoats (420 g/L, high 

gloss defined as ≥ 85% reflectance at 60°) and extreme high gloss topcoats (490 g/L, extreme 

high gloss defined as ≥ 95% reflectance at 60°). While the limits and classifications are not 

directly comparable, it is apparent the Rule 74.24.1 limits allow higher ROC content than the 

CTG in many coatings.Only one facility above the CTG threshold in Ventura County applies 

topcoats as defined in the CTG. The list of topcoats used at the facility includes six coatings, 

all of which meet the CTG limit for high gloss coatings except one. The non-compliant 

 

5

 Control Technique Guidelines for Miscellaneous Metal and Plastic Part Coatings Industry Request for 

Reconsideration, United States Environmental Protection Agency, Stephen D. Page, Director, Office of Air 

Quality Planning and Standards, June 1, 2010, http://www.noticeandcomment.com/EPA-Memo-ControlTechnique-Guidelines-for-Miscellaneous-Metal-and-Plastic-Part-Coatings-Industry-Request-fn-38627.aspx
2014 RACT SIP 

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coating is Awlgrip Topcoat, a two-component extreme high gloss linear polyester 

polyurethane coating with 650 g/L ROC content. This is a high-quality coating popular with 

pleasure craft owners due to its extreme high gloss, durability and long life. Based on 

discussion with knowledgeable staff, the Awlgrip Topcoat is a primary reason the District 

raised the ROC limit for two-component topcoats in 2002. At that time, no coatings were 

available with equivalent application and finish properties with ROC content compliant with 

the CTG limits. 

Staff conducted research to determine if coatings are available to meet the CTG ROC limits 

and satisfy the demand for the qualities of the Awlgrip Topcoat. SCAQMD staff indicated 

they have no knowledge of problems with compliance with the limits in Rule 1106.1 

(equivalent to the CTG limits). No variances have been requested in recent years. Staff 

conducted interviews with boatyard staff in Ventura County, San Diego County, and the 

jurisdiction of SCAQMD. The shipyards in SCAQMD jurisdiction indicated they used 

compliant coatings only, but could not compare the performance directly with the Awlgrip 

Topcoat since it is illegal at their area. Staff at a San Diego boatyard stated the majority of 

their topcoat jobs use Awlgrip Topcoat or a competing product from Sterling Lacquer 

Manufacturing (no ROC content information available). He said Alexseal Premium Topcoat 

501 is also competitive and has lower ROC content (590 g/L), however this is still not 

compliant with the CTG limits. He also stated Awlgrip provides very good technical support 

for their products. 

Staff interviewed the Ventura County boatyard operator that uses the Awlgrip Topcoat. He 

stated the boatyard uses relatively small amounts of topcoat, approximately 400 gallons per 

year, and approximately half of that is the Awlgrip Topcoat on pleasure craft. He stated the 

most-used paint for commercial boats is DuPont Imron 2.1 HG, which is compliant with all 

limits at 315 g/L ROC content. However, he believes no yacht-quality high solids coating is 

available. When the District adopted the original Rule 74.24.1 in 1999, the boatyard switched 

to the high solids topcoat Awlgrip developed for the Southern California market. He stated 

the coating was very difficult to apply properly and it dried slowly, resulting in failure to 

achieve acceptable results. Failure often occurred due to dew formation on uncured coating 

which disrupted the gloss. This caused re-application of the coating, up to four times in some 

cases. The increase in coating applications resulted in increased emissions due to additional 

coating use. 

The Ventura County boatyard operator stated that all yacht customers request Awlgrip 

Topcoat. He said many yacht owners bring their boats to Ventura from Alaska, Washington 

and San Francisco to take advantage of the ability to paint their yachts in the winter. If the 

District prohibits the use of the Awlgrip Topcoat by lowering the ROC limit in Rule 74.24.1, 

he believes the yacht owners will take their business elsewhere (such as Santa Barbara or San 

Diego). He stated his business has grown due to the ability to provide the service demanded 

by his clients. The commercial operators demand ablative antifoulant coatings and the yacht 

owners demand Awlgrip Topcoat. He expressed great concern that his business will be 

negatively impacted if the limits are lowered. 

Staff reviewed online forums for yacht and sailing enthusiasts to determine if the Awlgrip 

Topcoat enjoyed a reputation above and beyond the competition, indicating feasible 

compliant coatings do not exist. While the forums do not include VOC content data, it was 

evident that several topcoat systems are available and each has defenders and detractors. 
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Awlgrip topcoats are very popular, but competing products include Alexseal, Sterling, 

DuPont Imron, and International Perfection paint systems. The Awlgrip website lists a 

product (Awlgrip HS Topcoat) that claims similar performance to the two-component linear 

polyurethane Awlgrip Topcoat. Awlgrip HS Topcoat is a three-component system with the 

mixed coating VOC content of 420 g/L which is compliant with the CTG limit. However, the 

online forums have little to no information on the performance and usability of the Awlgrip 

HS Topcoat indicating this product has not generated a significant reputation within the 

pleasure craft community. 

Staff discovered a single water-based linear polyurethane topcoat, System Three WR-LPU 

Linear Polyurethane Topcoat. The Material Safety Data Sheet for this coating lists an ROC 

content of 105-120 g/L for the polyurethane dispersion and 370 g/L for the crosslinker (a 

small fraction of the overall volume when combined with the polyurethane dispersion). 

However, this coating system does not qualify as a high gloss or extreme high gloss topcoat, 

so it is not comparable with the solvent-based topcoats discussed elsewhere in this analysis. 

Staff concluded from this research that the extreme high gloss linear polyester polyurethane 

coatings on the market are not compliant with the CTG VOC limits. These coatings enjoy a 

strong positive reputation in the pleasure craft community with a reputation for superior 

appearance, durability and service life. The competing aliphatic polyurethane topcoat 

products from DuPont and International Paint Company have a different chemistry which 

yields lower performance on original gloss, gloss retention, and durability (resistance to 

damage such as scuffs, scratches and chips). 

Staff contacted a representative of Awlgrip and asked about a compliant version of the linear 

polyurethane Awlgrip Topcoat G/H. He stated the development of a lower VOC linear 

polyester polyurethane topcoat suitable for spray application was ongoing. He stated the 

current Awlgrip Topcoat G/H is compliant with the 490 g/L limit when mixed for hand 

application (brush or roll) due to the lower VOC content of the activator component used for 

hand application process. However, the coating mixed for spray application remains noncompliant. The other linear polyester polyurethane topcoats on the market also exceed the 

CTG ROC content limits. Therefore, there is justification for retaining the 650 g/L VOC 

limit on two component topcoats currently in Rule 74.24.1. 

Rule 74.24.1 achieves greater emission reductions than would occur if the District adopted 

the CTG limits alone. The CTG, with its applicability threshold of 2.7 tons ROC per year, 

applies only to one or possibly two sources in Ventura County with permitted (controlled) 

annual ROC emissions totaling up to 15.5 tons. Rule 74.24.1 applies to two or three 

additional sources with permitted (controlled) emissions totaling up to 6.6 tons ROC per year 

due to the rule’s lower applicability threshold (200 lb/year vs 2.7 tons per year for the CTG). 

The CTG states on page 40 the recommendations in the CTG will reduce emissions by 

approximately 35%. Therefore, the expanded applicability of Rule 74.24.1 generates 

emission reductions of approximately 3.6 tons ROC per year. 

In addition, Rule 74.24.1 applies to coatings applied to pleasure craft parts and structures 

made of wood. Since the permitted facilities are not required to track the amount of coatings 

used on wood substrates, it is difficult to determine the impact of this aspect of the rule. Rule 

74.24.1 includes a sales prohibition to reduce emissions from non-permitted users of pleasure 

craft coatings (e.g. individual hobbyists), a source also not subject to the CTG requirements. 
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According to a 1992 survey used in the development of the rule, approximately 19% of total 

marine coatings sold in Ventura County were sold retail and not applied by permitted sources. 

Since the total controlled permitted inventory is 18.9 tons ROC per year, the controlled nonpermitted inventory should be approximately 4.4 tons ROC per year. Again using the 35% 

control estimate from the CTG, Rule 74.24.1 reduces ROC emissions a further 2.4 tons per 

year. 

The more comprehensive coating ROC restrictions in Rule 74.24.1 reduce ROC emissions at 

least 6 tons per year beyond the reductions that would be achieved by adopting the CTG 

guidelines alone. This indicates the Rule 74.24.1 ROC limits on pleasure craft coatings are 

more comprehensive and more effective at reducing emissions than the baseline 

recommendation in the CTG. 

Rule 74.24.1 was originally adopted in November 1998 with the same ROC content limits 

(with the exception of the aluminum substrate antifoulant coatings) that were later included in 

the CTG. Due to feedback from the regulated community, the District revised Rule 74.24.1 

in January 2002. The amendments included the current ROC limits on topcoats and 

antifoulant coatings along with new restrictions on spray gun cleaning operations and 

cleaning solvent vapor pressure to offset the increase in emissions from the relaxed ROC 

content limits. According to the January 8, 2002 Staff Report, the ROC emissions were 

expected to increase by 900 pounds per year due to the relaxation of ROC limits on twocomponent topcoats and antifoulant coatings. However, this increase was offset by a 

reduction of ROC emissions of 1,900 pounds due to the new restrictions on spray gun 

cleaning and solvent vapor pressure. Therefore, the current requirements of Rule 74.24.1 

reduce emissions by an addition 0.5 tons per year of ROC beyond the baseline CTG 

requirements. 

On August 13, 2002, EPA published a direct final rule in the Federal Register6

 approving 

revisions to the California SIP, including District Rule 74.24.1 as amended in January 2002. 

In the discussion of the SIP revisions, the Federal Register notice states “To conclude, the 

submitted Rule 74.24.1 does not interfere with reasonable further progress or attainment. The 

net effect of amendments to the rule is to reduce ROC emissions.” 

The Federal Register notice refers to the April 2002 EPA Technical Support Document7

(TSD) prepared for the notice of direct final rulemaking. The TSD notes that EPA had not, at 

that time, produced a CTG for pleasure craft coating and commercial boatyard operations. 

Therefore, District Rule 74.24.1, along with SCAQMD Rule 1106.1 and San Diego County 

Air Pollution Control District Rule 67.18 provided a preliminary definition of RACT. The 

TSD includes no recommendations for revisions and finds no deficiencies in Rule 74.24.1. 

Although this EPA action occurred prior to the publication of the CTG update with pleasure 

craft coating guidelines, the ROC limits referenced in the CTG are taken directly from 

SCAQMD Rule 1106.1 cited above. In addition, the CTG refers to the 2002 version of Rule 

 

6

 “Revisions to the California State Implementation Plan, South Coast Air Quality Management District, Ventura 

County Air Pollution Control District; Direct final rule,” 67 Federal Register 156 (13 August 2002), pp. 52611 - 

52615. 

7

 J. S. Wamsley, Technical Support Document for EPA’s Notice of Direct Final Rulemaking, USEPA Region IX 

Air Division, April 2002. Accessed May 6, 2014. Link to TSD available at 

http://yosemite.epa.gov/R9/r9sips.nsf/AgencyProvision/8243BA552E89656088256C17007BDE31?OpenDocum

ent 
2014 RACT SIP 

June 10, 2014 

Page 41 of 43 

74.24.1 as one of the three California districts with pleasure craft coating rules. Although the 

SCAQMD rule was noted as the strictest, the CTG does not indicate EPA believed Rule 

74.24.1 did not satisfy RACT. 

As stated in its introduction, the CTG provides recommendations for state and local air 

pollution control agencies to consider in determining RACT. Rule 74.24.1 applies to a 

broader category of source operations than the pleasure craft coating operations covered by 

the CTG, has a lower applicability threshold, and includes a sales prohibition to reduce 

emissions from non-permitted users of pleasure craft coatings (e.g. individual hobbyists). In 

addition, during the 2002 rule revisions spray gun cleaning operation and solvent vapor 

pressure requirements were added to offset the increase in emissions from the higher coating 

ROC content limits requested by affected sources. Combined, these extra requirements 

increase the ROC reductions by 65% over the reductions expected by implementing the CTG 

requirements even considering the higher ROC limits for the topcoat and antifouling coatings. 

Therefore, the District considers Rule 74.24.1 RACT as written and no updates are required 

at this time. 

RULE 74.25: RESTAURANT COOKING OPERATIONS (Adopted 10/12/2004) 

Rule 74.25 reduces ROC and particulate matter emissions from conveyorized charbroilers. 

There is no CTG for this equipment and there are no major sources in Ventura County. 

Therefore, RACT analysis and RACT compliance for this rule are unnecessary. 

RULE 74.26: CRUDE OIL STORAGE TANK DEGASSING OPERATIONS 

(Adopted 11/8 1994) 

Rule 74.26 reduces ROC emissions by prohibiting the venting of ROC vapors to the 

atmosphere from above-ground tanks used to store crude oil or produced water. When such 

tanks are undergoing maintenance or being decommissioned, the rule requires ROC vapors to 

be treated rather than released to the air. 

Rule 74.26 was evaluated by the District in 2004 in an “All Feasible Measures” (AFM) 

analysis conducted pursuant to California Health and Safety Code Section 40914. This 

review was cited in the District’s 2006 RACT SIP as approved by EPA. The conclusions of 

the 2004 AFM analysis remain valid. SCAQMD Rule 1149 (amended 5/2/2008) has a lower 

threshold of ROC for degassed tanks, 5,000 ppmv versus 10,000 ppmv for Rule 74.26. 

However, the 2004 AFM analysis states the incremental cost to control emissions from 

10,000 ppmv to 5,000 ppmv would be excessive due to the large amount of time and dilution 

air needed to reduce the concentration a further 50%. SCAQMD was able to justify the lower 

limit due to the much more lax conditions of Rule 1149 prior to its amendment and a cost 

effectiveness threshold of $13,159 per ton of ROC reduced, much higher than what would be 

considered for RACT in Ventura County. 

SCAQMD also lowered the tank size applicability thresholds for Rule 1149 in its 2008 

revision. The District’s 2004 AFM analysis also addressed the tank size applicability 

threshold cost effectiveness for Rule 74.26. Assuming a ROC vapor density of 0.004 

lb/gallon of tank volume and a control efficiency of 95%, the cost effectiveness to control 

degassing of a 500-bbl tank ranges from $18-$25 per pound of ROC reduced (equivalent to 

$36,000 - $50,000 per ton). Smaller tanks, such as the 500-gallon level regulated by Rule 
2014 RACT SIP 

June 10, 2014 

Page 42 of 43 

1149, would have worse cost effectiveness due to the fixed costs of tank degassing operations 

increasing relative to tank size. Due to the high cost of reducing the tank size and/or ROC 

concentration thresholds, Rule 74.26 meets RACT and no update is necessary at this time. 

RULE 74.27: GASOLINE AND ROC LIQUID STORAGE TANK DEGASSING 

OPERATIONS (Adopted 11/8 1994) 

Rule 74.27 reduces ROC emissions by prohibiting the venting of ROC vapors to the 

atmosphere from any gasoline storage tank that has a storage capacity greater than 5,000 

gallons and any storage tank that has a storage capacity greater than 5,000 gallons that stores 

ROC liquids, excluding petroleum liquids, having a true vapor pressure equal to or greater 

than that determined by: TVP @ 68 °F (psia) = 2.3 + 23,000/V, where V is the volume of the 

tank in gallons. When such tanks are undergoing maintenance or being decommissioned, the 

rule requires ROC vapors to be treated rather than released to the air. 

Rule 74.27 was evaluated by the District in 2004 in an “All Feasible Measures” (AFM) 

analysis conducted pursuant to California Health and Safety Code Section 40914. This 

review was cited in the District’s 2006 RACT SIP as approved by EPA. The conclusions of 

the 2004 AFM analysis remain valid. SCAQMD Rule 1149 (amended 5/2/2008) has a lower 

ROC threshold, 5,000 ppmv versus 10,000 ppmv for Rule 74.27. However, the 2004 AFM 

analysis states the incremental cost to control emissions from 10,000 ppmv down to 5,000 

ppmv would be excessive due to the large amount of time and dilution air needed to reduce 

the concentration a further 50%. SCAQMD was able to justify the lower limit due to the 

much more lax conditions of Rule 1149 prior to its amendment and a cost effectiveness 

threshold ($13,159 per ton of ROC reduced) much higher than what would be considered 

RACT in Ventura County. 

SCAQMD also lowered the tank size applicability thresholds for Rule 1149 in its 2008 

revision. The 2004 AFM analysis also addressed the tank size applicability threshold cost 

effectiveness for Rule 74.27. Based on cost estimates of $400 (fixed cost) plus $0.04 per 

gallon of tank size for degassing, the cost effectiveness of degassing a 5,000 gallon tank is 

approximately $9 per pound of ROC reduced. This is equivalent to the District’s BACT cost 

effectiveness threshold and is by definition more stringent than RACT. Since the cost per 

pound of ROC removed will increase as tank size gets smaller, the current tank size threshold 

in Rule 74.27 is beyond RACT requirements. Due to the high cost of reducing the tank size 

and/or ROC concentration thresholds, Rule 74.27 meets RACT and no update is necessary at 

this time. 

RULE 74.28: ASPHALT ROOFING OPERATIONS (Adopted 5/10/1994) 

Rule 74.28 reduces ROC emissions from asphalt roofing equipment and operations by 

requiring close fitting container lids and temperature limits. Rule 74.28 applies to equipment 

used for melting, heating or holding asphalt or coal tar pitch. There is no CTG for this 

equipment and there are no major sources in Ventura County. Therefore, RACT analysis and 

RACT compliance for this rule are unnecessary. 

RULE 74.29: SOIL DECONTAMINATION OPERATIONS (Last Revised 4/8/2008) 

This rule established procedures by which ROC emissions are minimized during the aeration, 

treatment or removal of soil contaminated with petroleum fuel. Rule 74.29 applies to soil 
2014 RACT SIP 

June 10, 2014 

Page 43 of 43 

decontamination equipment and handling of contaminated soil. There is no CTG for this 

equipment or operations and there are no major sources in Ventura County. Therefore, 

RACT analysis and RACT compliance for this rule are unnecessary. 

RULE 74.30: WOOD PRODUCTS COATINGS (Last Revised 6/27/2006) 

Rule 74.30 reduces ROC emissions from wood products coatings and cleaning materials by 

ROC content limits and by requiring certain application methods. Rule 74.30, SCAQMD 

Rule 1136 (amended 6/4/1996), and SJVAPCD Rule 4606 (amended 10/16/2008) are 

equivalent in stringency. Therefore, Rule 74.30 meets RACT and no changes are required at 

this time. 

RULE 74.31: METALWORKING FLUIDS AND DIRECT CONTACT LUBRICANTS 

(Adopted 11/12/2013) 

Rule 74.31 applies to the production, sale and use of metalworking fluids and direct contact 

lubricants and reduces ROC emissions by requiring substitution of high-ROC metalworking 

fluids with low-ROC fluids, including medium napthenic oils, paraffinic oils, vegetable oils, 

synthetic or semi-synthetic oils, or water-reducible fluids. There is no CTG for this 

equipment or operations and there are no major sources in Ventura County. Therefore, 

RACT analysis and RACT compliance are unnecessary at this time. 
ATTACHMENT IV

JUNE 10, 2014 VENTURA COUNTY AIR POLLUTON CONTROL BOARD 

PACKET FOR THE 2014 REASONABLY AVAILABLE CONTROL TECHNOLOGY 

STATE IMPLMENTAITON PLAN REVISION

June 10, 2014 

Air Pollution Control Board 

800 South Victoria Avenue 

Ventura, CA 93009 

SUBJECT: PUBLIC HEARING TO APPROVE THE 2014 REASONABLY AVAILABLE 

CONTROL TECHNOLOGY STATE IMPLEMENTATION PLAN (2014 

RACT SIP) REVISION

RECOMMENDED ACTIONS: 

 1. Approve District staff's determination that the draft 2014 RACT SIP Revision is 

not a project subject to the California Environmental Quality Act (CEQA) as 

provided for in CEQA Guidelines Sections 15060(c)(2) and 15378(a). 

 2. Find and Approve the Ventura County 2014 RACT SIP Revision meets the 

requirements of the federal Clean Air Act for a serious ozone nonattainment area 

on the following bases: 

 (a) all District volatile organic compound (VOC) and nitrogen oxide (NOx) 

rules subject to the U.S. Environmental Protection Agency’s (EPA) 

Control Technique Guidelines (CTGs) meet or exceed Reasonably 

Achievable Control Technology (RACT) requirements; 

 (b) all stationary sources subject to CTGs and major, non-CTG stationary 

sources with the potential to emit 50 tons per year (tpy) or greater of VOCs 

or NOx are controlled to RACT or better standards; and 

 (c) the District has no stationary sources subject to certain CTGs and thus 

those CTGs qualify for findings to that effect called Negative 

Declarations. 

 3. Approve and Adopt a resolution (Attachment A) adopting the 2014 RACT SIP 

Revision (Attachment B) and Authorize the Chair to sign the Board resolution. 

 4. Direct the Clerk of the Board to forward two certified minute orders and an 

affidavit of publication of the public hearing notice for the proposed action to the 

Air Pollution Control District. 

 5. Direct staff to forward the signed resolution and the final 2014 RACT SIP 

Revision to the California Air Resources Board for transmittal to the U.S. 

Environmental Protection Agency as a proposed revision to the California State 

Implementation Plan for ozone under the federal Clean Air Act. 
2014 RACT SIP Revision 

June 10, 2014 

Page 2 

FISCAL IMPACT: 

Mandatory: Yes 

Fiscal impacts: None 

STATEMENT OF MATTER FOR BOARD CONSIDERATION: 

A. General Background 

The purpose of the 2014 RACT SIP Revision is to demonstrate that all District rules 

applicable to ozone precursor emissions meet or exceed RACT and fulfill RACT 

requirements for the federal 8-hour ozone standard. This process is a necessary part of 

Ventura County’s 8-hour ozone attainment planning requirements under the federal Clean 

Air Act. Ventura County is designated a serious nonattainment area for the federal 8-

hour ozone standard. If your Board approves the 2014 RACT SIP Revision, it will then 

be submitted the California Air Resources Board for transmittal to U.S. EPA as a formal 

revision to the California ozone SIP. The District also prepared RACT SIP revisions in 

2006 and 2009. 

Sections 182(b)(2) and 182(f) of the federal Clean Air Act Amendments (42 U.S.C. 

§7511a) require that ozone nonattainment areas implement RACT for sources that are 

subject to CTG. CTGs are documents issued by the EPA that define RACT for major 

anthropomorphic sources of VOC and NOx, both of which are ozone precursor air 

pollutants. RACT is defined as the lowest emissions limitation that a particular source is 

capable of meeting by application of control technology that is reasonably available 

considering technological and economic feasibility (44 FR 53762; September 17, 1979). 

RACT requirements are included in the Clean Air Act to ensure that significant source 

categories at major sources of ozone precursor emissions are controlled to a “reasonable” 

extent, but not necessarily to the more stringent best available control technology 

(BACT) or lowest achievable emission rate (LAER) levels expected for new or modified 

major stationary sources. Emission sources subject to CTGs are called CTG sources. 

Sources not subject to CTGs, but for which RACT may still be required by EPA 

regulation, are called non-CTG sources. 

B. 2014 RACT SIP Process and Analysis 

District staff started its RACT SIP evaluation by reviewing all available CTGs and 

comparing them to District air pollution control rules and applicable stationary sources 

subject to those rules. For each stationary source category, District staff identified 

applicable sources in the County and corresponding District rules. This was 

accomplished through the District’s permit and emissions inventory systems, and 

knowledgeable staff of the District’s permit and enforcement divisions. 
2014 RACT SIP Revision 

June 10, 2014 

Page 3 

Following identification of District rules to be evaluated for the RACT SIP, District staff 

made determinations as to whether the rules meet RACT standards for air pollutant 

emission reductions. The determinations were primarily based on comparing the rules 

with similar rules adopted by other air pollution control districts with higher or “worse” 

ozone nonattainment classifications pursuant to EPA’s June 2013 Proposed Ozone 

Implementation Regulation and EPA Region 9’s March 2006 framework for the RACT 

SIPs. District staff also considered the evaluations and findings of the District’s 2006 and 

2009 RACT SIP revisions. 

District staff considered the cost effectiveness of potential RACT in the evaluations as 

well. In cases where rules in air districts with higher ozone nonattainment classifications 

contain stricter requirements than District rules for similar sources, staff evaluated the 

cost effectiveness of those rules for application as RACT in Ventura County. EPA 

defines RACT as the lowest emission limitation that a particular source is capable of 

meeting by the application of control technology that is reasonably available considering 

technological and economic feasibility. Therefore, if the cost, in dollars per ton of 

pollutant removed, exceeded certain thresholds the control requirements were considered 

beyond RACT for Ventura County. Staff used the inflation-adjusted cost threshold for 

NOx set by EPA and the BACT cost effectiveness threshold for VOC set by the District 

to determine if a technology was economically feasible for application as RACT in 

Ventura County. 

The District’s 2014 RACT SIP evaluations are presented in Attachment B-1 (2014 RACT 

SIP Analyses), starting on page 21 of 43 of Attachment B (2014 Reasonably Available 

Control Technology State Implementation Plan Revision). The evaluations provide a 

determination whether each rule meets RACT as written or if rule updates are needed. 

C. 2014 RACT SIP – Findings Overview 

District staff’s RACT analyses found that: 

 1) All District air pollution control rules applicable to ozone precursor emissions meet or 

exceed RACT. 

 2) The District has no stationary sources subject to certain CTGs and thus those CTGs 

qualify for findings to that effect called Negative Declarations 

 3) All major non-CTG stationary sources of ozone precursor emissions are currently 

subject to one or more District rules that meet RACT. 

 4) The information and analyses presented in the 2014 RACT SIP Revision meet the 

requirements of Sections 182(b)(2) and 182(f) of the federal Clean Air Act (42 U.S.C. 

§7511a). 
2014 RACT SIP Revision 

June 10, 2014 

Page 4 

D. 2014 RACT Findings - Negative Declarations 

Districts may comply with the requirements of Section 182(b)(2) of the federal Clean Air 

Act by adopting a “Negative Declaration” for a CTG category when there are no emission 

sources to which the CTG applies. There are several CTG stationary source categories 

(listed in Table B-2 of the 2014 RACT SIP Revision Attachment B) for which there are 

no sources within the District’s jurisdictional boundaries. District staff, therefore, 

determined that Negative Declarations documenting that there are no sources in the 

county subject to those CTGs are appropriate. Moreover, it is important to note that any 

new major stationary sources (i.e., with VOC or NOx emissions greater than 50 tpy) in 

those CTG categories would be subject to BACT requirements, pursuant to the District’s 

New Source Review (Rule 26) regulation. And since BACT is more stringent than 

RACT, there should not be any adverse impact on the air quality from such sources. The 

CTGs listed in Table B-2 constitute the District’s Negative Declarations for the 2014 

RACT SIP. 

E. 2014 RACT SIP Revision and CEQA 

The 2014 RACT SIP Revision consists of technical evaluations of current District air 

pollution rules and as such will not result in any physical change in the environment. 

Therefore, adoption of the proposed 2014 RACT SIP Revision is not a project as 

provided for in Sections 15060(c)(3) and 15378(a) of the CEQA Guidelines. 

Public Review 

The public review period for the 2014 RACT SIP Revision began on April 3, 2014, and 

ended on May 5, 2014. The District emailed 34 notices of availability of the draft 2014 

RACT SIP to potentially interested representatives of public and private organizations 

and the general public. The District also placed a public notice on the District’s website 

and in a newspaper of general circulation. 

No written comments on the draft 2014 RACT SIP were received. District staff received 

informal comments from EPA Region 9 staff regarding the RACT determination for Rule 

74.24.1 - Pleasure Craft Coating and Commercial Boatyard Operations. EPA staff noted 

the ROC content limits for several coating types did not match those for pleasure craft 

coatings in the CTG for miscellaneous metal and plastic parts coating. The District 

responded to EPA’s comments by expanding the RACT analysis of Rule 74.24.1 to 

demonstrate that the emission reductions achieved by Rule 74.24.1 exceeded those that 

would occur if the District had adopted the baseline CTG requirements. 

Rule 74.24.1 as written results in 65 percent greater emission reductions than would be 

achieved using the baseline CTG recommendations. This is equivalent to 6.5 tons ROC 

emissions per year avoided due to the broader applicability and additional provisions in 

the existing rule. For this reason, along with technology issues discussed in the analysis, 

District staff concludes the current rule meets RACT and does not need to be revised. 

ATTACHMENT A 

A RESOLUTION OF THE VENTURA COUNTY AIR POLLUTION CONTROL 

BOARD OF DIRECTORS APPROVING AND ADOPTING THE 2014 

REASONABLY AVAILABLE TECHNOLOGY STATE IMPLEMENTATION 

PLAN REVISION FOR VENTURA COUNTY, CA 

 
A RESOLUTION OF THE VENTURA COUNTY AIR POLLUTION CONTROL 

BOARD OF DIRECTORS APPROVING AND ADOPTING THE 2014 

REASONABLY AVAILABLE TECHNOLOGY STATE IMPLEMENTATION 

PLAN REVISION FOR VENTURA COUNTY, CA 

WHEREAS, Ventura County, CA is classified a serious nonattainment area for the 

federal 8-hour ozone standard in accordance with the federal Clean Air Act (42 U.S.C. 

§7401 et seq.); and 

 WHEREAS, both the federal Clean Air Act and the California Clean Air Act (Health 

& Safety Code §39000 et seq.) require the Ventura County Air Pollution Control District 

(District) to adopt air pollution control plans, rules and regulations for volatile organic 

compounds (VOC) and nitrogen oxides (NOx) emissions in order to bring Ventura 

County into attainment with national and state ambient air quality standards for ozone as 

expeditiously as practicable; and 

WHEREAS, Sections 182(b)(2) and 182(f) of the federal Clean Air Act (42 U.S.C. 

§7511a, par. (b)(2) and subd. (f)) require ozone nonattainment areas designated as 

moderate or greater to submit a revision to the State Implementation Plan (SIP) for 

implementation of reasonably available control technology (RACT) under Section 

172(c)(1) of the federal Clean Air Act (42 U.S.C. § 7502(c)(1)); and 

WHEREAS, the federal Clean Air Act defines a major stationary source in a serious 

ozone nonattainment area as an emitting source with the potential to emit VOC or NOx 

emissions equal to or greater than 50 tons per year (42 U.S.C. § 7511a(c)); and 

 WHEREAS, District staff evaluated the District’s VOC and NOx rules subject to the 

United States Environmental Protection Agency’s (EPA) Control Technique Guidelines 

(CTG) source categories listed in Table B-1 of the 2014 RACT SIP Revision and found 

that they all meet or exceed RACT requirements; and

WHEREAS, District staff found that the source categories listed in Table B-2 of the 

2014 RACT SIP qualify for negative declarations and that RACT analyses for the CTG 

source categories listed in Table B-2 of the 2014 RACT SIP Revision are not necessary 

on the bases that there are no sources within the District jurisdiction subject to the CTGs 

listed in Table B-2 of the 2014 RACT SIP as explained more fully in 2014 RACT SIP 

Revision at page 5 of 40; and 

 WHEREAS, on April 3, 2014, the District published a notice of the public hearing 

on the draft 2014 RACT SIP Revision in a newspaper of general circulation within 

Ventura County; and 

WHEREAS, the Air Pollution Control Board (Board) held a public hearing on June 

10, 2014, to receive and consider public testimony on the draft 2014 RACT SIP Revision; 

and 
WHEREAS, the Board has considered the information and testimony presented at 

the public hearing, written comments, and District responses to those public comments; 

and 

WHEREAS, the Board has read and reviewed the draft 2014 RACT SIP Revision; 

and 

WHEREAS, the 2014 RACT SIP Revision is not a project as defined by CEQA 

Guidelines §15378 and accordingly is not subject to CEQA review pursuant to CEQA 

Guidelines §15060(c)(3). 

NOW, THEREFORE BE IT RESOLVED, the Board finds that the information and 

analyses presented in the 2014 RACT SIP Revision meet the requirements of Sections 

182(b)(2) and 182(f) of the federal Clean Air Act (42 U.S.C. § 7511a, par. (b)(2) and 

subd. (f)); and 

 BE IT FURTHER RESOLVED, the Board adopts the 2014 RACT SIP Revision for 

its part in the California State Implementation Plan; and 

FINALLY, BE IT RESOLVED, the Board directs District staff to forward this 

Resolution and the adopted 2014 RACT SIP Revision for Ventura County, CA to the 

California Air Resources Board for transmittal to the EPA as a revision to the California 

SIP for ozone. 

APPROVED AND ADOPTED this June 10, 2014. 

APPROVED AND ADOPTED this __________ day of June 2014 by the following vote: 

AYES: 

NOES: 

ABSENT: 

 

CHAIR, Air Pollution Control Board 

ATTEST: 

MICHAEL POWERS 

Ex officio Clerk of the Air Pollution Control Board

County of Ventura, State of California 

By: _____________________________________ 

 Deputy Clerk of the Board 
ATTACHMENT B 

VENTURA COUNTY AIR POLLUTION CONTROL DISTRICT 

2014 REASONABLY AVAILABLE CONTROL TECHNOLOGY 

STATE IMPLEMENTATION PLAN REVISION 

(REFER TO ADOPTED PLAN REVISION PRESENTED IN 

ATTACHMENT III OF THIS DOCUMENT)
ATTACHMENT V

CERTIFICATE OF PUBLICATION – PUBLIC NOTICE

ATTACHMENT VI 

NOTICE OF EXEMPTION FROM 

CALIFORNIA ENVIRONMENTAL QUALITY ACT