R. Corey

June 12, 2014 Page 2



### Attachments: I. SIP Completeness Checklist II. A Resolution of the Ventura County Air Polluti on 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 Con trol Board Packet for the 2014 Reasonably Available Control Technology State Imple mentation Plan Revision

V. Certificate of Publication – Public Notice VI. Notice of Exemption from California Environmen tal Quality Act

cc (electronic): Andy Steckel, EPA Region IX (w/att achments) Stanley Tong, EPA Region IX (w/attachments) Kurt Karperos, ARB (w/attachments) Sylvia Vanderspek, ARB (w/attachments)

### ATTACHMENT I

SIP COMPLETENESS CHE CKLISTAttachment 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 Procedure s Act:

Attachment II is a signed resolution from the Ventu ra 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 P lan Revision which includes all materials presented at the public hearing.

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

Attachment V is a copy of the Certificate of Public ation 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 SI P 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 Polluti on 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 Con trol Board Packet for the 2014 Reasonably Available Control Technology State Imple mentation Plan Revision

V. Certificate of Publication – Public Notice VI. Notice of Exemption from the California Enviro nmental Quality Act

### ATTACHMENT II

A RESOLUTION OF THE VENTURA COUNTY AIR P OLLUTION CONTROL

BOARD APPROVING AND ADOPTING THE 201 4 REASONABLY AVAILABLE

TECHNOLOGY STATE IMP LEMENTATION PLAN REV ISION

### ATTACHMENT III

2014 REASONABLY AVAI LABLE CONTROL TECHNO LOGY 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 required2014 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 review2014 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 RACT2014 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 C TGs

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 a2014 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 SIPJune 10, 2014Page 7 of 43Table B-1, Source Categories, CTG/ACT List, and Applicable District RulesSource CategoryReference Document *ApplicabilityVCAPCD RuleDateAdoptedDate LastRevisedCoatings and SolventsAerospace Manufacturingand Rework Operations &Coating OperationsControl of VOC Emissions fromCoating Operations at AerospaceManufacturing and ReworkOperations (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 operationsincluding contractors and subcontractors.Rule 74.13 - AerospaceAssembly andComponentManufacturing Operations4/15/1986 9/11/2012Supersedes the applicable parts of the MiscellaneousMetal Part and Products CTG. Does not apply tomanufacturing or rework operations involving spacevehicles; rework operations performed on antiqueaerospace vehicles or components; or research anddevelopment, quality control, laboratory testing, andelectronic parts and assemblies (except for cleaning andcoating of completed assemblies).Rule 74.12 - SurfaceCoating of Metal Partsand Products11/19/1985 4/8/2008Automobile RefinishingReduction of Volatile OrganicCompound Emissions fromAutomobile Body Refinishing (EPA453/R-94-031, 1994/04)Applies to automobile refinishing operations. Rule74.18 – MotorVehicle and MobileEquipment CoatingOperations1/28/1992 11/11/2008Automobile Refinishing (EPA-450/3-88-009, 1988/10)Applies to automobile refinishing operations. Rule74.18 – MotorVehicle and MobileEquipment CoatingOperations1/28/1992 11/11/2008Paper and Fabric, SurfaceCoating ofControl of Volatile Organic Emissionsfrom 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 puton paper, fabric, or plastic film, and includes decorativecoatings on metal foil such as gift wrap and packaging.Rule 74.3 - Paper, Fabricand Film CoatingOperations5/29/1979 12/10/1991Graphic ArtsACT - Control of Volatile OrganicEmissions from Existing StationarySources, Volume VIII: Graphic Arts -Rotogravure and Flexography (EPA450/2-78-033, 1978/12)Applies to graphic arts operations that use theflexographic and rotogravure printing processes asapplied to both publication and packaging printing.Rule 74.19 - Graphic Arts 8/11/1992 6/14/2011Offset Lithography Printing (EPA453/R-94-054, 1994/06)Applies to graphic arts operations that use the offsetlithographic printing process.Rule 74.19 - Graphic Arts 8/11/1992 6/14/2011Offset Lithographic Printing andLetterpress Printing (EPA-453/R-06-002, 2006/09)Applies to graphic arts operations that use the offsetlithographic printing or letterpress printing process.Rule 74.19 - Graphic Arts 8/11/1992 6/14/20112014 RACT SIPJune 10, 2014Page 8 of 43Table B-1, Source Categories, CTG/ACT List, and Applicable District Rules (cont’d)Source CategoryReference Document *ApplicabilityVCAPCD RuleDateAdoptedDate LastRevisedFor fabric coating, applies to all types of coatings appliedto fabric and any decorative or protective topcoatappliedover vinyl coated fabric or vinyl sheets. Does notapply tothe application of vinyl plastisol to the fabric.Rule 74.3 - Paper, Fabricand Film CoatingOperations5/29/1979 12/10/1991For paper coatings, applies to all coatings put onpaper,pressure sensitive tapes regardless of substrate (e.g.paper fabric or plastic film), and related web coatingprocesses on plastic film such as typewriter ribbons,photographic film, or magnetic tape. Also includesdecorative coatings on metal foil such as gift wrapandpackaging.Rule 74.3 - Paper, Fabricand Film CoatingOperations5/29/1979 12/10/1991Metal Furniture, SurfaceCoating ofControl of Volatile Organic Emissionsfrom Existing Stationary Sources,Volume III: Surface Coating of MetalFurniture (EPA-450/2-77-032,1977/12)Applies to surface coating of metal furniture by metalfurniture manufacturers.Rule 74.12 - SurfaceCoating of Metal Partsand Products11/19/1985 4/8/2008Metal Furniture Coatings (EPA453/R-07-005, 2007/09)Applies to metal surface coating units at facilities wherethe total actual VOC emissions from all metal furniturecoating operations, including cleaning activities,are atleast 6.8 kg/day (15 lb/day) of VOC before considerationof controls.Rule 74.12 - SurfaceCoating of Metal Partsand ProductsMetal Parts and Products,Surface Coating ofMiscellaneousControl of Volatile Organic Emissionsfrom Existing Stationary Sources,Volume VI: Surface Coating ofMiscellaneous Metal Parts andProducts (EPA-450/2-78-015,1978/06)Applies to industries that are not covered by specific CTGdocuments (Specific CTGs have been published for can,coil, automobile and light duty truck, metal furniture,magnet wire, and large appliances.)Rule 74.12 - SurfaceCoating of Metal Partsand Products11/19/1985 4/8/2008Miscellaneous Metal and PlasticParts Coatings (EPA 453/R-08-003,2008/09)Applies to industries that are not covered by specific CTGdocuments where the total actual VOC emissions fromallmetal and/or plastic parts coating operations, includingcleaning activities, are at least 6.8 kg/day (15 lb/day) ofVOC before consideration of controls.Rule 74.12 - SurfaceCoating of Metal Partsand Products11/19/1985 4/8/2008ShipbuildingShipbuilding and Ship RepairOperations (Surface Coating) (61 FR44050 8/27/96, 1996/08)Applies to coatings and solvents used for buildingormaintaining metal marine or fresh-water metal hulledvessels used for military or commercial operations,including self-propelled vessels and those towed byothercraft (barges). This definition includes, but is not limitedto, all military vessels, commercial cargo and passenger(cruise) ships, ferries, barges, tankers, containerships,patrol and pilot boats, and dredges.Rule 74.24 - MarineCoating Operations3/8/1994 9/11/20122014 RACT SIPJune 10, 2014Page 9 of 43Table B-1, Source Categories, CTG/ACT List, and Applicable District Rules (cont’d)Source CategoryReference Document *ApplicabilityVCAPCD RuleDateAdoptedDate LastRevisedRule 74.24.1 – PleasureCraft Coating andCommercial BoatyardOperations11/10/1998 1/8/2002Surface Coating Operations atShipbuilding and Ship RepairFacilities (EPA-453/R-94-032,1994/04)Applies to any marine or fresh-water metal hulled vesselused for military or commercial operations, including selfpropelled vessels and those towed by other craft.Thisdefinition includes, but is not limited to, all militaryvessels, commercial cargo and passenger ships, ferries,barges, tankers, container ships, patrol and pilotboats,and dredges. Pleasure craft, such as recreationalboatsand yachts, are not included.Rule 74.24 - MarineCoating Operations3/8/1994 9/11/2012Rule 74.24.1 – PleasureCraft Coating andCommercial BoatyardOperations11/10/1998 1/8/2002Solvent Metal CleaningControl of Volatile Organic Emissionsfrom Solvent Metal Cleaning (EPA450/2-77-022, 1977/11)Applies to cold cleaners, open top vapor degreasers, andconveyorized degreasers which use volatile solventstoclean metal parts.Rule 74.6 - SurfaceCleaning and Degreasing5/29/1979 11/11/2003 -effective7/1/2004ACT - Halogenated Solvent Cleaners(EPA-450/3-89-030, 1989/08)Applies to cleaning machines that use halogenatedsolvents.Rule 74.6.1 - BatchLoaded VaporDegreasers5/29/1979 11/11/2003 -effective7/1/2004ACT - 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 - SurfaceCleaning and Degreasing5/29/1979 11/11/2003 -effective7/1/2004Rule 74.6.1 - BatchLoaded VaporDegreasers5/29/1979 11/11/2003 -effective7/1/2004Traffic MarkingsReduction of VOC Emissions fromthe Application of Traffic Markings(EPA-450/3-88-007, 1988/08)Applies to application of highway traffic markings.74.2 – ArchitecturalCoatings6/19/1979 11/12/2010Wood FurnitureManufacturingControl of VOC Emissions fromWood Furniture ManufacturingOperations (EPA-453/R-96-007,1996/04)Applies to any facility that finishes wood furniture, orperforms cleaning or wash-off associated with woodfurniture finishing operations.Rule 74.30 - WoodProducts Coatings5/17/1994 6/27/2006PetroleumBulk Gasoline PlantsControl of Volatile Organic Emissionsfrom Bulk Gasoline Plants (EPA450/2-77-035, 1977/12)Applies to bulk plants with daily throughputs of 76,000liters (20,077 gal.) gasoline or less.Rule 70 - Storage andTransfer of Gasoline6/25/1974 3/10/2009effective4/1/20092014 RACT SIPJune 10, 2014Page 10 of 43Table B-1, Source Categories, CTG/ACT List, and Applicable District Rules (cont’d)Source CategoryReference Document *ApplicabilityVCAPCD RuleDateAdoptedDate LastRevisedExternal Floating RoofTanks, Petroleum LiquidStorage inControl of Volatile Organic Emissionsfrom Petroleum Liquid Storage inExternal Floating Roof Tanks (EPA450/2-78-047, 1978/12)Applies to external floating roof tanks larger than150,000liters (~40,000 gal. or 950 bbls.) storing petroleum liquids.Rule 71.2 - Storage ofReactive OrganicCompound Liquids6/20/1978 9/26/1989Volatile Organic Liquid Storage inFloating and Fixed Roof Tanks (EPA453/R-94-001, 1994/01)Rule 74.26 - Crude OilStorage Tank DegassingOperations11/8/1994 N/AFixed Roof Tanks, Storageof Petroleum Liquids inACT - Control of Volatile OrganicEmissions from Storage ofPetroleum Liquids in Fixed RoofTanks (EPA-450/2-77-036, 1977/12)Applies to storage vessels with capacities greaterthan150,000 liters containing petroleum liquids with atruevapor pressure greater than 10.5 KPa. Exempts fixedroof tanks with capacities less than 1,600,000 liters usedto store produced crude or condensate prior to leasecustody transfer.Rule 71.2 - Storage ofReactive OrganicCompound Liquids6/20/1978 9/26/1989Volatile Organic Liquid Storage inFloating and Fixed Roof Tanks (EPA453/R-94-001, 1994/01)Applies to storage tanks in all industries, but primarily inthe petroleum refineries, pipelines, chemical plants, liquidterminals.Rule 71.2 - Storage ofReactive OrganicCompound Liquids6/20/1978 9/26/1989Rule 74.26 - Crude OilStorage Tank DegassingOperations11/8/1994 N/ANatural Gas/GasolineProcessing Plants,Equipment Leaks fromControl of VOC Equipment Leaksfrom Natural Gas/GasolineProcessing Plants (EPA-450/3-83-007, 1983/12)Applies to facilities engaged in the separation ofnaturalgas liquids from field gas and/or fraction of the liquids intonatural gas products, such as ethane, propane, butaneand natural gasoline. It is not applicable to compressorstations, dehydration units, sweetening units, fieldtreatment, underground storage facilities, liquefied naturalgas units and field gas gathering systems unless they arelocated at a gas plant.Rule 74.10 - Componentsat Crude Oil and NaturalGas Production andProcessing Facilities9/29/1981 3/10/1998Gasoline DispensingStage II Vapor RecoveryStage II Gasoline DispensingFacilities (EPA-450/3-91-022a,1991/12) †Applies to gasoline dispensing into motor vehiclesatgasoline dispensing facilities.Rule 70 - Storage andTransfer of Gasoline6/25/1974 3/10/2009effective4/1/2009Gasoline Service StationsDesign Criteria for Stage I VaporControl Systems - Gasoline ServiceStations (EPA-450/R-75-102,1975/11)Applies to filling of gasoline storage tanks from gasolinetanker trucks.Rule 70 - Storage andTransfer of Gasoline6/25/1974 3/10/2009effective4/1/2009Organic Liquid StorageVolatile Organic Liquid Storage inFloating and Fixed Roof Tanks(EPA/453 R-94-001, 1994/01)Applies to storage tanks in all industries, but primarily inpetroleum refineries, pipelines, chemical plants, liquidterminalsRule 71.2 - Storage ofReactive OrganicCompound Liquids6/20/1978 9/26/19892014 RACT SIPJune 10, 2014Page 11 of 43Table B-1, Source Categories, CTG/ACT List, and Applicable District Rules (cont’d)Source CategoryReference Document *ApplicabilityVCAPCD RuleDateAdoptedDate LastRevisedPetroleum RefineryEquipment, Leaks fromControl of VOC Leaks fromPetroleum Refinery Equipment(EPA-450/2-78-036, 1978/06)Applies to leaks from equipment such as pumps,compressors, flanges, valves, and pressure reliefdevices.Rule 74.7 - FugitiveEmissions of ReactiveOrganic Compounds(ROC) at PetroleumRefineries and ChemicalPlants5/29/1979 10/10/1995Refinery VacuumProducing Systems,Wastewater Separators,and Process UnitTurnaroundsControl of Refinery VacuumProducing Systems, WastewaterSeparators, and Process UnitTurnarounds (EPA-450/2-77-025,1977/10)Applies to non-condensables from vacuum producingsystems, wastewater separators, and all pressurizedprocess units.Rule 74.8 - RefineryVacuum ProducingSystems, WastewaterSeparators and ProcessTurnarounds6/19/1979 7/5/1983Rule 74.7 - FugitiveEmissions of ReactiveOrganic Compounds(ROC) at PetroleumRefineries and ChemicalPlants5/29/1979 10/10/1995Synthetic OrganicChemical and PolymerManufacturing Equipment,Equipment Leaks fromControl of VOC Fugitive Emissionsfrom Synthetic Organic ChemicalPolymer and Resin ManufacturingEquipment (EPA-450/3-83-006,1984/03)Applies to leaks of process fluids (gaseous or liquid) fromplant equipment such as pumps, compressors, in-lineprocess valves, pressure relief devices, open-endedvalves, sampling connections, flanges, agitators, andcooling towers.Rule 74.7 – FugitiveEmissions of ReactiveOrganic Compounds atPetroleum Refineries andChemical Plants5/29/197910/10/1995Tank Trucks, GasolineLoading TerminalsControl of Hydrocarbons from TankTruck Gasoline Loading Terminals(EPA-450/2-77-026, 1977/10)Applies to tank truck terminals with daily throughputsgreater than 76,000 liters (20,077 gal.).Rule 70 - Storage andTransfer of Gasoline6/25/1974 3/10/2009effective4/1/2009Tank Trucks, Gasoline,and Vapor CollectionSystemsControl of VOC Leaks from GasolineTank Trucks and Vapor CollectionSystems (EPA-450/2-78-051,1978/12)Applies to gasoline tank trucks that are equipped withvapor collection systems and the vapor collectionsystems at bulk terminals, bulk plants and servicestations.Rule 70 - Storage andTransfer of Gasoline6/25/1974 3/10/2009effective4/1/2009Stationary Source NOxElectric Utility BoilersNOx Emissions from Utility Boilers(EPA-453/R-94-023, 1994/03)Applies to electric utility boilers. Rule 59 - Electrical PowerGenerating Equipment -Oxides of Nitrogen Oxide10/6/1969 7/15/19972014 RACT SIPJune 10, 2014Page 12 of 43Table B-1, Source Categories, CTG/ACT List, and Applicable District Rules (cont’d)Source CategoryReference Document *ApplicabilityVCAPCD RuleDateAdoptedDate LastRevisedIndustrial CommercialBoilersACT – NOx Emissions fromIndustrial Commercial & InstitutionalBoilers (EPA-453/R-94-022,1994/03)Applies to boilers used in industrial facilities. Rule 74.15 - Boilers,Steam Generators andProcess Heaters3/28/1989 11/8/1994Rule 74.15.1 - Boilers,Steam Generators, andProcess Heaters5/11/1993 9/11/2012Process HeatersACT – NOx Emissions from ProcessHeaters (EPA-453/R-93-034, revised1993/09)Applies to direct-fired heaters used primarily in thepetroleum industry.Rule 74.15 - Boilers,Steam Generators andProcess Heaters3/28/1989 11/8/1994Rule 74.15.1 - Boilers,Steam Generators, andProcess Heaters5/11/1993 9/11/2012Stationary Gas TurbinesACT - NOx Emissions fromStationary Combustion Turbines(EPA-453/R-93-007, 1993/01)Applies to stationary gas turbines used in variousapplications and operations.Rule 74.23 - StationaryGas Turbines3/14/1995 1/8/2002Stationary ReciprocatingInternal Combustion (IC)EnginesACT - NOx Emissions fromStationary IC Engines (EPA-453/R93-032, 1993/07, updatedSeptember 2000)Applies to stationary reciprocating internal combustionengines.Rule 74.9 - StationaryInternal CombustionEngines7/21/1981 11/8/2005OtherCutback AsphaltControl of VOC from Use of CutbackAsphalt (EPA-450/2-77-037,1977/12)Applies to use of cutback asphalt used for roadwaypaving.Rule 74.4 - CutbackAsphalt6/19/1979 7/5/1983Ethylene Oxide -Sterilization and AerationACT - Ethylene OxideSterilization/Fumigation Operations(EPA-450/3-89-007, 1989/03)Applies to ethylene oxide used as a sterilant/fumigant inproduction of medical equipment supplies, inmiscellaneous sterilization and fumigation operations,and at hospitals.Rule 62.6 - EthyleneOxide - Sterilization andAeration7/16/1991 N/AIndustrial AdhesivesControl Techniques Guidelines forMiscellaneous Industrial Adhesives(EPA-453/R-08-005)Applies to each miscellaneous industrial adhesiveapplication process at facilities where the total actualVOC emissions from all industrial adhesive operations,including cleaning activities, are at least 6.8 kg/day (15lb/day) of VOC before consideration of controls.Rule 74.20 – Adhesivesand Sealants6/8/1993 9/11/2012Large Petroleum DryCleanersControl of VOC Emissions fromLarge Petroleum Dry Cleaners,(EPA-450/3-82-009, 1982/09)Applies to petroleum solvent dry cleaning facilities thatconsume 123,000 liters or more of petroleum solventperyear.Rule 74.5.1 - PetroleumSolvent Dry Cleaning12/4/1990 N/A* EPA reference document numbers correspond to EPAReport column in table of Control Measures GuidanceDocuments found athttp://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 titlepage. Document obtained March 13, 2014 athttp://www.epa.gov/airquality/ozonepollution/SIPToolkit/ctg_act/199111_voc_epa450_3-91-022a_stage2_gasoline_dispensing%28v1%29.pdf2014 RACT SIPJune 10, 2014Page 13 of 43Table B-2, CTG/ACT Source Categories for Which There Are No Subject District SourcesSource CategoryReference Document *ApplicabilityVenturaCountySources?RACT AnalysisCoatings and SolventsAerospaceManufacturing andRework Operations &Coating OperationsControl of VOC Emissions from CoatingOperations at Aerospace Manufacturing andRework Operations (EPA-453/R-97-004,1997/12), See also Aerospace MACT (59FR-29216 6/06/94, 1994/06)Applies to aerospace coatings and cleaning solventsuse ataerospace manufacturing and rework operations thathave thepotential to emit greater than or equal to 25 tonsper year ofVOCs including contractors and subcontractors.Yes No sources with emissionsgreater than the CTGapplicability threshold of25 tons ROC per year.Automobile and Lightduty Trucks, SurfaceCoating ofControl of Volatile Organic Emissions fromExisting Stationary Sources - Volume II:Surface Coating of Cans, Coils, Paper,Fabrics, Automobiles, and Light-Duty Trucks(EPA-450/2-77-008, 1977/5),ControlTechniques Guidelines for Automobile andLight-Duty Truck Assembly Coatings (EPA453/R-08-006, 2008/09)For automobile & light truck coating, applies to all objects surfacecoated in automotive and light duty truck assemblyplants. Doesnot apply to customizers, body shops or other repainters.NoN/A**Auto, Transport,Business MachinePlastic CoatingsACT – Surface Coating ofAutomotive/Transportation and BusinessMachine Plastic Parts, (EPA-453/R-94-017,1994/02)Applies to surface coating of plastics used in motor vehicles andbusiness machines.No N/ACans and Coils,Surface Coating ofControl of Volatile Organic Emissions fromExisting Stationary Sources - Volume II:Surface Coating of Cans, Coils, Paper,Fabrics, Automobiles, and Light-DutyTrucks (EPA-450/2-77-008, 1978/06)For cans, applies to sheet basecoat and over varnish, two-piececan exterior basecoat and over varnish, two and three-piece caninterior body spray, two-piece can exterior end spray or roll coat,three piece can side seam spray, and end sealing compound.No N/AFor coil coating, applies to prime and topcoat or single coatoperation.No N/AFlat Wood Paneling,Surface Coating ofControl of Volatile Organic Emissions fromExisting Stationary Sources, Volume VII:Factory Surface Coating of Flat WoodPaneling (EPA-450/2-78-032, 1978/06),Control Techniques Guidelines for FlatWood Paneling Coatings (EPA-453/R-06-004, 2006/09)Applies to interior paneling made of wood products.No N/AFlexible PackagingPrintingControl Techniques Guidelines for FlexiblePackaging Printing (EPA-453/R-06-003,2006/09)Applies to flexible packaging printing operations that emit at least6.8 kg/day (15 lb/day) of VOC before considerationof controls.No N/AInk and PaintManufacturingControl of VOC from Ink and PaintManufacturing (EPA-450/3-92-013,1992/04) †Applies to products of the paint manufacturing industry, includingarchitectural coatings, product coating for original equipmentmanufacturers, and special-purpose coatings. Alsoapplies toink manufacturing, including letterpress inks, lithographic andoffset inks, gravure inks, and flexographic inks.Yes No major sources; Sourcescontrolled with BACT.2014 RACT SIPJune 10, 2014Page 14 of 43Table B-2, CTG/ACT Source Categories for Which There Are No Subject District Sources (cont’d)Source CategoryReference DocumentApplicabilityVenturaCountySources?RACT AnalysisLarge Appliances,Surface Coating ofControl of Volatile Organic Emissions fromExisting Stationary Sources, Volume V:Surface Coating of Large Appliances (EPA450/2-77-034, 1977/12), Control TechniquesGuidelines for Large Appliance Coatings(EPA 453/R-07-004, 2007/09)Applies to the coating of large appliances, such asdoors, cases,lids, panels and interior support parts of residential andcommercial washers, dryers, ranges, refrigerators,freezers,water heaters, dishwashers, trash compactors, air conditioners,and similar products.No N/AMagnet Wire, SurfaceCoating for InsulationofControl of Volatile Organic Emissions fromExisting Stationary Sources, Volume IV:Surface Coating for Insulation of MagnetWire (EPA-450/2-77-033, 1977/12)Applies to wire coating curing ovens. No N/AMetal FurnitureCoatingsControl of Volatile Organic Emissions fromExisting Stationary Sources, Volume III:Surface Coating of Metal Furniture (EPA450/2-77-032, 1977/12)Applies to surface coating of metal furniture by metal furnituremanufacturers.No N/AControl Techniques Guidelines for MetalFurniture Coatings (EPA 453/R-07-005,2007/09)Applies to metal surface coating units at facilities where the totalactual VOC emissions from all metal furniture coating operations,including cleaning activities, are at least 6.8 kg/day (15 lb/day) ofVOC before consideration of controls.No N/APaper, Film and FoilCoatingsControl 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 allpaper, film and foil coating operations, includingcleaningactivities, are at least 6.8 kg/day (15 lb/day) ofVOC beforeconsideration of controls.No N/APetroleumPetroleum RefineriesControl Techniques for VOC Emissionsfrom Stationary Sources (EPA-453/R-92-018, 1992/12)Applies to petroleum refineries.No N/AControl of Refinery Vacuum ProducingSystems, Wastewater Separators andProcess Unit Turnarounds (EPA 450/2-77-025, 1977/10)Applies to metal surface coating units at facilities where the totalactual VOC emissions from all metal furniture coating operations,including cleaning activities, are at least 6.8 kg/day (15 lb/day) ofVOC before consideration of controls.No N/AControl of VOC Leaks from PetroleumRefinery Equipment (EPA-450/2-78-036,1978/06)Applies to leaks equipment such as pumps, compressors,flanges, valves, and pressure relief devices.No N/AStationary Source NOxCementManufacturingNOx Emissions from Cement Manufacturing(EPA-453/R-94-004, 1994/03, and updateEPA-457/R-00-002, 2000/09)Applies to the kilns used in cement manufacturing.No N/AGlass ManufacturingNOx Emissions from Glass Manufacturing(EPA-453/R-94-037, 1994/06)Applies to glass manufacturing.No N/AIron and SteelNOx Emissions from Iron and Steel (EPA453/R-94-065, 1994/9)Applies to iron and steel manufacturing. No N/A2014 RACT SIPJune 10, 2014Page 15 of 43Table B-2, CTG/ACT Source Categories for Which There Are No Subject District Sources (cont’d)Source CategoryReference DocumentApplicabilityVenturaCountySources?RACT AnalysisNitric and Adipic AcidManufacturing PlantsNOx Emissions from Nitric and Adipic AcidManufacturing Plants (EPA-453/3-91-026,1991/12)Applies to nitric and adipic acid manufacturing operations. No N/AOtherAgricultural PesticidesControl of VOC from the Application ofAgricultural Pesticides (EPA-453/R-92-011,1993/3)Applies to pesticides used for agricultural purposes. Yes Regulated by the State ofCalifornia Department ofPesticide RegulationBatch ProcessesControl of VOC Emissions from BatchProcesses (EPA-453/R-93-020, 1994/2,a.k.a. EPA-453/R-93-017)Applies to plastic materials and resins, pharmaceuticals, gumand wood chemicals, cyclic crudes and intermediates, industrialorganic chemicals, and agricultural chemicals.Yes No major sources; Sourcescontrolled with BACT.Commercial BakeriesBakery Ovens (EPA-453/R-92-017, 1992/12) Applies tocommercial bakery operations. Yes No major sources; Sourcescontrolled with BACT.Ethylene Oxide -Sterilization andAerationEthylene Oxide Sterilization (EPA-450/3-89-007, 1989/03)Applies to ethylene oxide used as a sterilant/fumigant inproduction of medical equipment supplies, in miscellaneoussterilization and fumigation operations, and at hospitals.Yes No major sources.Fiberglass BoatManufacturingControl Techniques Guidelines forFiberglass Boat Manufacturing Materials(EPA 453/R-08-004, 2008/09)Applies to facilities that manufacture hulls or decks of boats fromfiberglass, or build molds to make fiberglass boathulls or decks,where the total actual VOC emissions from all fiberglass boatmanufacturing operations, including cleaning activities, coveredby the CTG are at least 6.8 kg/day (15 lb/day) of VOC beforeconsideration of controls.No N/AIndustrial AdhesivesControl Techniques Guidelines forMiscellaneous Industrial Adhesives (EPA453/R-08-005, 2008/09)Applies to each miscellaneous industrial adhesive applicationprocess at facilities where the total actual VOC emissions fromall industrial adhesive operations, including cleaning activities,are at least 6.8 kg/day (15 lb/day) of VOC before consideration ofcontrols.Yes No sources with emissionsgreater than the CTGapplicability threshold of 15lb/day of VOC.Industrial WastewaterIndustrial Wastewater CTG (Draft) EPA453/D-93-056, 1992/9); ACT (1994/4)Applies to emissions from the collection and treatment ofindustrial wastewater from: the organic chemicals,plastics, andsynthetic fibers industry; the pesticides manufacturing industry;the pharmaceuticals manufacturing industry; and thehazardouswaste treatment, storage, and disposal facilities industry.No N/ALeather Tanning andFinishing OperationsLeather Tanning and Finishing Operations(EPA-453/R-93-025) ‡Applies to leather finishing operations. No N/AOrganic WasteACT - Organic Waste Process Vents (EPA450/3-91-007, 1990/12)Applies to process vents including those on waste managementunits at TSDF treating wastes with total organics concentration ofless than 10 ppmw and those on treatment units thatare part ofa waste management system exempt from RCRA permitting.No N/APharmaceuticalProductsControl of Volatile Organic Emissions fromManufacture of Synthesized PharmaceuticalProducts (EPA-450/2-78-029, 1978/12)Applies to facilities and operations that synthesizepharmaceutical products.No N/A2014 RACT SIPJune 10, 2014Page 16 of 43Table B-2, CTG/ACT Source Categories for Which There Are No Subject District Sources (cont’d)Source CategoryReference DocumentApplicabilityVenturaCountySources?RACT AnalysisPlywood VeneerDryersControl Techniques for Organic Emissionsfrom Plywood Veneer Dryers (EPA-450/3-83-012, 1983/05)Applies to softwood plywood manufacturing operations. No N/APneumatic RubberTires, Manufacture ofControl of Volatile Organic Emissions fromManufacture 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 N/APolyester ResinControl of VOC Emissions fromManufacture 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 N/AControl of VOC Emissions from SyntheticOrganic Chemical Polymer and ResinManufacturing Equipment (EPA-450/3-83-006, 1984/03Applies to emissions from equipment used in synthetic organicchemical polymers and resins.No N/AControl of VOC Emissions from PolystyreneFoam Manufacturing (EPA-450/3-90-020,1990/09)Applies to polystyrene foam manufacturing Yes No major sources; Sourcescontrolled with BACT.Synthetic OrganicChemicalManufacturingControl of VOC Emissions from Air OxidationProcesses in Synthetic Organic ChemicalManufacturing Industry (EPA-450/3-84-015,1984/12)Applies to air oxidation processes used in the synthetic organicchemical manufacturing industry.No N/ASOCMI Distillation and Reactor Processes(EPA-450/4-91-031, 1983/08)Applies to reactor processes that chemically changefeed stocksinto products or intermediate chemicals and distillationprocesses used to separate chemicals in the synthetic organicchemical manufacturing industry.No N/APetroleum Solvent DryCleanersControl of VOC Emissions from LargePetroleum Dry Cleaners (EPA-450/3-82-009, 1982/09)Applies to petroleum solvent dry cleaning facilities that consume123,000 liters or more of petroleum solvent per year.No N/A* Report Numbers correspond to EPA Report column intable of Control Measures Guidance Documents foundat http://www.epa.gov/glo/SIPToolkit/ctg_act/; accessedMarch 13, 2014.** Not applicable† Report not listed on web page cited above. Report number taken from actual reference document titlepage. Document obtained March 26, 2014 athttp://www.epa.gov/ttncatc1/dir1/ink_paint.pdf.‡ Report not listed on web page cited above. Report number taken from actual reference document titlepage. Document obtained March 26, 2014 athttp://nepis.epa.gov/Exe/ZyNET.exe/2000HJFP.TXT?ZyActionD=ZyDocument&Client=EPA&Index=1991+Thru+1994&Docs=&Query=&Time=&EndTime=&SearchMethod=1&TocRestrict=n&Toc=&TocEntry=&QField=&QFieldYear=&QFieldMonth=&QFieldDay=&IntQFieldOp=0&ExtQFieldOp=0&XmlQuery=&File=D%3A\zyfiles\Index%20Data\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=ZyActionL&Back=ZyActionS&BackDesc=Results%20page&MaximumPages=1&ZyEntry=1&SeekPage=x&ZyPURL2014 RACT SIPJune 10, 2014Page 17 of 43Table B-3, Major Sources in Ventura CountyRules Evaluated that Apply to Ventura County MajorSource FacilitiesAPCDPermitNo.Facility Name597071.171.371.471.574.274.474.674.974.1074.1100004 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 SIPJune 10, 2014Page 18 of 43Table B-3, Major Sources in Ventura County (cont’d)Rules Evaluated that Apply to Ventura County MajorSource FacilitiesAPCDPermitNo.Facility Name74.11.174.1374.1574.15.174.1674.1974.2274.2374.2674.2774.2874.2900004 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 S IP

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 5/23/197 9

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 S IP (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

74.2 5 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 appr oval adding rule to SIP.
† The most recent revisions of these rules have bee n 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 a s part of the California State Plan for controlling existing MSW landfills, as set forth in 40 CFR part 60, subp art Cc. The submitted revision to the California 111(d) Plan fo r controlling MSW landfill gas emissions meets all applicable requirements for approval. This rule was also subm itted to EPA for inclusion in the SIP but EPA has t aken 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 avai lable control technology (RACT) for sources that are subject to Control Techniques Guid elines (CTG) issued by EPA and for “major sources” of VOC and NOx, which are ozone pre cursors. RACT is defined as the lowest emissions limitation that a particular sourc e 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 precurs or emissions are controlled to a “reasonable” extent, but not necessarily to the mor e stringent Best Available Control Technology (BACT) or “lowest achievable emission ra te” (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 Qual ity Standards (NAAQS) for ground-level ozone. Among those are requirements that State Imp lementation Plans (SIPs) for ozone nonattainment areas provide for RACT. According to the ozone rule, areas classified as moderate or higher ozone nonattainment areas must s ubmit revisions to their SIPs demonstrating that their current rules fulfill 8-ho ur ozone RACT for all CTG categories and all major, non-CTG sources.

RACT SIPs must contain adopted RACT regulations, ce rtifications where appropriate that existing provisions are RACT, and/or negative decla rations 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 su bmission 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 appr opriate supporting information for their

RACT demonstrations.

RACT demonstrations can be made with either RACT de terminations or by certifications that previously-required RACT controls represent RACT fo r 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 pollut ion. Emission sources covered by CTGs are known as CTG sources. Some CTGs specify the mi nimum size of sources to which they apply. Where a CTG does not specify the minimum si ze of the source to which it applies, or there is no CTG for a source category, states are r equired to apply RACT to sources in

nonattainment areas th2at exceed that area’s statut ory major stationary source threshold for its ozone nonattainment classification. Therefore, sin ce the Ventura County Air Pollution Control District (VCAPCD or “District”) is classifi ed a “serious” ozone nonattainment area, a2014 RACT SIP June 10, 2014 Page 22 of 43

major source is defined as one with the potential t o emit greater than 50 tons per year of volatile organic compounds (VOC) and/or nitrogen ox ides (NOx).

Documents useful in establishing RACT include CTGs, Alternative Control Techniques (ACT) guidance, Maximum Achievable Control Technolo gy (MACT) standards, New Source Performance Standards (NSPS), California Sug gested Control Measures (SCM) and RACT/Best Available Retrofit Control Technology (BA RCT) determinations, regulations adopted in other Districts, and guidance and rules developed by other state and local agencies.

RACT EVALUATIONS

Staff evaluated all District VOC 2 and/or NOx prohibitory rules that apply to CTG sou rce 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 we re not compared to CTG requirements again. 3 However, since some CTGs have not been updated fo r many years, staff compared District rules to rules adopted by other air distri cts 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 be low discuss the comparisons and provide

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

RULE 59: ELECTRIC POWER GENERATING EQUIPMENT – OXI DES OF NITROGEN EMISSIONS (Last Revised 7/15/1997)

Rule 59 reduces NOx emissions from electric power g enerating 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 Rul e 1135 in the South Coast Air Quality Management District (SCAQMD), which is designated a n “extreme” ozone nonattainment area. Although Rule 1135 is still in effect, it co uld 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 cre dits regularly trade at values greater than $4,000 per ton of NOx, which significantly exc eeds the inflation-adjusted RACT threshold of approximately $1,990 per ton of NOx em issions reduced. The April 2014, 12- month rolling average price for one ton of NOx RECL AIM credits was $2,009 (the most recent data available).

2 District rules use the terms reactive organic comp ounds or ROC to refer to substances the EPA conside rs VOC.

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

Revision certified that the District's rules met EP A's CTGs issued between 2006 and 2008 and re-certif ied that all major non-CTG sources of VOC or NOx were covere d by RACT Rules.2014 RACT SIP June 10, 2014 Page 23 of 43

The San Joaquin Valley Air Pollution Control Distri ct (SJVAPCD) does not have a rule specifically limiting emissions of NOx from electri c power generating equipment. The SJVAPCD rule that applies to boilers in general, Ru le 4306, limits NOx emissions based on heat input rather than net power output. Conductin g 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 AERA TION (Adopted 7/16/1991)

Rule 62.6 reduces ethylene oxide emissions from ste rilizers using ethylene oxide. The two known, permitted facilities that employ ethylene ox ide sterilizers in Ventura County have permit limitations on usage below the RACT applicab ility 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 sourc es 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 Re vised 4/1/2009)

Rule 70 reduces reactive organic compound (ROC) emi ssions from the storage and transfer of gasoline at bulk plants, terminals, and vehicle dis pensing 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 vapo r recovery system standards and is responsible for certifying systems to meet those st andards. California’s local air districts have the primary authority for regulating gasoline dispe nsing facilities under vapor recovery rules. CARB implemented enhanced vapor recovery requiremen ts during the 10 years starting in 2001. Bay Area Air Quality Management District (BA AQMD) amended its rules applicable to gasoline bulk terminals and plants, Rules 8-33 a nd 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 consider ed RACT and since the sources in the VCAPCD are smaller than those in the BAAQMD, the co st per ton would likely be higher.

Rule 70 was last updated on March 10, 2009. The Ma rch 2009 revision added exemptions for fleets using onboard refueling vapor recovery a s recommended by EPA. CARB stated in correspondence dated July 31, 2009 that they had re viewed the revised Rule 70 and had no comments. In addition, EPA published a direct fina l rule in the Federal Register (Vol. 76, No. 20, pages 5277-5280 dated January 31, 2011) tha t approved revisions to the District

4 Environmental Protection Agency Combined Heat and Power Partnership Program, “Technology Characterization: Steam Turbines”, December 2008, P age 8. Accessed Feb. 18, 2014 at http://www.epa.gov/chp/documents/catalog_chptech_st eam_turbines.pdf. A lower efficiency would give a less conservative conversion, indicating that the Rule 5 9 limit is stricter than the Rule 4306 limit.2014 RACT SIP June 10, 2014 Page 24 of 43

portion of the SIP that included the latest revisio ns to Rule 70. No specifications or performance standards with effective dates after 20 09 have been issued. Therefore Rule 70 meets RACT and no changes are required at this time

.

RULE 71.1: CRUDE OIL PRODUCTION AND SEPARATION (La st 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 gr eater 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 sys tem on all tanks not eligible for an exemption, where Rule 1178 allows a variety of floa ting 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, includin g demonstration that fewer than 6% of over 1,000 permitted tanks in the District are exempt fr om 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 org anic 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 constituent s, 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 permi ts 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 exist ing 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 w hich 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 LI QUIDS (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 a ny gasoline storage container with a capacity equal to or less than 40,000 gallons, or t o any other storage container with a capacity equal to or less than 5,000 gallons.

SCAQMD Rules 463 (amended 11/4/2011) and 1178 (amen ded 4/7/2006) and SJVAPCD Rule 4623 (amended 5/19/2005) apply to similar equi pment as Rule 71.2. Rule 71.2 includes an exemption for tanks <5,000 gallons, while Rule 4 623 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 petroleum2014 RACT SIP June 10, 2014 Page 25 of 43

facilities with greater than 20 tons of VOC emissio ns reported in the year 2000 and to tanks with capacities greater than 19,815 gallons. The r ules contain many similar provisions and requirements for tanks containing volatile organic liquids. The rules all have minor differences in the detailed requirements. The prov isions for fixed roof tanks are equivalent in all of the above-mentioned rules – a pressure-vacuu m relief valve or vapor recovery system. Most of the differences relate to floating roof tan ks. In some cases, the floating roof tank requirements in Rule 71.2 are stricter than the oth er districts’ rules while the other districts’ rules have stricter requirements in other details.

The permitted emissions of the six existing floatin g 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 analys is of Rule 71.2, including demonstration

that additional controls on these tanks would not b e cost effective. Compliance with the existing rule brings emissions from each of the tan ks 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. R ule 71.2 does not require revision to meet RACT.

RULE 71.3: TRANSFER OF REACTIVE ORGANIC COMPOUND L IQUIDS (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 provis ions 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 Rul e 4624 (amended 12/20/2007) apply to similar equipment as Rule 71.3. (Note: S ince Rule 71.3 does not apply to the transfer of gasoline, the provisions of Rule 462 th at apply to gasoline storage and transfer are covered under District Rule 70.) Although the vapo r destruction efficiency requirements are different, all existing sources in Ventura County u se 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 va por 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 facilitie s 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 d o 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 approp riate. The staff report for the 1990 revision of Rule 71.3 shows the addition of the 150,000-gall on 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 liqui ds with MRVP below 0.5 psia, while Rules 462 and 4624 exempt liquids with true vapor p ressure less than 1.5 psia. Therefore, Rule 71.3 meets RACT and does not require revision at this time.2014 RACT SIP June 10, 2014 Page 26 of 43

RULE 71.4: PETROLEUM SUMPS, PITS, PONDS AND WELL C ELLARS (Last Revised 6/8/1993)

Rule 71.4 reduces ROC emissions from sumps, pits, p onds and well cellars at facilities where crude oil or petroleum material is produced, gather ed, separated, processed, or stored. SCAQMD Rule 1176 (amended 9/13/1996) and SJVAPCD Ru le 4402 (amended 12/15/2011) apply to similar equipment as District Rule 71.4.

Rule 71.4 requires covers on allowed sumps that cov er 90% of the liquid surface area. The SCAQMD and SJVAPCD rules both require covers on sum ps that have very limited gaps at the edges. Otherwise they must cover the liquid co mpletely and have no open hatches, etc. However, Rule 71.4 includes a provision that the co ver must not leak, with a leak defined in Rule 71 as 10,000 ppm ROC as methane above backgrou nd. This provision effectively restricts ROC-containing liquid exposure to the atm osphere and limits emissions by limiting ROC concentrations in exposed air. In addition, Ru le 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 th is time.

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

Rule 71.5 reduces ROC emissions from glycol dehydra tors anywhere natural gas is dehydrated. SJVAPCD Rule 4408 (adopted 12/19/2002) applies to t he same type of equipment as Rule 71.5. The rules are essentially equivalent, but Ru le 71.5 has a lower exemption threshold so it applies to all glycol dehydrators in the Distric t. SCAQMD Rule 1148.1 (adopted 3/5/2004) has a similar 95% control requirement on systems ha ndling produced gas, but SCAQMD does not specifically regulate glycol dehydrators. Sinc e Rule 71.5 is equivalent to the SCAQMD and SJVAPCD rules, Rule 71.5 meets RACT and does no t 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 manufactur es any architectural coating for use within the District, as well as any person who applies or soli cits the application of any architectural coating

within the District. Since EPA has not issued a CTG for architectural co atings, RACT is required for major sources only. The sources subje ct to Rule 74.2 do not exceed the majorsource threshold of 50 tons ROC per year and theref ore Rule 74.2 is not required to meet RACT requirements.

RULE 74.3: PAPER, FABRIC AND FILM COATING OPERATIO NS (Last Revised 12/10/1991)

Rule 74.3 reduces ROC emissions from any applicatio n 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 a s 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% overall2014 RACT SIP June 10, 2014 Page 27 of 43

• Rule 74.3 includes a maximum equivalent emission li mit 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 r estrictive 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 efficienci es 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 applicatio n methods (roll and dip coating). New sources with significant potential emissions will b e 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 applicatio n. Rule 74.4 is equivalent to the cutback asphalt restrictions in other air districts in Cali fornia. All reviewed rules prohibit the use of cutback asphalts with greater than 0.5% organic com pounds with boiling points less than 500 °F. Some rules, including Rule 74.4, have exemptio ns for material used at temperatures less than 50 °F. This rule continues to satisfy RACT an d 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 so lvent dry cleaning operations through emission control, filtration equipment, and operati ng requirements.

SCAQMD Rule 1102 (amended 11/17/2000) and SJVAPCD R ule 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 t he addition of a leak inspection and leak repair cycle information label requirement. Rule 1 102 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 sp ecific 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 re view of District permits indicated one transfer machine remains operating in Ventura Count y. This machine is located in a small retail shop and has permitted potential emissions o f less than 1.7 tons ROC per year. However, CTG (EPA-450/3-82-009 1982/09) only applie s 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 June 10, 2014 Page 28 of 43

Any new petroleum solvent dry cleaning operations w ith 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 RAC T 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 so lvent 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 an y dry cleaning equipment not using perchloroethylene solvent. SJVAPCD Rule 4672 appli es 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 sp ecific leak check and repair requirements or allowances for operating leaking equipment. Rul e 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 Di strict permits indicated no transfer machines using synthetic solvent remain operating i n Ventura County. Therefore Rule 74.5.2 meets RACT and does not require an update at this t ime.

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

Rule 74.6 reduces ROC emissions from surface cleani ng conducted outside of degreasing tanks (e.g., hand wipe cleaning, cleaning with hand held 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 oper ations. 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 o perations 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 ha ve similar requirements for control device efficiency when using non-compliant solvents, excep t 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 tha t vary only slightly between them but no other significant differences exist.

The District’s 2009 RACT SIP submittal included a d etailed evaluation of Rule 74.6. According to the 2009 evaluation, all of the indust rial solvent cleaning operations in Ventura County meet CTG control recommendations, or fall wi thin the exclusions outlined in the guidelines. For example, the CTG for Industrial Cl eaning 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 re quirements as recommended by the2014 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 R evised 11/11/2003)

Rule 74.6.1 reduces ROC emissions from batch loaded vapor degreasers by specifying equipment and operating practice requirements. SCA QMD 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 c urrently 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 RAC T 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 R evised 10/10/1995)

Rule 74.7 reduces ROC emissions through operational and inspection requirements at petroleum refineries and chemical plants. Historic ally, only one petroleum refinery and only a few chemical plants have operated in Ventura Coun ty. 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. F acility #07519 is permitted to emit 2.5 tons of ROC per year from all facility sources, includin g 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, WAST EWATER SEPARATORS AND PROCESS TURNAROUNDS (Last Revised 7/ 5/1983)

Rule 74.8 reduces ROC emissions from refinery vacuu m producing systems, wastewater separators, and process turnarounds at petroleum re fineries. Historically, only a single petroleum refinery operated in the county. The pet roleum refinery has not operated since 1984. Rule 74.8 applies only to petroleum refineri es. Therefore, Rule 74.7 does not apply to any existing sources in the county and is not requi red to meet RACT.

RULE 74.9: STATIONARY INTERNAL COMBUSTION ENGINES (Last Revised 11/8/2005)

Rule 74.9 reduces NOx emissions from stationary spa rk-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 subjec t to the provisions of Rule 74.16.

SCAQMD Rule 1110.2 (amended 9/7/2012) and SJVAPCD R ule 4702 (amended 11/14/2013) regulate sources similar to those regul ated by Rule 74.9. The emission limits in Rule 1110.2 are significantly stricter than those i n 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 al lows some facilities to defer full compliance until 2017. In addition, Rule 4702 incl udes a fee option for facilities unwilling to comply with the stricter limits. The fees are capp ed at the Carl Moyer cost effectiveness threshold which is currently a weighted cost of $17 ,380 per ton of combined pollutants2014 RACT SIP June 10, 2014 Page 30 of 43

reduced. Of this amount, approximately 45% is assi gned to NOx emissions, meaning the Carl Moyer cost effectiveness for NOx is approximat ely $7,820 per ton.

Rule 74.9 exempts agricultural (AG) engines and eng ines used in oilfield drilling operations. Oilfield drilling engines are not exempt from the r ule 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 ec onomically 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 Ti er IV engines. Rule 4702 includes separate emission limits for spark-ignited AG engines and re gulates compression-ignited AG engines the same as other compression-ignited engines. Alt hough AG engines are exempt from Rule 74.9, the District requires registration of AG engi nes to track compliance with the Air Resources Board Air Toxic Control Measure (ATCM) fo r diesel particulates and documents spark ignited engines for emissions inventory purpo ses. 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 re ach 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 GA S PRODUCTION AND PROCESSING FACILITIES (Last Revised 3/10/1998)

Rule 74.10 reduces ROC emissions through operationa l and inspection practices and procedures to limit fugitive gas leaks at crude oil and gas production facilities, pipeline transfer stations, and natural gas processing facil ities.

SJVAPCD Rule 4409 (amended 4/20/2005) regulates sou rces similar to those regulated by Rule 74.10. Rule 4409 is essentially the same as R ule 74.10, with similar thresholds for leak classification and similar time requirements for re pairs (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 so urces; 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 e mission reductions. First, sources are required to employ a Leak, Detection and Repair (LD AR) Program to find and fix leaking components. Second, the rule allows District inspe ctors 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 dramatical ly increases rule compliance and provides an incentive for sources to undertake a diligent LD AR program to avoid potential violations. Rule 74.10 therefore meets RACT and does not requir e an update at this time.2014 RACT SIP June 10, 2014 Page 31 of 43

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

Rule 74.11 reduces NOx emissions from residential w ater heaters and applies to residential water heaters, distributers and installers. The ru le’s provisions are essentially the same as SCAQMD Rule 1146.2 (amended 5/6/2006) and SJVAPCD R ule 4902 (amended 3/19/2009). There is no CTG applicable to the sources covered b y Rule 74.11 and there are no known major sources of NOx subject to this rule in the Di strict. 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 BOILER S (Last Revised 9/11/2012)

Rule 74.11.1 is a point-of-sale rule that reduces N Ox emissions from large water heaters and small boilers that are sold, offered for sale, or i nstalled in Ventura County through certain requirements and limits.

SCAQMD Rule 1146.2 (amended 5/5/2006) and SJVAPCD R ule 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 ru les have equivalent emission limits as ppm NOx in source exhaust, although the rules vary in e xpression of limits based on heat input or heat output. Rule 1146.2 includes additional requi rements that require existing sources more than fifteen years old be retrofitted or replaced i f they do not meet emission limits that were effective January 1, 2000. Moreover, since the SCA QMD is classified an “extreme” nonattainment area, they must go beyond RACT requir ements 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 t o 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 PRO DUCTS (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 requirem ents. 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 mo stly 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 d etailed evaluation of Rule 74.12 and

includes additional details on how the rule meets t he 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 MANUF ACTURING OPERATIONS (Last Revised 9/11/2012)

Rule 74.13 reduces ROC emissions from the manufactu ring, assembling, coating, masking, bonding, paint stripping, and surface cleaning of a erospace components and the clean-up of equipment associated with these operations.2014 RACT SIP June 10, 2014 Page 32 of 43

SCAQMD Rule 1124 (amended 9/21/2001) and SJVAPCD Ru le 4605 (amended 6/16/2011) apply to sources similar to those subject to Rule 7 4.13. Rule 74.13 limits the emissions of ROC from the application of coatings or adhesives o n aerospace components. This rule contains limits on the ROC content of coatings, adh esives and cleaners used at aerospace component manufacturing operations. The ROC contro l requirements of this rule are equivalent to SCAQMD Rule 1124, Aerospace Assembly and Component Manufacturing Operation, with a few variations in limits for spec ialty coatings or adhesives. In addition, Rule 74.13 requirements exceed those of the EPA’s A ir Toxic Rule 40 CFR Part 63 Subpart

GG - National Emission Standards for Aerospace Manufactu ring and Rework Facilities

, dated December 8, 2000.

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

content limits in the CTG. District staff determin ed 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 sour ces 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 appl ies 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 ti me.

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

Rule 74.14 reduces ROC emissions from operations th at manufacture products from or otherwise use polyester resin material. ROC emissi ons from this manufacturing process are controlled by limiting loss rate, monomer ROC conte nt, 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 th is 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 operat ions, 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 Rul e 4320 (amended 10/16/2008) apply to sources similar to those subject to Rule 7 4.15. Rule 74.15 prohibits NOx and CO emissions in excess of 40 ppm and 400 ppm, respecti vely, 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 sourc es. 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 t o 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 $10,1 00 to $24,900 per ton for units complying2014 RACT SIP June 10, 2014 Page 33 of 43

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 atmo spheric 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 infl ation-adjusted 2013 dollars. This

indicates the current cost effectiveness of these t echnologies exceeds RACT guidelines. Since the baseline emission limits and compliance o ptions 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 PROCES S 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 R ule 4320 (amended 5/19/2011) apply to sources similar to those subject to Rule 7 4.15.1, 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 sour ces with annual heat input greater than

1.8 x 10 9 Btu. Both Rule 1146.1 and Rule 4320 include simil ar limits as baseline limits for all subject units not eligible for a low use exempt ion. All three rules include a compliance option for units with total annual fuel use less th an 1.8 x 10 9 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 re quirements.

Rule 1146.1 includes much stricter NOx limits on al l 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 re duced. These cost effectiveness values are far beyond the cost effectiveness guidelines fo r RACT of approximately $1,990 per ton of NOx reduced in inflation-adjusted 2013 dollars. Ru le 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 t he 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 oilfi eld 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 t he drilling site makes electric drilling economically infeasible. In cases where the Distri ct grants such an exemption, Rule 74.16 requires the diesel engines used in oilfield drilli ng rigs to meet NOx limits equivalent to Tier 1 diesel engines. No oil well drilling rigs c urrently hold a District Permit to Operate. To obtain a Permit to Operate, oil well drilling engin es would have to comply with more stringent BACT requirements pursuant to Rule 26, Ne w 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 r igs if they are registered under the statewide2014 RACT SIP June 10, 2014 Page 34 of 43

Portable Equipment Registration Program (PERP). As a result, all oil well drilling rigs operating in Ventura County have opted to comply wi th the PERP regulation instead of obtaining a District air permit. Therefore, for al l 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 (Las t Revised 2/9/1999)

Rule 74.17.1 reduces fugitive ROC emissions from mu nicipal solid waste landfills by means of landfill gas collection and control systems. Al l 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. SCAQM D Rule 1150.1 (amended 4/1/2011) and SJVAPCD Rule 4642 (amended 4/16/1998) do not co ntain more stringent requirements. Therefore, Rule 74.17.1 meets RACT and no changes a re required at this time.

RULE 74.18: MOTOR VEHICLE AND MOBILE EQUIPMENT COA TING OPERATIONS (Last Revised 11/11/2008)

Rule 74.18 limits ROC emissions from the applicatio n 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 conten t limits on cleaners used for surface preparation and application equipment cleanup.

The California Air Resources Board amended the stat ewide 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 in ks, fountain solutions, coatings, adhesives, and cleaners used at graphic arts operat ions through limits on the ROC content of inks, coating, adhesives, fountain solutions, and s olvent cleaners. The District’s 2009 RACT

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

how the rule meets the 2006 CTG for this source cat egory. 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. T he 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 o f the rule, SCAQMD Rule 1171 (amended 5/1/2009). The requirements of Rule 74.19 meet RAC T and no further changes are required.

RULE 74.19.1: SCREEN PRINTING OPERATIONS (Last Rev ised 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 speci fies 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 pres sure requirements. There is no CTG2014 RACT SIP June 10, 2014 Page 35 of 43

for this source category and there are no major sou rces in Ventura County. Therefore, RACT analysis and RACT compliance for this rule are unne cessary.

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

Rule 74.20 reduces ROC emissions from the use of ad hesives, sealants, adhesive primers, sealant primers and cleaning solvents used at bondi ng operations. Rule requirements limit ROC emissions by limiting the ROC content of adhesi ves, sealants, primers, and cleaners.

The ROC control requirements of this rule are equiv alent 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 lim it 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 limi ts 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 m aterials if the source uses add-on controls with overall removal efficiency of 85%, wh ich is equivalent to or stricter than the control requirement for Rule 1168 (80% overall cont rol) 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 o f 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 wou ld 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 concen tration limits. This rule does not apply to sources in a CTG category and there are no major so urces of ROC in Ventura County subject to this rule. Therefore, RACT analysis and RACT co mpliance for this rule are unnecessary.

RULE 74.22: NATURAL GAS-FIRED, FAN TYPE CENTRAL FU RNACES (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. The re 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 tu rbines with rated output greater than 0.3 MW fueled with gaseous or liquid fuels. This appli cability limit is the same as SCAQMD Rule 1134 (amended 8/8/1997) and SJVAPCD Rule 4703 (amended 9/20/2007). There are2014 RACT SIP June 10, 2014 Page 36 of 43

18 existing turbines in the District subject to Rul e 74.23. Half of the existing turbines are exempt based on a limit of less than 200 annual hou rs of operation. Eight (8) of the remaining turbines are limited by air permit condit ions to BACT emission levels. The final remaining unit has a specific permit limit due to i ts configuration and inability to costeffectively install add-on controls such as selecti ve 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 Revise d 9/11/2012)

Rule 74.24 reduces ROC emissions from coating and c leaning solvents used to coat marine or fresh water vessels, excluding boatyard repair faci lities and marinas. Rule requirements limit ROC emissions by limiting the ROC content of topcoa ts and primers. Emissions of ROC from cleaners are also controlled by limiting the R OC content of surface prep cleaners and application equipment cleaners.

The ROC control requirements of this rule are equiv alent to South Coast AQMD Rule 1106 (amended 1/13/1995) with some minor differences. R ule 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 COMMERCIA L 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 bo atyard repair facilities and marinas. This rule also contains a sales prohibition for noncompl ying coatings sold at marine stores that sell pleasure craft coatings. Rule requirements limit R OC emissions through ROC content limits on topcoats and primers. Emissions of ROC from cle aners are also controlled by limits on the ROC content of surface prep cleaners, the ROC c omposite vapor pressure of cleaning solvents, and requiring the use of enclosed spray g un washers. Also, this rule requires use of high transfer efficiency spray equipment such as HV LP spray equipment.

The ROC control requirements of this rule are equiv alent to South Coast AQMD Rule 1106.1 (amended 2/12/1999) with some minor differences. S ome 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 emi ssions from those operations are not subject to the CTG.

Staff analysis of Rule 74.24.1 identified several c oating types, antifoulant coatings and certain high gloss topcoats, where the Rule 74.24.1 maximum ROC content exceeds the maximum in2014 RACT SIP June 10, 2014 Page 37 of 43

CTG Table 5. However, EPA acknowledged in a June 1 , 2010 memorandum 5 that the ROC content limits in the CTG might be unacceptable to the regulated industry and states have flexibility in determining RACT. In discussions wi th EPA Region 9 staff about the RACT determination for this rule, Region 9 staff indicat ed they believed coatings meeting the CTG limits are now readily available and strongly recom mended revising Rule 74.24.1 to meet the

CTG limits to ensure the rule meets RACT for the 20 08 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. Th e inspection reports indicated both of the facilities currently use a mix of antifoulant coati ngs and one facility uses a mix of gloss topcoat coatings, some compliant with the CTG limit s 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 exemp t compounds (hereafter referred to merely as g/L) is a typographical error from the or iginal adoption of the rule. The CTG limit for this coating category is 560 g/L and it would b e difficult to consistently discern the difference between coatings with these two VOC cont ents using EPA Test Method 24.

For antifoulant coatings on other substrates, the C TG limit is 330 g/L and the Rule 74.24.1 limit is 400 g/L. One boatyard in the district use d 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 coa tings, 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 s uch coatings that comply with the 330 g/L

limit are not available. If the District lowers th e 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 a pply a compliant hard antifoulant. The additional labor would add up to $20,000 to the cos t of recoating the boat. In addition, the ablative antifoulant coatings are self-polishing, r esulting 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 topco ats (490 g/L) and two component topcoats (650 g/L). The CTG includes separate limi ts for high gloss topcoats (420 g/L, high gloss defined as ≥ 85% reflectance at 60°) and extreme high gloss top coats (490 g/L, extreme high gloss defined as ≥ 95% reflectance at 60°). While the limits and cla ssifications 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 CT G threshold in Ventura County applies topcoats as defined in the CTG. The list of topcoa ts used at the facility includes six coatings, all of which meet the CTG limit for high gloss coat ings except one. The non-compliant

5 Control Technique Guidelines for Miscellaneous Met al and Plastic Part Coatings Industry Request for Reconsideration, United States Environmental Protec tion Agency, Stephen D. Page, Director, Office of A ir Quality Planning and Standards, June 1, 2010, http: //www.noticeandcomment.com/EPA-Memo-ControlTechnique-Guidelines-for-Miscellaneous-Metal-and-Pl astic-Part-Coatings-Industry-Request-fn-38627.aspx2014 RACT SIP June 10, 2014 Page 38 of 43

coating is Awlgrip Topcoat, a two-component extreme high gloss linear polyester polyurethane coating with 650 g/L ROC content. Thi s 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 To pcoat 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 pr operties with ROC content compliant with

the CTG limits.

Staff conducted research to determine if coatings a re available to meet the CTG ROC limits and satisfy the demand for the qualities of the Awl grip 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 ju risdiction 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 a t a San Diego boatyard stated the majority of their topcoat jobs use Awlgrip Topcoat or a competi ng 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 Awlg rip provides very good technical support for their products.

Staff interviewed the Ventura County boatyard opera tor that uses the Awlgrip Topcoat. He stated the boatyard uses relatively small amounts o f 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 Imro n 2.1 HG, which is compliant with all limits at 315 g/L ROC content. However, he believe s 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 th e Southern California market. He stated the coating was very difficult to apply properly an d 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-applicat ion of the coating, up to four times in some cases. The increase in coating applications result ed in increased emissions due to additional coating use.

The Ventura County boatyard operator stated that al l yacht customers request Awlgrip Topcoat. He said many yacht owners bring their boa ts 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 b y lowering the ROC limit in Rule 74.24.1, he believes the yacht owners will take their busine ss elsewhere (such as Santa Barbara or San Diego). He stated his business has grown due to th e ability to provide the service demanded by his clients. The commercial operators demand ab lative 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 c ompetition, 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.2014 RACT SIP June 10, 2014 Page 39 of 43

Awlgrip topcoats are very popular, but competing pr oducts include Alexseal, Sterling, DuPont Imron, and International Perfection paint sy stems. The Awlgrip website lists a product (Awlgrip HS Topcoat) that claims similar pe rformance to the two-component linear polyurethane Awlgrip Topcoat. Awlgrip HS Topcoat i s a three-component system with the mixed coating VOC content of 420 g/L which is compl iant 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 generate d a significant reputation within the pleasure craft community.

Staff discovered a single water-based linear polyur ethane topcoat, System Three WR-LPU Linear Polyurethane Topcoat. The Material Safety D ata Sheet for this coating lists an ROC content of 105-120 g/L for the polyurethane dispers ion 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 topc oats 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 C TG VOC limits. These coatings enjoy a strong positive reputation in the pleasure craft co mmunity with a reputation for superior appearance, durability and service life. The compe ting aliphatic polyurethane topcoat products from DuPont and International Paint Compan y have a different chemistry which yields lower performance on original gloss, gloss r etention, and durability (resistance to damage such as scuffs, scratches and chips).

Staff contacted a representative of Awlgrip and ask ed about a compliant version of the linear polyurethane Awlgrip Topcoat G/H. He stated the de velopment of a lower VOC linear polyester polyurethane topcoat suitable for spray a pplication was ongoing. He stated the current Awlgrip Topcoat G/H is compliant with the 4 90 g/L limit when mixed for hand application (brush or roll) due to the lower VOC co ntent of the activator component used for hand application process. However, the coating mix ed for spray application remains noncompliant. The other linear polyester polyurethane topcoats on the market also exceed the CTG ROC content limits. Therefore, there is justif ication for retaining the 650 g/L VOC limit on two component topcoats currently in Rule 7 4.24.1.

Rule 74.24.1 achieves greater emission reductions t han would occur if the District adopted the CTG limits alone. The CTG, with its applicabil ity threshold of 2.7 tons ROC per year, applies only to one or possibly two sources in Vent ura County with permitted (controlled) annual ROC emissions totaling up to 15.5 tons. Rul e 74.24.1 applies to two or three additional sources with permitted (controlled) emis sions totaling up to 6.6 tons ROC per year due to the rule’s lower applicability threshold (20 0 lb/year vs 2.7 tons per year for the CTG). The CTG states on page 40 the recommendations in th e CTG will reduce emissions by approximately 35%. Therefore, the expanded applica bility of Rule 74.24.1 generates emission reductions of approximately 3.6 tons ROC p er year.

In addition, Rule 74.24.1 applies to coatings appli ed to pleasure craft parts and structures made of wood. Since the permitted facilities are n ot required to track the amount of coatings used on wood substrates, it is difficult to determi ne the impact of this aspect of the rule. Rule 74.24.1 includes a sales prohibition to reduce emis sions from non-permitted users of pleasure craft coatings (e.g. individual hobbyists), a sourc e also not subject to the CTG requirements.2014 RACT SIP June 10, 2014 Page 40 of 43

According to a 1992 survey used in the development of the rule, approximately 19% of total marine coatings sold in Ventura County were sold re tail and not applied by permitted sources. Since the total controlled permitted inventory is 1 8.9 tons ROC per year, the controlled nonpermitted inventory should be approximately 4.4 ton s 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 wo uld 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 e missions than the baseline

recommendation in the CTG.

Rule 74.24.1 was originally adopted in November 199 8 with the same ROC content limits (with the exception of the aluminum substrate antif oulant coatings) that were later included in the CTG. Due to feedback from the regulated commun ity, the District revised Rule 74.24.1 in January 2002. The amendments included the curre nt ROC limits on topcoats and antifoulant coatings along with new restrictions on spray gun cleaning operations and cleaning solvent vapor pressure to offset the incre ase in emissions from the relaxed ROC content limits. According to the January 8, 2002 St aff 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. Howev er, this increase was offset by a reduction of ROC emissions of 1,900 pounds due to t he new restrictions on spray gun cleaning and solvent vapor pressure. Therefore, th e current requirements of Rule 74.24.1 reduce emissions by an addition 0.5 tons per year o f ROC beyond the baseline CTG requirements.

On August 13, 2002, EPA published a direct final ru le in the Federal Register 6 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 reas onable further progress or attainment. The

net effect of amendments to the rule is to reduce R OC emissions.”

The Federal Register notice refers to the April 200 2 EPA Technical Support Document 7
(TSD) prepared for the notice of direct final rulem aking. The TSD notes that EPA had not, at that time, produced a CTG for pleasure craft coatin g 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 f inds no deficiencies in Rule 74.24.1. Although this EPA action occurred prior to the publ ication 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 C TG 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), p p. 52611 -

52615.

7 J. S. Wamsley, Technical Support Document for EPA’ s Notice of Direct Final Rulemaking, USEPA Region I X Air Division, April 2002. Accessed May 6, 2014. L ink to TSD available at http://yosemite.epa.gov/R9/r9sips.nsf/AgencyProvisi on/8243BA552E89656088256C17007BDE31?OpenDocum

ent2014 RACT SIP June 10, 2014 Page 41 of 43

74.24.1 as one of the three California districts wi th pleasure craft coating rules. Although the SCAQMD rule was noted as the strictest, the CTG doe s not indicate EPA believed Rule 74.24.1 did not satisfy RACT.

As stated in its introduction, the CTG provides rec ommendations for state and local air pollution control agencies to consider in determini ng RACT. Rule 74.24.1 applies to a broader category of source operations than the plea sure craft coating operations covered by the CTG, has a lower applicability threshold, and i ncludes a sales prohibition to reduce emissions from non-permitted users of pleasure craf t 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 incr ease 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 reducti ons 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 emiss ions 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 th is rule are unnecessary.

RULE 74.26: CRUDE OIL STORAGE TANK DEGASSING OPERA TIONS (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 cr ude oil or produced water. When such tanks are undergoing maintenance or being decommiss ioned, 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 an d 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 11 49 (amended 5/2/2008) has a lower threshold of ROC for degassed tanks, 5,000 ppmv ver sus 10,000 ppmv for Rule 74.26. However, the 2004 AFM analysis states the increment al 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 1 149 prior to its amendment and a cost effectiveness threshold of $13,159 per ton of ROC r educed, much higher than what would be considered for RACT in Ventura County.

SCAQMD also lowered the tank size applicability thr esholds for Rule 1149 in its 2008 revision. The District’s 2004 AFM analysis also ad dressed the tank size applicability

threshold cost effectiveness for Rule 74.26. Assum ing a ROC vapor density of 0.004 lb/gallon of tank volume and a control efficiency o f 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 Rule2014 RACT SIP June 10, 2014 Page 42 of 43

1149, would have worse cost effectiveness due to th e 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 D EGASSING 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 cap acity 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 ma intenance 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 an d 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 11 49 (amended 5/2/2008) has a lower ROC threshold, 5,000 ppmv versus 10,000 ppmv for Ru le 74.27. However, the 2004 AFM analysis states the incremental cost to control emi ssions 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 t o 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 hig her than what would be considered RACT in Ventura County.

SCAQMD also lowered the tank size applicability thr esholds 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 estima tes of $400 (fixed cost) plus $0.04 per gallon of tank size for degassing, the cost effecti veness 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 s tringent than RACT. Since the cost per pound of ROC removed will increase as tank size get s 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 mee ts 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 roofi ng equipment and operations by requiring close fitting container lids and temperat ure limits. Rule 74.28 applies to equipment used for melting, heating or holding asphalt or coa l 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 emiss ions are minimized during the aeration, treatment or removal of soil contaminated with petr oleum fuel. Rule 74.29 applies to soil2014 RACT SIP June 10, 2014 Page 43 of 43

decontamination equipment and handling of contamina ted soil. There is no CTG for this equipment or operations and there are no major sour ces 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 applica tion 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 me ets 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 s ubstitution of high-ROC metalworking fluids with low-ROC fluids, including medium napthe nic oils, paraffinic oils, vegetable oils, synthetic or semi-synthetic oils, or water-reducibl e fluids. There is no CTG for this equipment or operations and there are no major sour ces in Ventura County. Therefore, RACT analysis and RACT compliance are unnecessary a t this time.

### ATTACHMENT I V

JUNE 10, 2014 VENTUR A COUNTY AIR POLLUTO N 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 Environment al 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 S IP Revision meets the requirements of the federal Clean Air Act for a ser ious 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 ma jor, 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 subjec t to certain CTGs and thus

those CTGs qualify for findings to that effect call ed Negative

Declarations.

3. Approve and Adopt a resolution (Attachment A) a dopting 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 ce rtified minute orders and an affidavit of publication of the public hearing noti ce for the proposed action to the

Air Pollution Control District.

5. Direct staff to forward the signed resolution a nd the final 2014 RACT SIP

Revision to the California Air Resources Board for transmittal to the U.S. Environmental Protection Agency as a proposed revis ion to the California State Implementation Plan for ozone under the federal Cle an 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 dem onstrate that all District rules applicable to ozone precursor emissions meet or exc eed 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 r equirements under the federal Clean Air Act. Ventura County is designated a serious no nattainment area for the federal 8- hour ozone standard. If your Board approves the 20 14 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 impl ement RACT for sources that are subject to CTG. CTGs are documents issued by the E PA that define RACT for major anthropomorphic sources of VOC and NOx, both of whi ch are ozone precursor air pollutants. RACT is defined as the lowest emission s limitation that a particular source is capable of meeting by application of control techno logy 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 emis sions are controlled to a “reasonable” extent, but not necessarily to the more stringent b est available control technology (BACT) or lowest achievable emission rate (LAER) le vels 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 r eviewing all available CTGs and comparing them to District air pollution control ru les 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 emis sions inventory systems, and knowledgeable staff of the District’s permit and en forcement divisions.2014 RACT SIP Revision

June 10, 2014 Page 3



### Following identification of District rules to be ev aluated for the RACT SIP, District staff

made determinations as to whether the rules meet RA CT standards for air pollutant emission reductions. The determinations were prima rily based on comparing the rules with similar rules adopted by other air pollution c ontrol 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 evaluatio ns 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 h igher ozone nonattainment classifications contain stricter requirements than District rules f or similar sources, staff evaluated the cost effectiveness of those rules for application a s 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 th at 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 inf lation-adjusted cost threshold for NOx set by EPA and the BACT cost effectiveness thre shold for VOC set by the District to determine if a technology was economically feasi ble for application as RACT in Ventura County.

The District’s 2014 RACT SIP evaluations are presen ted in Attachment B-1 (2014 RACT SIP Analyses), starting on page 21 of 43 of Attachm ent B (2014 Reasonably Available Control Technology State Implementation Plan Revisi on). The evaluations provide a

determination whether each rule meets RACT as writt en 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 applic able 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 p recursor emissions are currently subject to one or more District rules that meet RAC T.

4) The information and analyses presented in the 2 014 RACT SIP Revision meet the requirements of Sections 182(b)(2) and 182(f) of th e 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 Secti on 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 severa l 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 bou ndaries. District staff, therefore, determined that Negative Declarations documenting t hat there are no sources in the county subject to those CTGs are appropriate. More over, 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 requi rements, 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 ev aluations 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 R evision is not a project as provided for in Sections 15060(c)(3) and 15378(a) o f the CEQA Guidelines.

Public Review
The public review period for the 2014 RACT SIP Revi sion began on April 3, 2014, and ended on May 5, 2014. The District emailed 34 noti ces 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 Boa tyard Operations. EPA staff noted the ROC content limits for several coating types di d not match those for pleasure craft coatings in the CTG for miscellaneous metal and pla stic parts coating. The District responded to EPA’s comments by expanding the RACT a nalysis of Rule 74.24.1 to

demonstrate that the emission reductions achieved b y Rule 74.24.1 exceeded those that would occur if the District had adopted the baselin e CTG requirements.

Rule 74.24.1 as written results in 65 percent great er emission reductions than would be achieved using the baseline CTG recommendations. T his is equivalent to 6.5 tons ROC emissions per year avoided due to the broader appli cability and additional provisions in the existing rule. For this reason, along with tec hnology issues discussed in the analysis,

District staff concludes the current rule meets RAC T and does not need to be revised.

### ATTACHMENT A

A RESOLUTION OF THE VENTURA COUNTY AIR POLLUTION CO NTROL

BOARD OF DIRECTORS APPROVING AND ADOPTING THE 2014

REASONABLY AVAILABLE TECHNOLOGY STATE IMPLEMENTATIO N

PLAN REVISION FOR VENTURA COUNTY, CA

### A RESOLUTION OF THE VENTURA COUNTY AIR POLLUTION CO NTROL

BOARD OF DIRECTORS APPROVING AND ADOPTING THE 2014

REASONABLY AVAILABLE TECHNOLOGY STATE IMPLEMENTATIO N

PLAN REVISION FOR VENTURA COUNTY, CA

WHEREAS , Ventura County, CA is classified a serious nonatt ainment area for the

federal 8-hour ozone standard in accordance with th e 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 C ounty Air Pollution Control District (District) to adopt air pollution control plans, ru les and regulations for volatile organic compounds (VOC) and nitrogen oxides (NOx) emissions in order to bring Ventura County into attainment with national and state ambi ent air quality standards for ozone as expeditiously as practicable; and

WHEREAS , Sections 182(b)(2) and 182(f) of the federal Clea n Air Act (42 U.S.C. §7511a, par. (b)(2) and subd. (f)) require ozone no nattainment areas designated as moderate or greater to submit a revision to the Sta te Implementation Plan (SIP) for implementation of reasonably available control tech nology (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 stationar y 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 NO x rules subject to the United States Environmental Protection Agency’s (EP A) 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 li sted 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 R ACT SIP Revision are not necessary

on the bases that there are no sources within the D istrict jurisdiction subject to the CTGs listed in Table B-2 of the 2014 RACT SIP as explain ed 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 pu blic 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 test imony 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 RA CT SIP Revision;

and

WHEREAS , the 2014 RACT SIP Revision is not a project as de fined 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 Pla n; and

FINALLY, BE IT RESOLVED , the Board directs District staff to forward this Resolution and the adopted 2014 RACT SIP Revision f or Ventura County, CA to the

California Air Resources Board for transmittal to t he EPA as a revision to the California

SIP for ozone.

APPROVED AND ADOPTED this June 10, 2014.

APPROVED AND ADOPTED this __________ day of June 20 14 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 PUBLI CATION

– PUBLIC NOTICE

### ATTACHMENT VI

NOTICE OF EXEMPTION FROM
CALIFORNIA ENVIRONMENTAL QUALITY ACT