UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA's Notice of Proposed Rulemaking

for the

California State Implementation Plan

EPA’s Evaluation of

Ventura County Air Pollution Control District, 

Reasonably Available Control Technology

State Implementation Plan Revision (2009 RACT SIP Revision)

Adopted September 15, 2009

Prepared by: Stanley Tong

January 2014
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RULE IDENTIFICATION -

Agency: Ventura County Air Pollution Control District (VCAPCD)

SIP Approved Version: Final Ventura County Air Pollution Control District 2006 Reasonably 

Available Control Technology (RACT) State Implementation Plan 

(SIP) Revision

Adopted June 27, 2006

Submitted January 31, 2007

SIP approved April 21, 2009 (74 FR 18148)

Subject of this TSD: Ventura County Air Pollution Control District 2009 Reasonably 

Available Control Technology State Implementation Plan (2009 

RACT SIP) Revision

Adopted September 15, 2009

Submitted November 17, 2009

BACKGROUND -

Volatile organic compounds (VOC) and nitrogen oxides (NOx) in the presence of sunlight can 

lead to the formation of ground-level ozone or “smog” which can result in significant impacts to 

human health and the environment. Section 182 of the Clean Air Act (CAA) requires areas that 

are classified as moderate or above for ozone nonattainment to implement reasonably 

available control technology (RACT) for specific types of sources. 

The Ventura County Air Pollution Control District (VCAPCD) falls under this requirement as it 

is classified as a serious1ozone non-attainment area under the 1997 8-hour national ambient 

air quality standard (NAAQS) for ozone (40 CFR 81.305). Under CAA § 182(b)(2) and (f), 

VCAPCD must, at a minimum, adopt RACT level controls for sources covered by a Control 

Techniques Guidelines (CTG) document and for any other major stationary source of VOC or 

NOx. 

Between 2006 and 2008, EPA issued 11 new or revised CTGs. States are required to submit 

a SIP revision in response to the CTGs within a year of the date the CTGs were finalized.2

 

1

On February 14, 2008, the California Air Resources Board (CARB) requested EPA reclassify the 8-hour ozone 

non-attainment classification for Ventura County, Sacramento Metro, and Western Mojave Desert (see 74 FR 

43654, August 27, 2009). On May 20, 2008 (73 FR 29073), EPA granted the State of California's request to 

reclassify Ventura County from "moderate" to "serious" for the 1997 8-hour ozone standard. On December 3, 2012 

(77 FR 71551) EPA published a final rule determining that Ventura County attained the 1997 8-hour ozone 

standard. EPA’s attainment determination suspended the requirements for Ventura to submit an attainment 

demonstration and associated planning SIPs related to attainment of the 1997 8-hour ozone NAAQS for so long 

as the area continues to attain the standards, but did not suspend Ventura’s obligation to meet the specific RACT

control requirements under CAA 182(b)(2) and (f). 40 CFR 51.918.

2

See 71 FR 58745 (October 5, 2006) http://www.gpo.gov/fdsys/pkg/FR-2006-10-05/pdf/E6-16485.pdf; 72 FR 

57215 (October 9, 2007) http://www.gpo.gov/fdsys/pkg/FR-2007-10-09/pdf/E7-19627.pdf; and 73 FR 58481 

(October 7, 2008) http://www.gpo.gov/fdsys/pkg/FR-2008-10-07/pdf/E8-23750.pdf.
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SUBMITTAL SUMMARY -

VCAPCD 2009 Reasonably Available Control Technology State Implementation Plan Revision 

("2009 RACT SIP") – dated September 15, 2009, adopted September 15, 2009.

The District adopted its 2009 RACT SIP on September 15, 2009 and the California Air 

Resources Board (CARB) submitted it to EPA on November 17, 2009. Ventura performed its 

2009 RACT SIP analysis based on an ozone non-attainment classification of "serious". This 

classification defines a major source as those facilities that have the potential to emit at least 

50 tons per year (tpy) of VOC or NOx.

VCAPCD's submittal included the following documents:

a. Final Ventura County Air Pollution Control District 2009 Reasonably Available Control 

Technology State Implementation Plan Revision, September 15, 2009 [hereinafter 

“2009 RACT SIP”].

b. Resolution of the Ventura County Air Pollution Control Board approving and adopting 

the 2009 Reasonably Available Control Technology State Implementation Plan Revision 

– adopted on September 15, 2009.

VCAPCD's analysis evaluated the following areas. Further discussion is provided below.

 Eleven new or revised CTGs EPA issued between 2006 and 2008

 Negative declarations

 Additional major sources identified after reclassification to "serious" nonattainment for 

the 1997 8-hour ozone standard

1. Eleven New or Revised CTGs

Industrial Cleaning Solvents

Flexible Package Printing

Flat Wood Paneling Coatings

Offset Lithographic Printing and Letterpress Printing

Large Appliance Coatings

Metal Furniture Coatings

Paper, Film, and Foil Coatings

Miscellaneous Metal and Plastic Parts Coatings

Fiberglass Boat Manufacturing

Miscellaneous Industrial Adhesives

Automobile and Light-Duty Truck Assembly Coatings

VCAPCD reviewed the above CTGs and determined it only had sources covered by the 

following three CTGs. VCAPCD’s 2009 RACT SIP indicated it either had no sources in the 

remaining 8 CTGs or emissions were below the applicability threshold of the specific CTG.
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CTG Category VCAPCD Rule 

(version cited in 

9/15/09 staff report)

Current rule SIP Status

Industrial Cleaning

Solvents

EPA 453/R-06-001

Rule 74.6 (11/11/03)

Surface Cleaning and 

Degreasing

11/11/03 Rule 74.6 was approved into the 

SIP on 10/25/05 (70 FR 61561)

Offset Lithographic

Printing and 

Letterpress Printing 

EPA 453/R-06-002

Rule 74.19 (11/11/03)

Graphic Arts

6/14/11 Rule 74.19 was amended on 

6/14/11 and approved into the SIP 

on 9/24/13 (78 FR 58459)

Miscellaneous Metal 

and Plastic Parts 

Coatings

EPA 453/R-08-003

Rule 74.12 (11/11/03)

Surface Coating of 

Metal Parts and 

Products

4/08/08 Rule 74.12 was amended 4/08/08

and approved into the SIP on 

5/24/11 (76 FR 30025)

1a RACT Evaluation for three sources:

Industrial Cleaning Solvents

The Industrial Cleaning Solvents CTG covers all industrial cleaning operations and 

highlights the following nine specific categories which are believed to be responsible for 

the majority of VOC emissions. These categories are:

1 Spray Gun Cleaning (50 percent);

2 Spray Booth Cleaning (14 percent);

3 Large Manufactured Components Cleaning (14 percent);

4 Parts Cleaning (7.0 percent);

5 Equipment Cleaning (6.9 percent);

6 Line Cleaning (3.6 percent);

7 Floor Cleaning (2.9 percent);

8 Tank Cleaning (0.82 percent); and

9 Small Manufactured Components Cleaning (0.44 percent).

The CTG recommends an applicability threshold of 6.8 kg/day (15 lb/day). Facilities 

exceeding this threshold should be subject to a VOC content limit of 50 grams per liter 

(0.42 lb/gal) for cleaning materials for each of the above nine cleaning unit operations, 

or emissions should be controlled to achieve an overall control efficiency of at least 85 

percent. 

The CTG also recommends several stationary source categories including many 

coating and printing operations be excluded from the CTG. These categories are 

generally those where the State or local regulatory agency has already adopted source 

specific prohibitory rules that include VOC limits on solvent cleaning operations.

VCAPCD Rule 74.6 – Surface Cleaning and Degreasing, applies to any person 

performing solvent cleaning activities and to any person that manufactures or supplies 

solvents for use in solvent cleaning activities in the District. Rule 74.6 limits the VOC 

content of solvents to 25 grams/liter and allows a higher VOC content limit for certain 

operations such as cleaning of uncured coatings, adhesives and inks and cleaning of 

electronic components. Rule 74.6 also allows the use of an emissions control system 
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with a combined capture and control efficiency of at least 85% as an alternative to 

meeting the Rule’s VOC content limit.

Rule 74.6 was approved into the SIP on October 25, 2005 (70 FR 61561) and we agree 

it meets the 2006 Industrial Cleaning Solvents CTG.

1b. Offset Lithographic Printing and Letterpress Printing

VCAPCD's 2009 RACT SIP concluded that Rule 74.19 – Graphic Arts, as amended on 

November 11, 2003, meets or exceeds the RACT recommendations in the 2006 CTG 

for offset lithographic printing and letterpress printing. The District's analysis states that 

while Rule 74.19's 8 percent (~80 grams/liter) VOC limit for fountain solutions is less 

stringent than the CTG's recommended limit of 5 percent (~50 grams/liter) alcohol or 

alcohol substitutes for sheet-fed offset lithographic printing, the rule contains several 

more stringent requirements than the CTG that overall makes Rule 74.19 achieve

significantly greater VOC reductions than would be achieved by the CTG alone.

VCAPCD's analysis highlights the following areas where Rule 74.19 is more stringent 

than the CTG.

CTG Rule 74.19 (11/11/03) Additional tons of VOC 

reduced by Rule 74.19 

over the CTG

Applicability >15 lb/day or 2.7 tpy >200 lb/12 mth (>0.1 tpy) 7 tpy

Exemption <110 gallons/yr Not allowed 3 tpy

Fountain Soln’ limit ~50 grams/liter ~80 grams/liter Loss of <1 tpy*

* Ventura County’s staff report states that the CTG’s 5 percent (~50 grams/liter) alcohol limit for sheet-fed 

offset lithographic printing “does not apply to sources in Ventura County because they all use alcohol 

substitutes, most commonly certain glycol ethers...and are incorporated in small quantities... to produce a 

final mixed fountain solution less than 30 g/l.”3

During EPA’s review of VCAPCD’s draft 2009 RACT SIP, we commented that SIP 

approved Rule 74.19’s limit of 8% VOC is the federally enforceable limit and that while 

facilities may be using a lower VOC content solution, that lower limit is not federally 

enforceable.4

In response to EPA’s comments, VCAPCD performed additional analysis and estimated 

that less than one ton per year emissions loss would result if their largest sources 

increased their fountain solution emissions up to the maximum allowed by Rule 74.19.5

The District also restates that overall, Rule 74.19 is more stringent than the CTG and 

achieves 10 tons more emission reductions per year than the CTG would achieve.

6 We 

 

3

Ventura County APCD 2009 RACT SIP staff report dated September 15, 2009, Attachment 2, Page 5 - 7.

4

Letter from Andrew Steckel (EPA Region IX) to Michael Villegas (VCAPCD) dated August 25, 2009.

5

Letter from Michael Villegas (VCAPCD) to Andrew Steckel (EPA Region IX) dated September 2, 2009.

6

2009 RACT SIP, Attachment 2, Page 7.
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agree with VCACPD’s analysis that Rule 74.19, as amended on November 11, 2003,

achieves greater reductions than the CTG.

On June 14, 2011, Rule 74.19 was amended to further reduce the VOC content limit for 

fountain solutions to match the 2006 CTG and to reduce the VOC content limit of 

cleaning solvents used for printing operations. The 2011 amendments were approved 

into the SIP on September 24, 2013 (78 FR 58459).

1c. Miscellaneous Metal and Plastic Parts Coatings

EPA’s Miscellaneous Metal and Plastic Parts Coatings CTG applies when the total 

actual VOC emissions exceed 15 lb/day (or 2.7 tons/rolling 12 month period) before

controls. The CTG includes, but is not limited to the coating of fabricated metal 

products, molded plastic parts, small and large farm machinery, commercial and 

industrial machinery, automotive or transportation equipment, motor vehicle 

accessories, bicycles and sporting goods, toys, railroad cars, and lawn and garden 

equipment.

Attachment 2 of VCAPCD’s 2009 RACT SIP includes two tables listing the average 

actual VOC emissions from miscellaneous metal parts coating facilities and plastic 

parts coating facilities. Table 7 lists five miscellaneous metal parts coating facilities 

covered by Rule 74.12 – Surface Coating of Metal Parts and Products. VCAPCD’s staff 

report states that one of the facilities, A-1 Truck and Equipment, specializes in coating

in-use heavy-duty government equipment and therefore, is not covered by the 

miscellaneous metal and plastic parts CTG. The remaining four facilities are covered by

the CTG and by Rule 74.12. EPA approved Rule 74.12 (as amended April 8, 2008) into 

the SIP on May 24, 2011 (76 FR 30025) as meeting the 2008 Miscellaneous Metal and 

Plastic Parts Coatings CTG.

Table 8 of VCAPCD’s 2009 RACT SIP lists five facilities which conduct plastic parts 

coatings. The 2009 RACT SIP states there are no plastic parts coating operations with 

actual emissions that exceed the CTG’s applicability threshold of 15 lb/day or 2.7 

tons/rolling 12 month period. The largest source emits 10.6 pounds per day of VOC.

7

We agree Rule 74.12 meets the 2008 Miscellaneous Metal and Plastic Part Coatings 

CTG.

2. Negative Declarations

2a. CTGs where VCAPCD has no sources

VCAPCD 2009 RACT SIP states that District staff reviewed their permit and emissions 

inventory files, consulted with knowledgeable District staff, and determined there were no 

stationary sources covered by the following four CTGs. VCAPCD also indicated it did not 

anticipate these sources in the future.

 

7

2009 RACT SIP, Attachment 2, Pages 9-10.
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CTG Source 

Category

CTG Document Title

Flat Wood 

Paneling Coatings 

EPA-453/R06-004 Control Techniques Guidelines for Flat 

Wood Paneling Coatings

Large Appliance 

Coatings

EPA-453/R-07-004 Control Techniques Guidelines for 

Large Appliance Coatings

Paper, Film and 

Foil Coatings

EPA-453/R-07-003 Control Techniques Guidelines for 

Paper, Film, and Foil Coatings

Automobile and 

Light-Duty Truck 

Assembly Coatings

EPA-452/R-08-006 Control Techniques Guidelines for 

Automobile and Light-Duty Truck Assembly Coatings 

EPA Evaluation

EPA-453/R06-004 Control Techniques Guidelines for Flat Wood Paneling Coatings.

A review of CARB's 2010 emissions inventory did not identify any flat wood paneling coating 

facilities in VCAPCD listed under SIC codes 2431 – Millwork; 2435 – Hardwood Veneer and 

Plywood; 2436 – Softwood Veneer and Plywood; or 2493 – Reconstituted Wood Products. 

We also reviewed the 2006 CTG and noted that while the CTG listed flat wood coating 

facilities in Placer County and South Coast AQMD, there were none listed in Ventura 

County.8

We are not aware of any flat wood paneling coating facilities in Ventura County APCD and 

agree with the District’s conclusion that it has no facilities covered by the 2006 Flat Wood 

Paneling Coatings CTG.

EPA-453/R-07-004 Control Techniques Guidelines for Large Appliance Coatings. 

The 2007 CTG lists the following SIC codes that may be covered by this CTG: 

3631 – Household Cooking Equipment; 

3632 – Household Refrigerators and Home and Farm Freezers; 

3633 – Household Laundry Equipment; 

3639 – Household Appliances, not elsewhere classified; 

3582 – Commercial Laundry, Dry Cleaning and Pressing Machines; 

3585 – Air Conditioning and Warm Air Heating Equipment and Commercial and Industrial 

Refrigeration Equipment; and 

3589 – Service Industry Machinery, not elsewhere classified.

We searched CARB’s emissions inventory database for the above SIC codes and did not 

identify any facilities in VCAPCD under the above SIC codes. We agree with VCAPCD’s 

negative declaration for the Large Appliance Coatings CTG.

EPA-453/R-07-003 Control Techniques Guidelines for Paper, Film, and Foil Coatings.

 

8

Control Techniques Guidelines for Flat Wood Paneling Coatings, EPA 453/R-06-004 September 2006, Appendix 

B.
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The 2007 CTG does not list any Paper, Film, and Foil Coating facilities in Ventura County.

9

The background information document for the CTG lists the following SIC codes applicable 

to paper printing. 

We searched CARB's 2008 and 2010 emissions inventory database for these SIC codes 

and determined two potential facilities, Crockett Graphics and Performance Materials Corp, 

listed under SIC codes 2653 and 3083 respectively, that may be subject to the CTG. 

Discussion with VCAPCD indicated these two facilities are not paper, film, or foil coating 

operations. The District clarified that Crockett Graphics performs lithographic and 

flexographic printing and is subject to Rule 74.19 Graphic Arts, and Performance Materials 

Corp. is an acrylic/graphite laminate manufacturer.

2653: Corrugated and Solid Fiber Boxes: 

2657: Folding Paper Board Boxes

2671: Packaging Paper and Plastics Films

2672: Coating and Laminated Paper

2673: Plastics, foil, and Coated Paper Bags

2674: Bags: Uncoated Paper and Multi Wall

2675: Die-cut Paper and Paperboard and Cardboard

2679: Converted Paper and Paper Board

2754: Commercial Printing, gravure

2761: Manifold Business Forms

3073: Plastic Aseptic Packaging

3081: Unsupported Plastics Film and Sheet

3083: Laminated Plastics Plate, Sheet, and Profile Shapes: 

3291: Abrasive Products

3497: Laminated Aluminum (metal) Foil and Leaf, Flexible Packaging

3861: Photographic Equipment and Supplies

3955: Carbon Paper and Inked Ribbons

3996: Linoleum, Asphalted-Felt-Base, and Other Hard Surface Floor Coverings 

EPA agrees there are no facilities in VCAPCD covered by this CTG.

EPA 453/R-08-006 Control Technique Guidelines for Automobile and Light Duty Truck 

Assembly Coatings

A search of CARB’s emissions inventory did not identify any automobile or light duty truck 

assembly lines in VCAPCD.

In summary, EPA reviewed CARB's 2010 emissions inventory and did not find any facilities 

covered by the above four CTGs for which VCAPCD is claiming a negative declaration.

 

9

Control Techniques Guidelines for Paper, Film, and Foil Coatings, EPA 453/R-07-003 September 2006, 

Appendix B.
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2b. CTGs where VCAPCD has sources, but are below the applicability threshold

VCAPCD determined that while it has sources in the following four CTGs categories, 

emissions from these sources are below the applicability threshold for the specific CTG. 

The District also included these CTGs in their negative declaration.

CTG Source 

Category

CTG Document Title

Miscellaneous 

Industrial 

Adhesives

EPA 453/R-08-005 Control Techniques Guidelines for 

Miscellaneous Industrial Adhesives

Flexible Package

Printing

EPA 453/R-06-003 Control Techniques Guidelines for 

Flexible Package Printing

Metal Furniture 

Coatings

EPA 453/R-07-005 Control Techniques Guidelines for 

Metal Furniture Coatings

Fiberglass Boat 

Manufacturing 

Materials

EPA 453/R-08-004 Control Techniques Guidelines for 

Fiberglass Boat Manufacturing Materials 

Miscellaneous Industrial Adhesives

The CTG applies to facilities where the total actual VOC emissions from all miscellaneous 

industrial adhesive application processes, including related cleaning activities, equal or 

exceed 6.8 kg/day (15 lb/day) actual emissions, or an equivalent level such as 3 tons per 

12-month rolling period before consideration of controls.

Table 2 of VCAPCD’s 2009 RACT SIP indicates the largest source in this category emits 

2.19 tpy, which is below the 2.7 tpy applicability threshold of the CTG.

Flexible Package Printing

The CTG applies to flexible package printing and cleaning operations that emit at least 6.8 

kg/day (15 lb/day), or an equivalent level such as 450 lb/month or 3 tons per 12-month 

rolling period of actual emissions of VOC before consideration of controls.

VCAPCD’s 2009 RACT SIP staff report indicates the only facility it has which might conduct 

flexible package printing is Proctor and Gamble and clarifies that Proctor and Gamble only 

prints the package date codes and related information on the package. The District 

estimates VOC emissions from the package printing operation are approximately 2 lb/day10,

well below the 15 lb/day applicability threshold of the CTG.

 

10 2009 RACT SIP, Attachment 1, page 5
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Metal Furniture Coatings

The CTG applies to metal furniture surface coating operations where the total actual VOC 

emissions from all metal furniture coating operations, including related cleaning activities, 

equal or exceed 6.8 kg/day (15 lb/day), or an equivalent level such as 3 tons per 12-month 

rolling period, before consideration of controls.

VCAPCD’s 2009 RACT SIP lists four metal furniture coating facilities subject to District Rule 

74.12 – Surface Coating of Metal Parts and Products. Attachment 1, Table 3 of the 2009 

RACT SIP shows the maximum emissions comes from Artistic Design (facility 1335), and 

are 14.6 lb/day based on material usage from 1999 through 2008. The District clarified that 

while these emissions are very close to the 15 lb/day CTG threshold, VCAPCD’s 

investigation determined that recent emissions, those between 2005 and 2008 were lower, 

approximately 7.69 lb/day, and is still less than the CTG’s applicability threshold.

Fiberglass Boat Manufacturing Materials

The CTG applies to gel coats, resins, and materials used to clean application equipment 

used in fiberglass boat manufacturing operations. It does not apply to the manufacturing of 

parts of boats or boat trailers unless the facility also manufactures boat hulls or decks. The 

CTG applies to facilities where the total actual VOC emissions from all fiberglass boat 

manufacturing operations equal or exceed 6.8 kg/day (15 lb/day) or an equivalent threshold 

of 2.7 tons per 12-month rolling period.

VCAPCD’s 2009 RACT SIP lists two fiberglass boat manufacturing facilities in Ventura 

County. The average actual VOC emissions from these facilities are 0.3 lb/day and 0.195 

lb/day, well below the CTG’s 15 lb/day applicability threshold. VCAPCD’s 2009 RACT SIP 

also mentions there are three other active boat manufacturing facilities in the District, but 

explains the CTG does not apply to them because one facility does not manufacture hulls 

and decks, while the other two facilities do not use polyester resin material.

Based on VCAPCD’s analysis, we agree with VCAPCD’s negative declaration for the 

Miscellaneous Industrial Adhesives, Flexible Package Printing, Metal Furniture Coatings, 

and Fiberglass Boat Manufacturing Materials CTGs.

3. Additional Major Sources after Reclassification to serious Ozone nonattainment

VCAPCD’s 2006 RACT SIP analysis looked at all emission sources that had the potential 

to emit at least 25 tpy of VOC and/or NOx11. At that time, the District identified 28 facilities 

 

11 At the time VCAPCD submitted its 2006 RACT SIP, the District was classified as a “moderate” non-attainment 

area for the 1997 8-hour ozone standard. The CAA defines a major source for a moderate ozone non-attainment 

area as sources having the potential to emit at least 100 tpy of VOC or NOx. VCAPCD’s 2006 RACT SIP,

however, evaluated major sources at the more stringent threshold of 25 tpy because District Rule 26.1 – New 

Source Review, defines a major source as greater than 25 tpy of VOC or NOx.
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with emissions greater than 25 tpy and certified that stationary sources at those facilities 

were covered by SIP approved rules that satisfied RACT. 

On May 20, 2008, (73 FR 29073) EPA granted VCAPCD’s request to reclassify from a 

“moderate” to “serious”12 ozone non-attainment area for the 1997 8-hour ozone standard. 

VCAPCD’s 2009 RACT SIP states that “since the 2006 RACT SIP considered CTG 

sources and major non-CTG VOC and NOx sources down to 25 tons per year, the 2006 

RACT SIP is able to serve as the District’s serious area RACT certification for CTGs issued 

prior to 2006.”13

EPA EVALUATION

We reviewed CARB’s emissions inventory for 2008 and contacted CARB to determine if 

there were any new major stationary sources in VCAPCD between 2008 – 2010. CARB 

stated there were no new stationary sources over 25 tpy between 2008 – 2010, but that 

there was one source (Simi Valley Landfill) that exceeded 25 tpy in 2010 and 4 sources 

whose emissions fell below 25 tpy after 2008.

14 Simi Valley Landfill was previously 

identified as a major source in VCAPCD’s 2006 RACT SIP which was approved as fulfilling 

RACT. 

A comparison between VCAPCD’s 2006 and 2008 emissions inventory also revealed the 

following two additional sources exceeding 25 tpy (but below 50 tpy). 

Vintage Petroleum, Fillmore, CA (Permit #54) 35 tpy VOC (2008); 10.1 tpy (2010).

Reliant Energy15, Oxnard, CA (Permit #65) 33 tpy NOx (2008) and 6.9 tpy NOx 

(2010).

Vintage Petroleum’s 2012 permit restricts VOC emissions to 24.93 tpy16, which is below 

both the District’s 25 tpy threshold for major sources17 and the 50 tpy threshold for major 

sources in areas classified as a “serious” ozone nonattainment area.

Reliant Energy’s two 7,400 MMBTU/hr steam generators are considered major sources by 

the District and are covered by Rule 59 “Electrical Power Generating Equipment - Oxides 

of Nitrogen Emissions”. The units are equipped with selective catalytic reduction with 

ammonia injection to reduce NOx emissions. Discussion with the facility indicated these 

units are used for power generation when requested by the California Independent System 

 

12 For serious ozone non-attainment areas, a major source is one that has the potential to emit at least 50 tpy or 

greater of VOC or NOx. See CAA 182(c) and (f).

13 2009 RACT SIP Attachment III page 3.

14 Email from Stephen Zelinka (CARB) to Stanley Tong (EPA) dated November 13, 2012.

15 Reliant Energy was previously listed as Ormand Beach Generating Station in VCAPCD's 2006 RACT SIP.

16 Vintage Production California, Inc – Permit to Operate #54.

17 VCAPCD Rule 26.1 New Source Review - Definitions
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Operator (CAISO) and are not operated continuously.

Since Rule 59 was last amended in 1997, it may be an area to investigate for potential 

emission reductions to support the 2008 8-hour ozone standard RACT SIP certification.

A search for large composting operations18 in VCAPCD identified California Mushroom 

Farm Inc. whose permitted throughput is 1,050 cubic yards/day. Prior to its closure in 2013,

and subsequent purchase by a Pennsylvania company, the California Mushroom Farm was

reported to be one of California’s largest mushroom farms19. Discussion with the District 

indicated that the facility was exempted from obtaining an air permit20 from composting 

operations under Rule 23, “Exemptions from Permit”. Therefore, the annual VOC 

emissions from composting are not known. 

The District should request emission records be maintained to support a permit exemption 

if the new owner plans to restart composting operations. A compost regulation should be 

considered if emissions are found to be significant.

4. EPA August 25, 2009 Comment Letter

Our August 25, 2009 comments on a draft version of the 2009 RACT SIP listed two 

potential approvability issues: 1) the need to submit the April 8, 2008 amendments to Rule 

74.12 “Surface Coating of Metal Parts and Products” and 2) the fountain solution limits in 

Rule 74.19 “Graphic Arts” did not match the 2006 Offset Lithographic and Letterpress 

Printing CTG. Both Rules 74.12 and 74.19 are now SIP approved.

5. Summary of Evaluation of VCAPCD 2009 RACT SIP

For the 11 CTGs EPA issued between 2006 and 2008, we agree with VCAPCD’s analysis 

that it only has sources covered by the following CTGs:

Industrial Cleaning Solvents 

Rule 74.6 was approved into the SIP on 10/25/2005.

Offset Lithographic and Letterpress Printing 

Rule 74.19 was approved into the SIP on 9/24/13.

Miscellaneous Metal and Plastic Parts Coatings

Rule 74.12 was approved into the SIP on 5/24/2011.

 

18 http://www.calrecycle.ca.gov/organics/SupplierList/default.asp

19 http://www.vcstar.com/news/2011/apr/23/a-new-era-for-ventura-countys-only-mushroom-farm/

20

 VCAPCD Rule 23 “Exemptions from Permit”, paragraph J.16 

http://www.vcapcd.org/Rulebook/Reg2/RULE%2023.pdf
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EPA reviewed VCAPCD's negative declarations and we agree with the conclusion that 

there are no sources in the District covered by the following CTGs: 

Flat Wood Paneling Coatings

Large Appliance Coatings

Paper, Film and Foil Coatings

Automobile and Light-Duty Truck Assembly Coatings

We agree with VCAPCD’s negative declarations that there are no sources which exceed 

the following CTG applicability thresholds: 

Miscellaneous Industrial Adhesives

Flexible Package Printing

Metal Furniture Coatings

Fiberglass Boat Manufacturing Materials

We also agree major stationary sources which may have resulted due to reclassification of 

VCAPCD from “moderate” to “serious” nonattainment for the 1997 8-hour ozone standard 

are covered by SIP approved RACT rules.

EPA believes the 2009 RACT SIP analysis performed by the VCAPCD adequately 

demonstrates its rules are consistent with EPA recommendations in the 2006, 2007 and 

2008 CTGs.

6. Recommendations

1. VCAPCD should review, and amend as appropriate, the NOx limits in Rule 59 "Electric 

Power Generating Equipment – Oxides of Nitrogen Emissions" for the 2014 RACT SIP.

2. If the successor company to California Mushroom Farms restarts composting operations, 

the District should consider requiring records be maintained to support any permit 

exemptions, or consider developing a rule if emissions are expected to be significant.

7. Public Comments

VCAPCD's 2009 RACT SIP was made available for public comment. No public comments 

were received by the VCAPCD.

8. REFERENCES

1. Ventura County Air Pollution Control District 2009 Reasonably Available Control 

Technology State Implementation Plan (2009 RACT SIP) Revision – dated September 15, 

2009.

2. Final Ventura County Air Pollution Control District 2006 Reasonably Available Control 

Technology (RACT) State Implementation Plan (SIP) Revision – dated June 27, 2006.
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3. “State Implementation Plans, General Preamble for the Implementation of Title I of the 

Clean Air Act Amendments of 1990” (57 FR 13498; April 16, 1992).

4. "State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for 

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

November 25, 1992) ("the NOx Supplement").

5. CARB's emissions inventory database 

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

6. EPA's CTGs and ACTs 

http://www.epa.gov/airquality/ozonepollution/SIPToolkit/ctgs.html

7. VCAPCD, CARB, and EPA Region IX databases of VCAPCD rules

VCAPCD: http://www.vcapcd.org/Rulebook/RuleIndex.htm

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

EPA: http://epa.gov/region09/air/sips/index.html

8. Letter from Andrew Steckel (EPA Region IX) to Michael Villegas (VCAPCD) dated August 

25, 2009.

9. Letter from Michael Villegas (VCAPCD) to Andrew Steckel (EPA Region IX) dated 

September 2, 2009.

10.Email from Stephen Zelinka (CARB) to Stanley Tong (EPA) dated November 13, 2012.

11.Permit to Operate – #54 Vintage Production California, Inc; Table No. 2 Permit to Operate 

#65.

12.http://www.calrecycle.ca.gov/organics/SupplierList/default.asp

13.VCAPCD Rule 23 “Exemptions from Permit”

14.A New Era for Ventura County's Only Mushroom Farm, posted April 23, 2011 at 3:14 p.m.,

updated April 23, 2011 at 4:06 p.m., Ventura County Star,

http://www.vcstar.com/news/2011/apr/23/a-new-era-for-ventura-countys-only-mushroomfarm/?print=1

15.Impact of California Mushroom Farm's closing spreads to community, state and nation, 

September 27, 2013, Ventura County Star,

http://insurancenewsnet.com/oarticle/2013/09/27/impact-of-california-mushroom-farmsclosing-spreads-to-community-state-and-nat-a-395859.html

16.Ventura's California Mushroom Farm Inc. sold to a mushroom grower, Ventura County 

Star, 

http://features.rr.com/article/c11b28c02e0eda8481ae1f69d97aac97#.Uul8cLTfumB