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 D istrict

, R easonably Available Control Technology State Implementation Plan Revision ( 2009 RACT SIP Revision )

Adopted September 15, 2009

Prepared by: Stanley Tong

January 2014- 2

-

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 Implem entation Plan (2009 RACT SIP) Revision Adopted September 15, 2009
Submitted November 17 , 200 9

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 se rious 1 ozone 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 an d 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) r equested 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 2 0, 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, 2 012 ( 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 f or 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 (Octo ber 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

.- 3

-

SUBMITTAL SUMMARY

-

VCAPCD 2009 Reasonably Available Control Technology State Implementa tion 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 perfo rmed its
2009 RACT SIP analysis based on an ozone non

- attainment classification of "se rious ". 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 , 200 9 [hereinafter
“2009 RACT SIP”].
b. Resolution of the Ventura County Air P ollution 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.

 Elev en new or revised CTGs EPA issued between 2006 and 200 8

 N egative declarations

 A dditional major sources identified after reclassification to "se rious " nonattainment for
the 1997 8

- h ou r ozone standard

1. Eleven New or Revised CTGs

Industrial Cleaning Solve nts
Fle xible 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 Boa t 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 s ources in the remaining 8 CTGs or emissions were below the applicability threshold of the specific CTG.- 4

-

CTG Category VCAPCD Rule ( version cited in
9/ 15 /0 9 staff report ) Current r ule 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/ 0 8/08 Rule 74.12 wa s amended 4/08/08
and a pproved 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 p ercent);

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 Manufactur ed Components Cleaning (0.44 percent).

The CTG recommends an applicability thre shold of 6.8 kg/day (15 lb/day). Facilities exceeding this threshold should be subject to a VOC content limit of 50 grams pe r liter (0.42 l b/gal) f or cleaning material s for eac h 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 an d Degreasing, applies to any person performing solvent cleaning activities and to any person that manufactures or s upplies
solvents for use in solvent cleaning activities in the District. Rule 74.6 limits the VOC content of solvents to 25 grams/liter and a llows 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- 5

-

with a combined capture and control efficie ncy 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 20 06 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) alc ohol or
alcohol substitutes for sheet

- fed offset lithographic printing

, the rule contains several more stringent requirements than the CTG that overall make s 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
Exe mption <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 g rams /l iter ) 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 t he ir largest sources
increase d their fountain solution emissions up to the maximum allowed by Rule 74.19. 5

The District also re stat es 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.- 6

-

agree with VCACPD’s analysis that Rule 74.19 , as amended on November 11, 2003, achieves greater reductions tha n 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 approv ed 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 th e total actual VOC emissions exceed 15 lb/day (o r 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
indu strial 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 par ts coating facilities
covered by Rule 74.12

– Surface Coa ting of Metal Parts and Products. VCAPCD’s staff report st ates that one of the faci lities , 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
Pla stic 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

ton s /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 S IP 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.- 7

-

CTG Source Category CTG Document Title

Flat Wood Paneling Coatings EPA

- 453/R06

- 004 Control Techniques Guidelines for Flat Wood Paneling Coatings Large Applianc e Coatings EPA

- 453 /R

- 07

- 004 Control Techniques Guidelines for Large Appliance Coatings Paper, F ilm 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 20 10 emissions inventory did not identify any flat wood paneling coating
facilities in VCAPCD listed under SIC code s 2431

– Millwork; 2435

– Hardwood Veneer and Plyw ood; 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 a re not aware of any flat wood paneling coating facilities in Ventura County APCD and

a gree with the District’s conc lusion that it has no facilities covered by th e 2006 Flat Wood Paneling Coatings CTG.

EPA

- 453/R

- 07

- 004 Control Techniques Guidelines f or 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

– Househol d 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 SI C codes and did not identify any facilities in VCAPCD under the above SIC codes. We agree with VCAPCD’s negative decl aration 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, EP A 453/R

- 06

- 004 September 2006, Appendix

B.- 8

-

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 a pplicable

to paper printing.

We searched CARB ' s 2008 and 2010 emissions inventory database for the se SIC codes
and determined two potential facilities , Crockett Graphic s and Performance Materials Corp,

l isted under SIC code s 2653 and 3083 respectively

, t hat 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
f lexographic 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: Plastic s, 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 a nd 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 Co atings

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 20 10 emissions inventory and did not find any facilities

c overed 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.- 9

-

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 the se sources are below the applica bility 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 Co ntrol Techniques Guidelines for

Fiberglass Boat Manufacturing Materials

Miscellaneous Industrial Adhesives

The CTG app lies to facilities where the total actual VOC emissions from all miscellaneous industrial adhesive application processes, including r elated cleaning activities

, equal or exceed 6.8 kg/day (15 lb/day) actual emissions , or an equivalent level such as 3 t ons 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 packag e 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 print s the package date codes and related information on the package. The District
estimates VOC emission s from the package printing operation are approximately 2 lb/day 10

, well below the 15 lb/day applicability th reshold of the CTG.

10 2009 RACT SIP, Attachment 1, page 5- 10

-

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 f our metal furniture coating facilities subject to District Rule

74.12

– Surface Coating of Metal Parts and Pro ducts

. A ttachment 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 clarifie d that

w hile these emissions are very close t o 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

T he 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 hu lls 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 RAC T 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 o n VCAPCD’s analysis, we agree with V CAPCD’s negative declaration for the Miscellaneous Industrial Adhesives, Flexible Package Printing, Metal Furniture Coatings, and Fiberglass Boat M anufacturing Materials CTG s

.

3. Additional Major Sources after Re classif ication 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 NOx 11

. At that time, the District identified 2 8 facilities

11 At the time VCAPCD submitted its 2006 RACT SIP, the Distric t 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.- 11

-

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 f or 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 sourc es 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 exceed ing 25 tpy (but below 50 tpy)

.

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

. Reliant Energy 15 , Oxnard, CA ( Permit # 65) 33 tpy NOx (2 008 ) and 6.9 tpy NOx (2010).

Vintage Petroleum’s 2 012 permit restricts VOC emissions t o 24.93 tpy 16

, which is below
both the District’s 25 tpy threshold for major sources 17 and the 50 tpy threshold for major

sources in areas classified as a “ seri o us” ozone nonattainment area

.

Reliant Energy ’s two 7,400 MMBTU/hr steam generators are consider ed 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 th e 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 ha s 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 Or mand 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- 12

-

Operator (CAISO) and are not operat ed continuously

.

Since Rule 59 was last amended in 1997, it may be an area to investigat e for potential
emission reductions to support the 2008 8

- hour ozone standard RACT SIP certification

.

A search for large composting operations 18 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 farms 19

. Discussion with the District
indicated that the fa cility wa s exempted from obtaining an air permit 20 from composting operations under R ule 23, “Exemptions from Permit” . Therefore, the annual VOC emissions from composting are not know n

.

The District should request emission records be maintained to support a permit exemption
i f the new owner plans to restart c omposting 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 ha s sources covered by the following CTGs:

Industrial Cleaning Sol vents Rule 74.6 was approved into the SIP on 10/25/2005.

Offset Lithographic and Letterpress Printing
Rule 74.19 was a pproved 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- 13

-

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 “se rious ” nonattainment for the 1997 8

- hour ozone standard are covered by SIP approved RACT rules.

EPA belie ves 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 Farm s restart s composting operations,
the District should consider requiring records be maintained to suppo rt any permit exemptions

, or consider developing a rule if emissions are expected to be s ignificant

.

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
Techno logy (RACT) State Implementation Plan (SIP) Revision

– dated June 27, 2006.- 14

-

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 Plan s; 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.htm l

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

- mushroom

farm/?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

- farms

closing

- spreads

- to

- community

- state

- and

- nat

- a

- 395859.html

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

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