J. Goldstene
2009 RACT SIP Revision September 24, 2009 Page 2

Attachments: I. SIP Completeness Checklist II. A Resolution of the Ventura County Air Pollution Control Board Approving and Adopting the 2009 Reasonably Available Control Technology State Implementation Plan Revision

III. Final 2009 Reasonably Available Control Technology State Implementation Plan

Revision IV. September 15, 2009 Ventura County Air Pollution Control Board Packet for the 2009 Reasonably Available Control Technology State Implementation Plan

Revision
V. Certificate of Publication – Public Notice

cc: Andy Steckel, EPA Region IX (w/attachments) Stanley Tong, EPA Region IX (w/attachments) Kurt Karperos, ARB (w/attachments) Andrea Juarez, ARB (w/attachments)ATTACHMENT I

SIP COMPLETENESS CHECKLISTAttachment I SIP COMPLETENESS CHECKLIST

Agency: Ventura County Air Pollution Control District 669 County Square Drive, 2nd Floor Ventura, California 93003

Plan Submitted: 2009 Reasonably Available Control Technology State Implementation
Plan Revision (2009 RACT SIP Revision)

Adoption Date: September 15, 2009

1. Evidence That the District Adopted th e Plan and That the District Followed All of the Requirements of its Administrative Procedures Act:

Attachment II is a signed resolution from th e Ventura County Air Pollution Control Board adopting the draft 2009 Reasonably Available Control T echnology State Implementation
Plan Revision as the final 2009 Reasonably Available Control Technology State Implementation Plan Revision . Attachment II also certifies that the 2009 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 final 2009 Reasonably Available Control Tec hnology State Implementation Plan
Revision is included as Attachment III.
4. Compilation of Public Comments and the District's Responses:

Written comments received by the District, along with the District’s responses, during the public comment period are provided in Att achment C to the September 15, 2009 Ventura County Air Pollution Control Board Packet for the 2009 Reasonably Available Control Technology State Implementation Plan Revision , which is included as Attachment IV.
5. Evidence that Public Notice Was Given of the Proposed Adoption of the Plan:

Attachment V is a copy of the Certificate of P ublication for the Public Notice. The Public Notice was published at least 30 days prior to the public hearing.

LIST OF ATTACHMENTS

I. SIP Completeness Checklist (this document) II. A Resolution of the Ventura County Air Pollution Control Board Approving and Adopting the 2009 Reasonably Available Control Technology State Implementation Plan
Revision
III. Final 2009 Reasonably Available Control Tec hnology State Implementation Plan
Revision IV. September 15, 2009 Ventura County Air Pollution Control Board Packet for the 2009 Reasonably Available Control Technology State Implementation Plan Revision
V. Certificate of Publication – Public NoticeATTACHMENT II

A RESOLUTION OF THE VENTURA COUN TY AIR POLLUTION CONTROL BOARD
APPROVING AND ADOPTING THE 2009 REASONABLY AVAILABLE
CONTROL TECHNOLOGY STATE IMPLEMENTATION PLAN REVISIONATTACHMENT III

FINAL VENTURA COUNTY AIR POLLUT ION CONTROL DISTRICT
2009 REASONABLY AVAILABLE CONTROL TECHNOLOGY
STATE IMPLEMENTATION PLAN REVISIONVENTURA COUNTY AIR POLLUT ION CONTROL DISTRICT

2009 REASONABLY AVAILABLE CONTROL TECHNOLOGY STATE IMPLEMENTATION PLAN (2009 RACT SIP) REVISION

SEPTEMBER 15, 2009

LEGAL & REGULATORY BACKGROUND

The federal Clean Air Act Amendments (CAAA) of 1990 gives the states primary responsibility for achieving the national am bient air quality standards (NAAQS). The NAAQS are set by the U.S. Environmental Protection Agency (EPA) as the maximum concentrations in the atmosphere for specifi c 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 impl ement its responsibiliti es under the CAAA.

Sections 182(b)(2) and 182(f) of the CA AA (42 U.S.C. §7511(a)) require ozone nonattainment areas to implement reasonabl y available control technology (RACT) emission standards for sources of air polluti on that are subject to control techniques guidelines (CTG) issued by EPA. 1 RACT is also required for “major sources” 2 of volatile organic compounds (VOC) and nitr ogen oxides (NOx) emissions, which are precursors of ozone or urban smog. RACT is defined as the lowest emissions limitation that a particular source is capable of meeting by the application of air pollution control technology that is reasonably available considering technological and economic feasibility (44 FR 53762; September 17, 1979). 3

PURPOSE OF A RACT SIP
The purpose of the 2009 Reasonably Available Control T echnology State Implementation

Plan Revision (2009 RACT SIP) is to demonstrate th at all District ru les applicable to ozone precursor emissions meet or exceed reasonably availa ble control technology (RACT) and fulfill RACT requirements for the federal 8-hour ozone standard. This process is necessary because Ve ntura County is classified as a serious nonattainment area

for the federal 8-hour ozone standard.

1 CTGs are guidance documents that define RACT for existing sources of air pollution. Emission sources subject to CTGs are called CTG sources. RACT co ntrols are also required on major VOC and NOx stationary sources not covered by CTGs. Such sources are called non-CTG sources.

2 In Ventura County, Rule 26, New Source Review, defines major stationary VOC and NOx sources as those with a potential to emit 25 tons or more of VOC or NOx.

3 RACT requirements are included in the Clean Air Ac t to ensure that significan t source categories at major sources of ozone precursor emissions are contro lled to a “reasonable” extent, but not necessarily to the more stringent best available control technology (BACT) or maximum achievable control technology (MACT) levels expected for new or modified major stationary sources.

Page 1 Attachment III2009 RACT SIP September 15, 2009

REQUIREMENTS FOR A RACT SIP
According to the EPA’s Final Rule to Implement the 8-Hour Ozone NAAQS (70 FR 71612; November 29, 2005), areas classi fied as moderate ozone nonattainment or higher were to certify that their ru les fulfill 8-hour ozone RACT for all CTG categories and all major non-CTG sources as a revision to their SIPs . The SIP revisions were due to EPA by September 15, 2006.

The EPA 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 . In addition, EPA Region 9 provided a basic framework

for the RACT SIPs. That framework was c ontained in a letter (March 9, 2006) from EPA Region 9 to the California Air Resour ces Board (CARB) and is presented below:

• Describe efforts to identify all source categ ories within the District requiring RACT, including CTG sources (i.e., covered by an EPA CTG 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 CT Gs, alternative control techniques (ACT) guidance, MACT standards, new source pe rformance standards (NSPS), California suggested control measures (SCM), RACT /best available retrofit control technology determinations, regulations adopted in other Districts, and guidance and rules developed by other state and local agencies.

• Some Districts may use the California Ai r 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 dem onstration that no additional controls have become more reasonably available since then.

DISTRICT RACT HISTORY
The District approved its 2006 RACT SIP on June 27, 2006. The 2006 RACT SIP found that all District rules that apply to ozone precursor emissions fulfill RACT requirements for the 8-hour ozone NAAQS. District rules meet or exceed RACT because they comply

Page 2 Attachment III2009 RACT SIP September 15, 2009

with more current and stringent control requ irements of the California Clean Air Act.

The 2006 RACT SIP also found that all CTG sources and major non-CTG sources

within District boundaries meet or exceed RACT. The 2006 RACT SIP was submitted as

a moderate ozone nonattainment area RACT certification. Moderate area RACT

certifications must consider all CTG s ources and major non-CTG sources with a potential to emit 100 tons per year or great er of either VOC or NOx. The 2006 RACT SIP, however, considered all CTG and major non-CTG sources with the potential to emit 25 tons per year or greater of VOC or NOx, the RACT certification threshold for severe

areas.

On May 20, 2008, EPA granted the District’s request to reclassify (i.e., “bump-up”)

from a moderate ozone nonattainment area to a serious ozone nonattainment area. The District requested reclassi fication because photochemical modeling, along with other analyses, conducted for the Ventura C ounty 2007 Air Quality Management Plan indicated that Ventura County would not attain the federal eight-hour ozone standard by

the deadline for moderate ozone nonattainment areas and would need more time to attain the federal eight-hour ozone st andard. This classification bump-up obligated the District to certify that all CTG sources and major non- CTG sources with the potential to emit 50 tons per year or greater of VOC or NOx meet or exceed RACT. Therefore, 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.

EPA approved the District’s 2006 RACT SIP Revision on April 21, 2009.

2009 RACT ANALYSES AND FINDINGS
Since District adoption of th e 2006 RACT SIP, EPA has issued eleven new CTGs: four in 2006, three in 2007, and four in 2008. In response, District staff prepared the 2009

RACT SIP Revision to address the new CTGs. The new CTGs are presented in Table 1, “Source Categories, CTG Documents Issued Since Adoption of the Ventura County 2006 RACT SIP, and Applicable District Rules.”

The 2009 RACT SIP Revision is divided into two sections. Attachment 1, “Ventura County APCD 2009 RACT Negative Declarations” includes negative declarations covering eight CTG categories for which Vent ura County either has no sources or has

sources but the sources area below the CTG applicability thresholds. Attachment 2, “Ventura County APCD 2009 RA CT Certifications” includes RACT certifications covering the three CTG categories for which Ventura County has sources above the CTG applicability thresholds.

Summary - Negative Declarations The District is required to submit negative declarations for all CTG categories for which there are: 1) no subject sour ces in the county; or, 2) no s ubject sources with emissions

Page 3 Attachment III2009 RACT SIP September 15, 2009

above CTG applicability thresholds. The purpose of the negative declarations (see Attachment 1) is to certify that Ventura County does not have s ources subject to the

CTGs.

Ventura County does not have sources fo r the following four CTG categories:

• Flat Wood Paneling Coatings

• Large Appliance Coatings

• Paper, Fabric, and Foil Coatings

• Automobile and Light-Duty Truck Assembly Coatings

Ventura County has sources for the following four CTG categories, but ROC emissions associated with each subject source are le ss than the CTG applicability thresholds:

• Miscellaneous Industrial Adhesives

• Flexible Package Printing

• Metal Furniture Coating

• Fiberglass Boat Manufacturing Materials

Summary - RACT Certifications The District is required to certify that all District rules covered by CTGs, and for which it

has sources with emissions over the relevant CTG applicability thresholds, meet or

exceed RACT.

Ventura County has sources with ROC emissi ons above the relevant CTG applicability thresholds for the following three CTG categories (see Attachment 2):

• Offset Lithographic Printi ng and Letterpress Printing

• Miscellaneous Metal and Plastic Parts Coatings

• Industrial Cleaning Solvents

CONCLUSION
Based on the 2006 RACT SIP and the proposed 2009 RACT SIP revisi ons, the District has fulfilled RACT certification requiremen ts for a serious federal 8-hour ozone

nonattainment area.

Page 4 Attachment III2009 RACT SIP September 15, 2009

Page 5 Attachment III CALIFORNIA ENVIRONMENTA L QUALITY ACT (CEQA)

The 2009 RACT SIP Revision is an evaluation of current District air pollution rules and

will not result in new or revised District rules or any physical change in the environment. Therefore, adoption of the proposed 2009 RACT SIP Revision is not a project as defined in Section 15378(a) of the CEQA Guidelines and therefore not subject to CEQA review pursuant to CEQA Guidelines Section 15060(c)(3).Table 1Source Categories, CTG DocumentsIssued Since Adoption of theVentura County 2006 RACT SIP, and Applicable District Rules

Page 6
A ttachment IIISourceCategoryCTG DocumentApplicabilitySubjectSources?VCAPCDRuleDate LastAmendedEPAApproval*MeetsRACT?IndustrialCleaningSolventsControl TechniquesGuidelines forIndustrial CleaningSolvents(EPA-453/R-06-001;9/06)Applies to industries that have to use organic solventfor cleaning unit operationssuch as mixing vessels(tanks), spray booths, and parts cleaners, where afacility emits at least 6.8 kg/day (15 lb/day) of VOCbefore consideration ofcontrols in an ozonenonattainment area. The cleaning activities forremoval of foreign material from substrate beingcleaned includes actions (activities) such as wiping,flushing, or spraying.Yes(seeAttachment 2)a) Variousb) 74.6 -SurfaceCleaning andDegreasingNA**11/11/03NA11/11/03YesYesFlexiblePackagingPrintingControl TechniquesGuidelines forFlexible PackagingPrinting(EPA-453/R-06-003,9/06)Applies to flexible packaging printing operations thatemit at least 6.8 kg/day (15 lb/day) of VOC beforeconsideration of controls.No(seeAttachment 1)NANANANAFlat WoodPanelingCoatingsControl TechniquesGuidelines for FlatWood PanelingCoatings(EPA-453/R-06-004,9/06)Applies to facilities that apply flat wood panelingcoatings that emit at least 6.8 kg/day (15 lb/day) ofVOC before consideration of controls.No(seeAttachment 1)NANANANAOffsetLithographicPrinting andLetterpressPrintingControl TechniquesGuidelines for OffsetLithographic Printingand LetterpressPrinting(EPA-453/R-06-002,9/06)Applies to cleaning materials and fountain solutionsused in any offset lithographic printing operationwhere the emissions associated with all aspects of theoperation equal or exceed 6.8 kg/day (15 lb/day)actual emissions of VOC, or an equivalent level,before consideration of controls. Also applies toheatset web offset lithographic printing operations andheatset web letterpress printing operations withpotential to emit from the dryer, prior to controls, atleast 25 ton/yr of VOC (petroleum ink oil) from heatsetinks.Yes(seeAttachment 2)Rule 74.19 -Graphic Arts11/11/0311/11/03Yes 2009 RACT SIP September 15, 2009Page 7
A ttachment IIISourceCategoryCTG DocumentApplicabilitySubjectSources?VCAPCDRuleDate LastAmendedEPAApproval*MeetsRACT?Large ApplianceCoatingsControl TechniquesGuidelines for LargeAppliance Coatings(EPA-453/R-07-004,9/07)Applies to large appliance coating units at facilitieswhere the total actual VOC emissions from all largeappliance coating operations, including cleaningactivities, at that facility are at least 6.8 kg/day (15lb/day) of VOC before consideration of controls.No(seeAttachment 1)NANANANAMetal FurnitureCoatingsControl TechniquesGuidelines for MetalFurniture Coatings(EPA-453/R-07-005,9/07)Applies to metal surface coating units at facilitieswhere the total actual VOC emissions from all metalfurniture coating operations, including cleaningactivities, are at least 6.8 kg/day (15 lb/day) of VOCbefore consideration of controls.No(seeAttachment 1)NANANANAPaper, Film, andFoil CoatingsControl TechniquesGuidelines forPaper, Film, and FoilCoatings(EPA-453/R-07-003,9/07)Applies to facilities where the total actual VOCemissions from all paper, film, and foil coatingoperations, including cleaning activities, are at least6.8 kg/day (15 lb/day) of VOC before consideration ofcontrols.No(seeAttachment 1)NANANANAMiscellaneousMetal andPlastic PartsCoatingsControl TechniquesGuidelines forMiscellaneous Metaland Plastic PartsCoatings(EPA-453/R-08-003,9/08)Applies to miscellaneous metal product and plasticparts surface coating units at facilities where the totalactual VOC emissions from all miscellaneous metalproduct and plastic parts surface coating operations,including cleaning activities, are at least 6.8 kg/day (15lb/day) of VOC before consideration of controls.Yes(seeAttachment 2)74.12 –MiscellaneousMetal Parts andProducts4/8/08NAYesFiberglass BoatManufacturingControl TechniquesGuidelines forFiberglass BoatManufacturing(EPA-453/R-08-004,9/08)Applies to facilities that manufacture hulls or decks ofboats from fiberglass, or build molds to makefiberglass boat hulls or decks, where the total actualVOC emissions, including cleaning activities, from allfiberglass boat-manufacturing operations covered bythe CTG are at least 6.8 kg/day (15 lb/day) of VOCbefore consideration of controls.No(seeAttachment 1)NANANANAMiscellaneousIndustrialAdhesivesControl TechniquesGuidelines forMiscellaneousIndustrial Adhesives(EPA-453/R-08-005,9/08)Applies to miscellaneous industrial adhesiveprocesses at facilities where the total actual VOCemissions from all miscellaneous industrial adhesiveapplication processes, including cleaning activities,are at least 6.8 kg/day (15 lb/day) of VOC beforeconsideration of controls.No(seeAttachment 1)NANANANA 2009 RACT SIP September 15, 2009Page 8
A ttachment IIISourceCategoryCTG DocumentApplicabilitySubjectSources?VCAPCDRuleDate LastAmendedEPAApproval*MeetsRACT?Automobile andLight-DutyTruck AssemblyCoatingsControl TechniquesGuidelines forAutomobile andLight-Duty TruckAssembly Coatings(EPA-453/R-08-006,9/08)Applies to VOC emissions stemming from the use ofcoatings in automobile and light-duty truck assemblycoating operations.No(seeAttachment 1)NANANANA 2009 RACT SIP September 15, 2009* Date of EPA Federal Register Notice** Not applicableATTACHMENT 1

VENTURA COUNTY APCD
2009 RACT NEGATIVE DECLARATIONS

RACT SOURCE CATEGORIES WITH NO SOURCES IN VENTURA COUNTY

RACT Source Categories

Flat Wood Paneling Coatings Large Appliance Coatings Paper, Film, and Foil Coatings Automobile and Light-Duty Truck Assembly Coatings

RACT Guidance Documents Control Techniques Guidelines for Flat Wood Paneling Coatings ( EPA-453/R-06-004 ; 9/06)

Control Techniques Guidelines for Large Appliance Coatings ( EPA-453/R-07-004 ; 9/07)

Control Techniques Guidelines for Paper, Film, and Foil Coatings ( EPA-453/R-07-003 ; 9/07)

Control Techniques Guidelines for Automobile and Light-Duty Truck Assembly Coatings ( EPA-453/R-08-006 ; 9/08)

As was done for the 2006 RACT SIP, District staff reviewed the District’s permit and emissions inventory systems for its fede ral Clean Air Act pl an, consulted with knowledgeable District staff, and subsequently determined that there are no stationary sources within Ventura County for the four CTG categories listed above. The District does not anticipate these sources in the future. If such s ources locate in the county, they will be subject to the District’s New S ource Review requirements, which are more stringent than RACT.

Conclusion Since there are no stationary sources in Ve ntura County for the four CTG categories listed above, negative declarations for these CTG categories are appropriate.

Page 1 Attachment 12009 RACT SIP September 15, 2009

RACT SOURCE CATEGORIES WITH SOURCES IN VENTURA COUNTY BUT
WITH EMISSIONS BELOW THE CTG APPLICABILITY THRESHOLDS

RACT Source Category

Miscellaneous Industrial Adhesives

RACT Guidance Document Control Techniques Guidelines for Offset Miscellaneous Indu strial Adhesives ( EPA-453/R-08-005 ; 9/08)

The 2008 CTG for miscellaneous industrial ad hesives provides control recommendations for reducing VOC emissions from miscellane ous industrial adhesi ves and adhesive primer application processes

. The miscellaneous industrial adhesives product category includes adhesives (including adhe sive primers used in conjun ction with certain types of adhesives) used at industria l manufacturing and repair faci lities for a wide variety of products and equipment that operate adhesives application processes. The miscellaneous industrial adhesives product category does not include adhe sives that are addressed by CTGs already issued for categories listed unde r CAA Section 183(e) or by earlier CTGs.

These include the CTGs issued under Sect ion 183(e) for aerospace coatings; metal furniture coatings; large applia nce coatings; flat wood paneli ng coatings; paper, film, and foil coatings; offset lithographic printing and letterpress printing; and flexible package printing. Coil coating, fabric coating, and r ubber tire manufacturing were not listed under CAA Section 183(e). However, they were th e subject of earlier CTGs, which address adhesives used in those processes.

As stated in the CTG, EPA recommends that the control approaches discussed in Section VI of the CTG apply to each miscellaneous i ndustrial adhesive application process at a facility where the total actual VOC emissions from all miscellaneous industrial adhesive application processes at that f acility, including related cleanin g activities, are equal to or exceed 6.8 kg/day (15 lb/day), or an equiva lent level such as 2.7 tons per 12-month rolling period, before consid eration of controls. EPA doe s not recommend these control approaches for facilities that emit below this level because of the very small VOC

emission reductions that can be achieve d. The recommended threshold level is equivalent to the evaporation of approximately 2 gal/day of solvent. Such a level is

considered to be an incident al level of solvent usage that could be expected even in facilities that use low-solvent adhesives, such as radiation cured adhesives.

District Rule 74.20, Adhesives and Sealan ts, reduces ROC emissions by limiting the ROC content of adhesives, sealants, adhesive primers, and sealant primers. Solvent cleaners, which are the largest source of ROC emissions at these facilities, are regulated by ROC content and/or ROC comp osite partial vapor pressure.

Page 2 Attachment 12009 RACT SIP September 15, 2009

An important aspect of Rule 74.20 is its applic ability to much smalle r sources than those recommended by the CTG. Bonding operations using adhesives in Ventura County that emit over 200 lb/yr of ROC are required to meet all the requirements in the rule, and are required to have APCD permits to enforce those requirements. This cutoff level is significantly lower than the 15 lb/day threshold in the CTG, which corresponds to 2.7 ton/yr of ROC. Consequen tly, all sixteen permitted adhesive operations in the county

have actual ROC emissions much less than the CTG threshold, and thus none of the

recommended control measures in the CTG apply to existing county sources. These sixteen adhesive operations, along with thei r ROC emissions, are presented below in Table 2. As can be seen from Table 2, RO C emissions associated with each of the facilities are below the CTG’s applicability th resholds. It should be noted that the two largest sources in Table 2, Pe ntair and Perma Plaque, do not have any add-on controls

and so the emissions shown for these sources are before controls.

Table 2 Industrial Adhesives Sources in Ventura County

Facility Name SIC Code Actual ROC Emissions (ton/yr) Permitted ROC Emissions

(ton/yr)
Aquaria 3231 -----* 1.50
Avica, Inc. 3728 -----* < 200 lb/yr
California Amplifier 3663 1.02 ----- Drum Workshop 3931 0.12 ----- ERG International 2522 -----* 1.74
Freedom Designs 3842 0.75 ----- Milgard Manufacturing 3211 -----* 1.12

Pentair Pool Produ cts 3648 1.87 ----- Perma Plaque 3999 2.19 ----- PTI Technologies 3728 0.10 ----- Record Technology 3652 -----* 0.03
Robbins Auto Top 3711 1.10 ----- Santa Maria Tire 7534 0.18 ----- SolarWorld Industries 3674 0.19 ----- Technicolor Home Entertainment Services 3652 0.01 -----

Waterway Plastics 3088 -----* 1.21

* Actual ROC emissions not available, so permi tted ROC emissions are provided for information

purposes

Conclusion None of the adhesive operations in Vent ura County are subject to the 2008 CTG for

miscellaneous industrial adhesives becau se their emissions are below the CTG

Page 3 Attachment 12009 RACT SIP September 15, 2009

applicability thresholds and, therefore, a ne gative declaration for this CTG category is appropriate.

Page 4 Attachment 12009 RACT SIP September 15, 2009

RACT Source Category

Flexible Package Printing

RACT Guidance Document Control Techniques Guidelines for Flexible Package Printing ( EPA-453/R-06-003 ; 9/06)

The 2006 CTG for flexible package printing provides control recommendations for reducing VOC emissions from inks, coatings, adhesives and cleaning materials used in flexible packaging printing operations. Flexible packaging refers to any package or part of a package the shape of which can be readily changed. Flexible packaging includes, but is not limited to, bags, pouches, liners, and wraps utilizing pa per, plastic, film, aluminum foil, metalized or coated paper or film, or any combination of these materials.

As stated in the CTG, EPA recommends applying the control recommendations for flexible packaging printing cleaning material s to flexible packaging printing operations that emit at least 6.8 kg/day ( 15 lb/day) actual emissions of VOC before consideration of emission controls. States and local agencies have discretion to consider the 15 lb/day VOC applicability level, an equivalent appl icability level expressed on a monthly basis (e.g., 450 lb/month), an equivale nt applicability level expr essed on a 12-month rolling basis (e.g., 3 tons per 12-month rolling period) , or other applicability levels for their regulations.

The only facility in Ventura County that mi ght conduct flexible package printing is the Proctor and Gamble facility in Oxnard, Calif ornia, which manufactures consumer paper products. That facility conducts only very limited package printing. Product packages used at the Oxnard facility ar e preprinted at facilities out side the county, and only prints package date codes and related information printed on the packaging using large-format ink-jet printers. VOC emissions from this package printing operation are only 726 lb/yr (2 lb/day), which is far less th an CTG applicability threshold.

Conclusion The only package printing operation in Ventur a County that might be subject to the 2006 CTG for flexible package pr inting falls below the CTG a pplicability thresholds and, therefore, a negative declaration fo r this CTG category is appropriate.

Page 5 Attachment 12009 RACT SIP September 15, 2009

RACT Source Category

Metal Furniture Coatings

RACT Guidance Document Control Techniques Guidelines for Metal Furniture Coatings ( EPA-453/R-07-005 ; 9/07)

The 2007 CTG for metal furniture coatings provides control recommendations for reducing VOC emissions from metal furniture co ating operations. Such coatings include paints, sealants, caulks, inks, adhesives, and maskants. Metal furniture coatings provide a covering, finish, or functional or protective layer, and can also provide a decorative finish

to metal furniture.

The metal furniture coatings product category under section 183(e) of the CAA includes the coatings that are applied to the surfaces of metal furniture for decorative, protective, and functional purposes. A metal furniture s ubstrate is the furniture or components of

furniture constructed entir ely or partially from metal. Me tal furniture incl udes, but is not limited to, the following types of products: household, office, instit utional, la boratory, hospital, public building, rest aurant, barber and beauty shop, and dental furniture, as well as components of these products. Metal furnitu re also includes offi ce and store fixtures, partitions, shelving, lockers, lamps and ligh ting fixtures, and wastebaskets. Metal furniture coatings include paints and adhe sives and are typically applied without a primer. Higher solids and powder coatings ar e used extensively in the metal furniture surface coating industry

In terms of applicability, EPA recommends that the control approaches discussed in Section VI of the CTG apply to each metal furniture surface coating unit at a facility

where the total actual VOC emissions from all metal furniture coating operations, including cleaning activ ities, are equal to or exceed 6.8 kg/day (15 lb/day), or an equivalent level such as 2.7 tons per 12-m onth rolling period, before consideration of controls. EPA does not recommend these control approaches for facilities that emit below this level because of the very small VOC emission reductions that can be achieved. The recommended threshold level is equivalent to the evaporation of approximately 2 gal/day of solvent. Such a level is consider ed an incidental level of solvent usage that could be expected even in facilities that use very low-solvent coatin gs, such as powder or

UV cure.

There are four metal furniture manufacturers in Ventura County. These four facilities, along with their VOC emissions, are presented below in Table 3. As can be seen from Table 3, actual ROC emissions from all of the facilities are below the CTG’s applicability

thresholds.

Page 6 Attachment 12009 RACT SIP September 15, 2009

Table 3 Average Actual ROC Emissions from Metal Furniture Coating Facilities Subject to VCAPCD Rule 74.12

Actual ROC Emissions*
Permit Company lb/hr lb/day ton/yr

0196 Originals 22 0.464 3.713 0.483

0651 ERG International 0.122 0.975 0.127

1174 Hanson Lab Furniture 0.387 3.095 0.402

1335 Artistic Design 1.826 14.607 1.899

* Calculations assume 2,080 hr/yr of operation and 8 hr/day.

Actual emission calculations for the facili ties listed in Table 3 are based on 2,080 hr/yr and one work shift of 8 hr/day. Artistic Design has actual average daily emissions of 14.607 lb/day, very near the CTG’s app licability threshold of 15 lb/day.

District staff contacted Artisti c Design and verified that th ey operate only one shift per day. The 14.6 lb/day estimate based on actual material use from 1999 through 2008 (with 2000 missing). If average material use from 2005 through 2008 is used, average ROC emissions are lowered to 1.0 ton/yr and 7.69 lb/day, which are lower than the CTG applicability threshold. In any event, Rule 74.12 is more stringent overall than the CTG and two comparable rules.

Conclusion

None of the metal furniture manufacturers in Ventura County are subject to the 2007 CTG for metal furniture coating because thei r emissions are below the CTG applicability thresholds and, therefore, a negative declaration for this CTG category is appropriate.

Page 7 Attachment 12009 RACT SIP September 15, 2009

RACT Source Category

Fiberglass Boat Manufacturing Materials

RACT Guidance Document Control Techniques Guidelines for Fibe rglass Boat Manufacturing Materials ( EPA-453/R-08-004 ; 9/08)

The 2008 CTG for fiberglass boat manufacturin g provides control recommendations for reducing VOC emissions from the use of gel co ats, resins, and materials used to clean application equipment used in fiberglass boa t manufacturing operations. It applies to

facilities that manufacture hulls or decks of boats from fiberglass, or build molds to make fiberglass boat hulls or decks (hereinafter referred to as “fibergl ass boat manufacturing facilities”).

The CTG recommendations do not extend to f acilities that only manufacture parts of boats (such as hatches, seats, or lockers), or boat trailers, but do not manufacture hulls or decks of boats from fiberglass, or build molds to make fiberglass boat hulls or decks. If a facility manufactures hulls or decks, or molds for hulls or de cks, then the manufacture of all other fiberglass boat parts, including small parts such as ha tches, seats, and lockers are

covered. The CTG’s recommended control a pproaches also do not extend to surface coatings applied to fiberglass boats, and do not apply to industrial adhesives used in the assembly of fiberglass boats. Surface coatings for fibergla ss and metal recreational boats (pleasure craft) are addressed in the CTG for miscellaneous metal parts and plastic parts surface coating. Industrial adhesives used in boat assembly are addressed in the CTG for miscellaneous industrial adhesives. Polyester resin putties used to assemble fiberglass parts, however, are not c onsidered adhesives and are addressed in the CTG.

As discussed in the CTG, EPA does not reco mmend the control approaches discussed in

Section VI of the CTG for facilities that emit below 6.8 kg/day because of the very small

VOC emission reductions that coul d be achieved. Such a level is considered to be very low within the fiberglass boat manufacturing industry and is expected only from facilities producing only small numbers of small boats (such as specialty kayaks or canoes).

There are two fiberglass boat manufacturing facilities in Ventura County. These facilities, along with their VOC emissions, ar e presented in Table 4. The CTG does not apply to these facilities b ecause their ROC emissions are below the CTG applicability

thresholds.

Page 8 Attachment 12009 RACT SIP September 15, 2009

Table 4 Average Actual ROC Emissions from Fiberglass Boat Manufacturing

Actual ROC Emissions*
Permit Company lb/hr lb/day ton/yr

00433 Anacapa Marine Services 0.037 0.300 0.039

01083 Ventura Harbor Boatyard 0.024 0.195 0.025

* Calculations assume 2,080 hr/yr of operation and 8 hr/day.

There are three other active boat manufactur ing facilities in Ve ntura County, Electra Craft in Westlake Village (Permit No. 7360) , and two Anchors Way Marine Centers in the Cities of Ventura and Oxnard (Perm it Nos. 253 and 1391, respectively). The CTG does not apply to Electra Craft because the hu lls and decks assembled at the facility are made outside of Ventura County. The CTG also does not apply to the two Anchors Way Marine Centers because neither uses polyester resin material . Four other boat building permits in the county are inactive at this time.

Conclusion None of fiberglass boat ma nufacturers in Ventura Count y are subject to the 2008 CTG for fiberglass boat manufacturing because their emissions are below the CTG applicability thresholds and, therefore, a ne gative declaration for this CTG category is appropriate.

Page 9 Attachment 12009 RACT SIP September 15, 2009

Page 10 Attachment 1 THIS PAGE INTENTIONALLY LEFT BLANKPage 1 Attachment 2 ATTACHMENT 2

VENTURA COUNTY APCD
2009 RACT CERTIFICATIONS

RACT Source Category

Industrial Cleaning Solvents

RACT Guidance Document Control Techniques Guidelines fo r Industrial Cleaning Solvents ( EPA-453/R-06-001 ; 9/06)

Background In September 2006, EPA published a CTG for Industrial Cleaning Solvents. The CTG provides control recommendations for reducing VOC emissions from industries that use organic solvents used to remove contaminants such as adhesives, inks, paint, dirt, soil, oil, and grease. Contaminants are remove d from parts, products, tools, machinery, equipment, vessels, floors, walls, and othe r work production related work areas for a variety of reasons including safety, oper ability, and to avoid product contamination.

The recommended measures for controlling emi ssions of VOC from the use, storage, and disposal of industrial cleaning solvents incl udes work practice standards, limitations on VOC content of the cleaning materials, and an optional alternative limit on composite vapor pressure of the cleaning materials. Th ey also include the us e of add-on controls

with an overall emission reduction of at least 85 percent by mass.

In terms of applicability, EPA recomme nds applying the control recommendations

contained in the CTG to facilities that emit at least 6.8 kg/day (15 lb/day) of VOC from solvent cleaning activities before considerati on of controls in an ozone nonattainment area. Moreover, EPA also recommends ex clusions from CTG applicability those industries relevant to the product categorie s listed for regulation under CAA Section 183(e).

In Ventura County, solvent cleaning sour ces operations are regulated by several

individual District ru les, which cover all the product ca tegories listed for regulation under CAA Section 183(e). In addition, Ventura County has Rule 74.6, Surface Cleaning and Degreasing, that regulates those solvent cleaning operations not covered by other source-specific rules.

Evaluation In general, all coating operations, whic h includes spray gun cleaning, are regulated by source-specific rules, while parts cleaning operations are regulated by Rule 74.6. This

rule has a default VOC content limit for solv ent cleaning of 25 g/l, which is more2009 RACT SIP September 15, 2009

Page 2 Attachment 2 stringent than the 50 g/l RACT requirement for parts cleaners recommended by the CTG. Furthermore, Ventura County APCD currently permits all cleaning operations where annual VOC emissions exceed 200 lb/yr. A survey of all permitted sources in the county indicates that these operations may be classi fied into at least one of the following categories:

1) Facility that emits less than 15 lb/day of VOC before consideration of controls.

2) Subject to one of the VCAPCD rules that includes product categories regulated under CAA Section 183(e).

3) Subject to VCAPCD Rule 74.6, Surface Cleaning and Degreasing.

Although Rule 74.6 contains a vapor pr essure limit of 33 mm Hg at 20 o C for application equipment cleanup of coatings, adhesives, inks or resins, or for cleaning of electronic components or aerospace components, this re quirement applies to operations that are excluded by the CTG, including categories listed for regulatio n under CAA Section 183(e), categories with specific exemp tions under Bay Area AQMD Rule 8-4-16, categories subject to specif ic rules and exemptions under Bay Area AQMD Rule 8-4-117, or categories with special limits outlined in South Coast AQMD Rule 1171.

All of the industrial solvent cleaning operations in Ve ntura County meet CTG control recommendations, or fall within the exclusions outlined in the guidelines. This includes product categories listed for regulation under CAA Section 183(e), categories with specific exemptions under Ba y Area AQMD Rule 8-4-16, cate gories subject to specific rules and exemptions under Bay Area AQMD Ru le 8-4-117, or categories with special limits outlined in South Coast AQMD Rule 1171.

Conclusion Ventura County APCD rules governing indus trial solvent cleaning operations meet RACT requirements as recommended by the September 2006 CTG for industrial cleaning

solvents.2009 RACT SIP September 15, 2009

Page 3 Attachment 2 RACT Source Category

Lithographic Printing and Letterpress Printing

RACT Guidance Document Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing ( EPA-453/R-06-002 ; 9/06)

Background The EPA issued a CTG document in September 1993 entitled Control of Volatile Organic Compound Emissions from Offset Lithographic Printing and an alternative control techniques (ACT) document on offset lithographic printing in June 1994. At the time, these two documents established RACT guidelines for ozone nonattainment areas such as Ventura County. In September 2006, EPA published an updated CTG for Offset Lithographic Printing and Letterpress Printing.

Letterpress printing and offset lithographic printing have seve ral important similarities, including similar sources of VOC emissions and similar available VOC control approaches. “Lithographic pr inting” is a printing pr ocess where the image and non-image areas are chemically differentiated ; the image area is oil receptive, and the non-image area is water receptive. This me thod differs from other printing methods, where the image is a raised or recessed su rface. “Offset lithographic printing” is a printing process that transfers the ink film from th e lithographic plate to an intermediary surface (blanket), which, in turn, transf ers the ink film to the substrate.

The CTG recommends three mechanisms to reduce VOC emissions from offset lithographic printing and letterpr ess printing. These options are add-on controls, process modifications or work practices, and mate rial reformulation or substitution. The

recommended level of control for VOC emissions from heatset dryers is either 90 or 95 percent control efficiency, depending on the control device’s installation date.

In terms of applicability, EPA recommends th at the control options discussed in the CTG for cleaning materials and fountain solutions apply to any offset lithographic printing operation where the emissions associated wi th all aspects of the operation equal or exceed 6.8 kg/day (15 lb/day) actual emissions of VOC, or an equivalent level, before

consideration of controls.

EPA further recommends that the options fo r fountain solutions not be applied to sheet-fed presses with maximum sheet size of 11x17 inches or smaller, or to any press

with total fountain solution re servoir of less than one ga llon. These exclusions are

included because the recomme nded VOC (alcohol or alcohol substitute) content levels associated with such presses would yield a sm all emission reduction relative to the cost of achieving the reduction (e.g., changi ng and maintaining rollers).2009 RACT SIP September 15, 2009

Page 4 Attachment 2 Similarly, EPA recommends that the control approaches for cleaning materials discussed in the CTG apply to any letterpress pr inting operation where actual VOC emissions associated with all aspects of the operation eq ual or exceed 6.8 kg/day (15 lb/day), or an equivalent level, before consideration of c ontrols. These control options include: 1) limits on the VOC composite vapor pressure of cleaning mate rials; and 2) limits on the VOC content of cleaning materials, with an exclusion of 110 gal/yr of cleaning materials, which meet neither the low VOC composite vapor pressure recommendation nor the

lower VOC content recommenda tion and work practices.

EPA recommends a different applicability th reshold for heatset web offset lithographic printing and letterpress printi ng operations. Specifically, EP A recommends applying the

add-on control recommendations for heatset web offset lithographi c printing operations and heatset web letterpress prin ting operations only to those pr esses with potential to emit from the dryers, prior to contro ls, of at least 25 ton/yr of VOC (petroleum ink oil) from

heatset inks.

EPA also recommends providing printers with the option of using an enforceable limitation on potential emissions to keep an individual press below this 25 ton/yr potential to emit threshold. Guidance on limiting potential to emit from printing operations is provided in the technical s upport document (TSD) for Title V Permitting of Printing Facilities (see Appendix A). EPA believes add-on control for heatset presses with potential to emit below 25 ton/yr is t oo costly for the emission reduction that would

be achieved. EPA also recommends excludi ng heatset presses used for book printing and excluding heatset presses with a maximum we b width of 22 inches or less from the add-on control options. EPA believes add-on control for such heatset presses is too costly relative to the emission reduction that would be achieved.

Rule 74.19, Graphic Arts, limits ROC emissions fr om graphic arts operations. This rule was last amended on November 11, 2003, to make clerical corrections and to make the

rule more consistent with other District source-specific rules. On April 10, 2001, the rule was amended to satisfy state best avai lable retrofit control technology requirements and federal RACT requirements. This anal ysis will evaluate Rule 74.19, Graphic Arts,

to determine if it meets RACT based on the latest recommendations from the 2006 CTG.

Evaluation Rule 74.19 reduces ROC emissions by limiting the ROC content of inks, coatings, adhesives, and fountain solutions used in gr aphic arts operations. Solvent cleaners, which are the largest source of ROC emissions at these facilities, are regulated by ROC content and/or ROC composite partial vapor pressure.

An important aspect of Rule 74.19 is its applic ability to much smalle r sources than those recommended by the CTG. Graphic art so urces in Ventura County that emit over 200 lb/yr of ROC are required to meet all the requirements in the rule and must have APCD2009 RACT SIP September 15, 2009

Page 5 Attachment 2 permits. This cutoff level is significantly lower than the 15 lb/day (2.7 ton/yr) of ROC applicability threshold recommended by the CTG.

The impact of this more stringent cutoff level on ROC emissions from graphic arts operations in the county can be seen in th e list in Table 5 of all currently permitted lithographic printing and letterpr ess printing sources in the county. Table 5 shows that only the four largest sources would have b een controlled by the CTG compared to the twenty-nine sources listed in the table.

The twenty-five smaller sources controlled by Rule 74.19, but excluded from the CTG, emit 16.8 ton/yr of ROC. If you assume th at Rule 74.19 controls these sources by 30 percent, then Rule 74.19 reduces actual emission s by at least 7 ton/yr more than the CTG.

This is a conservative estimate since EPA assumes 70 percent cont rol effectiveness for

uncontrolled sources.

Another important difference between Ru le 74.19 and the CTG is that the CTG recommends a 110 gal/yr cleaning solvent ex emption per source. Rule 74.19 does not allow this exemption, and the resulting emissions reduced by Rule 74.19 are about 3 ton/yr. Thus, the total em issions reduced by Rule 74.19, when compared to the CTG, are at least 10 ton/yr of actual ROC emissi ons based on these different exemption levels.

Rule 74.19's 80 g/l (8 percent) VOC limit for fo untain solutions is less stringent than the Lithographic and Letterpress CTG's reco mmendation of 50 g/l (5 percent) alcohol

or alcohol substitutes for sheet-fed offset lithographic printing. The VOC Blue Book allows higher cutoffs than the CTG if em issions are <5 percent of the inventory. Fountain solution emissions are larger than 5 percent of the inve ntory, and there is no backstop in the permits, which allows fount ain solutions with VOC up to the rule limits. However, the alcohol limit does not apply to sources in Ventura County because they all use alcohol substitutes, mo st commonly certain glycol ethers. These additives have high boiling points and lowe r volatilities than traditional fountain solutions and are incorporated in small qua ntities (from 2 to 4 ounces per gallon of water) to produce a final mixed founta in solution less than 30 g/l.2009 RACT SIP September 15, 2009

Page 6 Attachment 2

Table 5 Lithographic Printing and Letterpress Printing Sources in Ventura County (Sorted by Actual ROC Emissions)

Facility Name APCD Permit Number Actual ROC Emissions

(ton/yr) Type of Printing SIC Code
Greater than 2.7 tons/yr
Crockett Graphics 0836 5.9 Lithography 2653 Ventura County Star 7067 5.1 Lithography 2752 Jano Graphics 7277 4.8 Lithography 2752 Ventura Printing 1143 3.0 Lithography 2759 Less than 2.7 tons/yr

Holden Color 7205 2.6 Lithography 2752 Custom Printing 7243 1.5 Lithography 2752 Clarks Printing 7270 1.3 Lithography 2759 Trend Graphics 7658 1.2 Lithography 2752

Bestforms 7047 1.1 Lithography/Letterpress 2752 Sir Speedy 7046 0.8 Lithography 2752 Fausset Printing 7290 0.8 Lithography 2752

Basic Business Forms 1059 0.7 Lithography/Letterpress 2752 Herald Printing 7041 0.7 Lithography 2759 Ace Graphics 7084 0.6 Lithography 2752

TFP Data 7074 0.5 Lithography 2752 Vanguard Printing 7283 0.5 Lithography 2752 AA Printing 7347 0.4* Commercial Printing 2750 Amp Graphics 7236 0.4* Lithography 2752 John Devine Printing 7042 0.4* Lithography 2759 Ojai Printing 7291 0.4* Lithography 2752 Precision Tag and Label 0568 0.4* Lithography 2752 Print N Image 7278 0.4* Lithography 2752 Quickprint Plus 7044 0.4* Lithography 2759 Signature Graphics 7309 0. 4* Lithography 2752 The Printing Press 7062 0.4 Lithography 2752 Ticket Factory 7156 0.4* Letterpress 2752 Coast Index 7082 0.3 Lithography/Screen 2752 Arms Printing 7115 0.1 Commercial Printing 2759 Flyer Web Printing 7234 0.1 Lithography 2752

Total Actual Emissions 35.6

* Actual ROC emissions from AA Printing, Amp Graphics, John Devine Printing, Ojai Printing, Precision Tag & Label,

Print N Image, Quickprint Plus, Signature Graphics, and Ticket Factory, were estimated based on graphics arts operations of similar size.2009 RACT SIP September 15, 2009

Page 7 Attachment 2 In any case, Rule 74.19 overall is more stringe nt than the CTG and, and as noted above,

achieves an additional 10 tons more emission reductions than would the CTG. Moreover, the entire rule is in the SIP and is federally enforceable. Staff estimated the potential lost emissions for the largest sources if they in crease their fountain solution emissions up to the Rule 74.19 limits. The potential loss was le ss than one ton of ROC per year from all
facilities. This means that Rule 74.19 is stil l significantly more effective than the CTG, even considering the difference in the fountain solution limits.

RACT Recommendation for Heatset Web Offset Printing

The CTG recommends add-on controls for heat set web offset lithographic printing and letterpress printing operations where the poten tial to emit is at least 25 ton/yr of ROC from heatset inks prior to the installation of controls. The source with the largest potential emissions in the county is the Ve ntura County Star newspaper with permitted emissions of 10.41 ton/yr of ROC. Thus, no existing sour ces in the county would be subject to this requirement. Any new sour ces would be subject to VCAPCD Rule 26.2, New Source Review, which requires best av ailable control tec hnology (BACT) for all new sources and emission offsets for any RO C or NOx sources where the potential to emit is greater than or equal to 5 ton/yr. These new source review requirements are much more stringent than the RACT recommendation in the CTG.

RACT Recommendation for Solvent Cleaners

Another RACT recommendation to reduce RO C emissions is to require the use of low-vapor pressure or low-ROC content solv ent cleaners. Examples include blanket washes, roller washes, plate cleaners, me tering roller cleaners, impression cylinder cleaners, rubber rejuvenators, and other cleaner s used for cleaning a press or press parts. The RACT recommendation for cleaning materials is an ROC composite vapor pressure less than 10 mm Hg at 20 o C, or cleaning material contai ning less than 70 weight percent ROC. The cleaning requirements in Rule 74.19 are summarized in Table 6.

The most common cleaners used in lithograp hic printing are the blanket and roller washes. For these two cleaning applications , the Rule 74.19 vapor pr essure requirement is identical to the CTG at 10 mm Hg at 20 o C, but the ROC conten t option at 2.5 lb/gal (about 33 percent ROC by weight) in Rule 74.19 is more stringent than the 70 percent by weight in the CTG. Another significant difference is the requirement for the repair and maintenance cleaners used for general press cleaning and repair. Rule 74.19 limits these cleaners to an ROC content of 50 g/l without the option of using a low vapor pressure cleaner. Although the cleaner requirements of Rule 74.19 are more stringent than the CTG, an estimate of emission savings could not be easily calculated given the available data in the permit files.2009 RACT SIP September 15, 2009

Page 8 Attachment 2

Table 6 Rule 74.19, Graphic Arts So lvent Cleaning Requirements

Solvent Cleaning Activity Limits ROC g/l (lb/gal) Limits ROC Composite
Partial Pressure mm Hg @ 20 o C

a. Surface Preparation 70 (0.58) Not Applicable b. Repair and Maintenance Cleaning 50 (0.42) Not Applicable c. Cleaning of Ink Application Equipment 1) General, unless listed below 100 (0.83) AND 3 2) Lithographic or Letterpress Printing i) Roller Wash 300 (2.5) OR 10 ii) Blanket Wash 300 (2.5) OR 10 iii) Metering Roller Cleaner 300 (2.5) OR 25 iv) Plate Cleaner 300 (2.5) OR 25

Conclusion Ventura County APCD Rule 74.19 meets or exceeds the RACT recommendations in the 2006 CTG for offset lithographic pr inting and letterpress printing.2009 RACT SIP September 15, 2009

Page 9 Attachment 2 RACT Source Category

Miscellaneous Metal and Plastic Parts Coatings

RACT Guidance Document Control Techniques Guidelines for Miscella neous Metal and Plastic Parts Coatings ( EPA-453/R-08-003 ; 09/08)

Background In September 2008, EPA published a CTG for Miscellaneous Metal and Plastic Parts Coating. The CTG provides control recomme ndations for reducing VOC emissions from the use of coatings applied to miscellaneous metal products and plastic parts. The miscellaneous metal product and plastic part s surface coatings categories under Section 183(e) of the CAA includes coatings that are ap plied to a wide range of metal and plastic parts and products. Such parts or products are constructed either par tially or entirely of metal or plastic.

Miscellaneous metal product and plastic pa rts surface coatings serve decorative, protective, and functional pur poses. Coatings protect me tal parts from corrosion by providing resistance to moisture , heat, and sometimes the outdoor elements. Plastic parts may be coated to provide color, texture, or protection, thus imp roving appearance and durability, and can also function to atte nuate electromagnetic interference/radio frequency interference signals, and to conceal mold lines and flaws in substrate surfaces.

There are two general emission control tec hniques for reducing VOC emissions from miscellaneous metal product and plastic part s coatings: pollution prevention measures, and emission capture and add-on control syst ems. Pollution prevention is the most prevalent control technique being used by the miscellaneous metal product and plastic parts surface coating facilities. Add-on control systems are available to these facilities,

but few facilities utilize this control technique.

In terms of applicability, the CTG recommends that the control appr oaches suggested in the CTG apply to each miscellaneous metal product and plastic parts surface coating unit at a facility where th e total actual VOC emissions from all miscellaneous metal product and plastic part surface coating operations, in cluding related cleaning activities, at the facility are equal to or exceed 6.8 kg/day (15 lb/day), or an equivalent level of 2.7 tons per 12-month rolling period, before consider ation of controls. The CTG does not recommend the control approaches for facilities that emit below that level because of the very small VOC emission reducti ons that could be achieved.

The District rule applicable to this CT G is Rule 74.12, Surface Coating of Metal Parts and Products. This RACT analysis will eval uate Rule 74.12 to determine if it meets

RACT based on the latest recommendations from the 2008 CTG.2009 RACT SIP September 15, 2009

Page 10 Attachment 2 Evaluation

Rule 74.12 controls ROC emissions from me tal parts and product coating operations through ROC content limits and transfer effici ency requirements. It does not apply to product coating operations regulat ed by other District coating rules such as architectural coatings (Rule 74.2), aerospace components (Rule 74.13), motor vehicles (Rule 74.18), or marine and freshwater vessels (Rule 74.24) . The rule also controls ROC emissions from materials used for surface preparation and cleanup.

There are five metal coating facilities in Ventura County with RO C emissions above the CTG applicability thresholds subject to Rule 74.12. These facilities are presented below

in Table 7.

Table 7 Average Actual ROC Emissions fr om Miscellaneous Metal Parts Coating Facilities Subject to VCAPCD Rule 74.12

Actual ROC Emissions* Facility Name APCD Permit Number ton/yr lb/day Business Activity A-1 Truck & Equipment 0207 2.83 21.80 Motor Vehicle Repair and Blasting Bend-Pak, Inc. 0505 2.56 19.67 Auto Repair Equipment Mfgr. G.I. Rubbish Company 7086 3.88 29.85 Trash Collection Haas Automation 7226 2.36 18.13 CNC Machine Tool Mfgr. Weatherford Oil Country 7297 2.09 16.09 Oil Production Tool Mfgr.

* Calculations assume 2080 hr/yr of operation and 260 day/yr.

A-1 Truck and Equipment is a facility that specializes in coating in-use heavy-duty government equipment. The CTG recommends that “state RACT rules provide facilities that coat bodies and/or body parts for new h eavier vehicles the opti on of meeting either the state RACT requirements for miscellaneous metals and plastic parts coatings or the state RACT requirements for auto and light-dut y truck coatings.” This facility does not coat new vehicles and Rule 74.12 does not appl y; the applicable District rule is Rule 74.18, Motor Vehicle and Mobile Equipment Co ating Operations. Therefore, the CTG does not apply to this operation.

Since actual emissions from th e four applicable sources in Table 7 exceed the 15 lb/day threshold, the analysis of Rule 74.12 is relevant.

For plastic parts coating operations in Ve ntura County, no source has actual emissions that exceed either the 2.7 ton/yr or 15 lb /day thresholds. See Table 8 for details.2009 RACT SIP September 15, 2009

Page 11 Attachment 2

Table 8 Average Actual ROC Emissions fr om All Coating Operations that Include Plastic Parts in Ventura County

Actual ROC Emissions Facility Name APCD Permit Number ton/yr lb/day Business Activity Perma Plaque Corp. 0523 0.36 2.77 Plastic to Wood Adhesives & Coating Data Exchange Corp. 0650 0.23 1.78 Metal & Plastic Parts Mfgr. & Coating Royal Coatings 0712 1.06 8.12 Metal & Plastic Parts Coating J & A Manufacturing 1106 1.38 10.63 Metal & Plastic Parts Coating WM J Matson Company 8017 0.01 0.60* Metal & Plastic Parts Coating

* Estimated actual based on 15 gall ons of material used during 2009

Actual emissions in Table 8 for the WM Matson Company are based on 15 gallons of material used during 2009. WM Matson is a new facility that commenced operations in Ventura County in February 2009. The only in spection of the facility occurred on March 25, 2009. Being such a new facility, no meani ngful actual emissions information was available at that time. In August 2009, staff obtained six months of actual surface coating material data from WM Matson. Projecting th is material out to a year, staff estimates that total facility ROC emissions for 2009 will be 0.38 ton/yr and 2.93 lb/day. These

estimates are less than the CTG thresholds.

So far in 2009, WM Matson has not coated any pl astic parts. Staff has estimated that 15 gallons of material may be used for plastic parts during the remainde r of 2009. On this basis, ROC emissions for plastic parts coating for 2009 will be 0.01 ton/yr and 0.60 lb/day. These amounts are less than the CTG thresholds.

In any case, WM Matson coats parts for th e aerospace industry, which is regulated by Rule 74.13. Plastic parts are not excluded fr om Rule 74.13. Therefore, plastic aerospace parts coating operations are s ubject to Rule 74.13. This is true for other plastic parts coating operations in Ventura County as well.

The September 2008 CTG recommends three alternatives for the control of ROC emissions from miscellaneous metal parts:

1) VOC content limits for each coating cat egory based on the use of low-VOC content coatings and specified application met hods to achieve good transfer efficiency.

2) Equivalent VOC emission rate limits base d on the use of a combination of low-VOC coatings, specified applicati on methods, and add-on controls.

3) An overall VOC control efficiency of 90 percent for add-on controls. In April 2008,

the District revised Rule 74.12 to raise th e control efficiency requirement to 90
percent.2009 RACT SIP September 15, 2009

Page 12 Attachment 2 This analysis of Rule 74.12 will focus on coat ing ROC limits and other applicable rule requirements.

Table 9 lists the ROC emission limits in the CTG and the related limits in Rule 74.12, SCAQMD Rule 1107, and Bay Area AQMD Rule 8- 19. As shown in Table 9, the Rule 74.12 limits are as, or more stringent than, thos e in the CTG. For the six CTG categories in which Rule 74.12 has no limit, either th e "General, One Com ponent" or "General, Multi-Component" limits would apply. These ge neral categories are either equivalent in stringency or more stringent than the CTG limits.

Table 9 Comparison Between Misc. Metal and Plastic Coating CTG and VCAPCD Rule 74.12, SCAQMD Ru le 1107 and BAAQMD Rule 8-19

Metal Furniture CTG VCAPCD
Rule 74.12 SCAQMD
Rule 1107 BAAQMD Rule 8-19
Baked Air Baked Air Baked Air Baked Air Coating Type lb/gal lb/gal lb/gal lb/gal lb/gal lb/gal lb/gal lb/gal General, One Comp 2.3 2.8 2. 3 2.3 2.3 2.3 2.3 2.8 General, Multi-Comp 2.3 2.8 2.3 2.8 2.3 2.8 2.3 2.8
Extreme Hi-Gloss 3.0 3.5 3. 0 3.5 3.0 2.8 3.0 3.5
Extreme Performance 3.0 3.5 3.0 3.5 3.0 3.5 3.5 3.5

Heat Resistant 3.0 3.5 3.0 3.5 3.0 3.5 3.0 3.5

Metallic 3.5 3.5 3.0 3.5 3.5 3.5 3.0 3.5 Pretreatment Coating 3.5 3.5 2.3 2.8 3.5 3.5 3.5 3.5
Solar Absorbent 3.0 3.5 3.0 3.5 3.0 3.5 3.0 3.5 Camouflage 3.5 3.5 3.0 3.5 3.5 3.5 3.0 3.5 Etching Filler 3.5 3.5 3. 5 3.5 3.5 3.5 --- --- High Perf. Arch. 6.2 6.2 3.5 3.5 3.5 3.5 3.5 3.5 High Temperature 3.5 3.5 3.5 3.5 3.5 3.5 3.5 3.5
Mold Seal 3.5 3.5 3.5 3.5 3.5 3.5 --- --- Pan Backing 3.5 3.5 3.5 3.5 3.5 3.5 --- ---
Silicone Release 3.5 3.5 3.5 3.5 3.5 3.5 3.5 3.5 Vacuum Metalizing 3.5 3.5 3.5 3.5 3.5 3.5 --- --- Military Specification 2.3 2. 8 --- --- 2.3 2.8 --- --- Prefab Arch. 1 Comp. 2.3 3.5 --- --- 2.3 2.3 --- ---
Prefab Arch. Multi. 2.3 3. 5 --- --- 2.3 2.8 --- --- Touch Up 3.0 3.5 -- - --- 3.0 4.5 --- --- Repair 3.0 3.5 -- - --- 3.0 4.5 --- --- Electric Insulating Var. 3.5 3.5 --- --- 3.5 3.5 --- ---2009 RACT SIP September 15, 2009

Page 13 Attachment 2 Rule 74.12 transfer efficiency requirements incl ude electrostatic app lication, operated at a minimum of 60 kV; flow coat applicati on, dip coat application, high-volume, low-pressure application, hand application, or any other mean s demonstrated to achieve at least 65 percent transfer efficiency.

In lieu of complying with the specifie d ROC content limits, air pollution control equipment may be used provided the combined capture and control device efficiency reduces emissions by at least 90 percent by we ight and approved by the District by an Authority to Construct and Pe rmit to Operate. Rule 74.12’s provisions regarding control device capture efficiency and coating transfer efficiency are the same or similar to those recommended by the CTG.

Rule 74.12 limits the ROC content of material used for substrate cleaning to no more than 25 g/l of material. It also limits material for either spray equipm ent cleaning or cleanup to an ROC content of not more than 25 g/l of material.

An important aspect of Rule 74.12 is its applic ability to much smalle r sources than those recommended by the CTG. Metal parts a nd product coating operations in Ventura County that emit over 200 lb/yr of ROC are requir ed to meet the requirements in the rule, and are required to have APCD permits to en force those requirements. This cutoff level is significantly lower than the 15 lb/day threshold in the CTG, which corresponds to 2.7 ton/yr of ROC.

A significant difference between the CTG a nd Rule 74.12 involves work practices for coating and cleaning activities. Rule 74.12 speci fies that all ROC containing materials, including, but not limited to surface coatin gs, cleanup solvents, or surface preparation

materials shall be stored in closed containers that are nonabsorbent and do not leak.

The CTG recommends more specific and extensive work practices for coating activities: 1) store all VOC -containing coatings, thinners , and coating-related waste materials in closed containers; 2) ensure that mixing and storage containers used for VOC-containing coatings, thinners, and coating-re lated waste materials are kept closed at all times except when depositing or removing these materials; 3) minimize spills of VOC-containing coatings, thinners, and coatin g-related waste materi als; and 4) convey VOC-containing coatings, thinners, and coatin g-related waste materi als from one location to another in closed containers or pipes.

The CTG also recommends the following work pr actices for cleaning materials: 1) store all VOC-containing cleaning materials and used shop towels in closed containers; 2) ensure that storage containers used fo r VOC-containing cleaning materials are kept closed at all times except when depositing or removing these materials; 3) minimize spills of VOC-containing cleaning materi als; 4) convey VOC-containing cleaning

materials from one location to another in clos ed containers or pipe s; and 5) minimize2009 RACT SIP September 15, 2009

Page 14 Attachment 2 VOC emissions from cleaning of applicati on, storage, mixing, and conveying equipment by ensuring that equipment cleaning is perfor med without atomizing the cleaning solvent and all spent solvent is capt ured in closed containers.

Although the CTG recommendations for coating and cleanup work practices are more extensive than those in Rule 74.12, it does no t contain VOC-content li mits for substrate cleaning and cleanup activities as does Rule 74.12. Rule 74.12 specifies that no person

shall use a material for substrate surface clean ing and for either spray equipment cleaning or cleanup that has an ROC content exceeding 25 g/l of material.

Rule 74.12 also contains severa l recordkeeping requirements to help ensure compliance

with the rule. The CTG does not co ntain recordkeeping recommendations.

Conclusion Ventura County APCD Rule 74.12 meets or exceeds the RACT recommendations in the 2008 CTG for miscellaneous metal and plastic parts coatings.

OVERALL RACT CONCLUSION

District staff found that all District ru les applicable to the 2006, 2007, and 2008 CTGs

meet or exceed RACT recommendations.ATTACHMENT IV

SEPTEMBER 15, 2009
VENTURA COUNTY AIR POLLUT ION CONTROL BOARD PACKET
FOR THE 2009 REASONABLY AVAILABLE CONTROL TECHNOLOGY
STATE IMPLEMENTATION PLAN REVISIONATTACHMENT V

CERTIFICATE OF PUBLICATION – PUBLIC NOTICE