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 CHECKLIST 

Attachment 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 the Plan and That the District Followed All 

of the Requirements of its Administrative Procedures Act:

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

adopting the draft 2009 Reasonably Available Control Technology 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 Technology 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 Attachment 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 Publication 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 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 

ATTACHMENT II 

A RESOLUTION OF THE VENTURA COUNTY AIR POLLUTION CONTROL BOARD 

APPROVING AND ADOPTING THE 2009 REASONABLY AVAILABLE 

CONTROL TECHNOLOGY STATE IMPLEMENTATION PLAN REVISION 





ATTACHMENT III 

FINAL VENTURA COUNTY AIR POLLUTION CONTROL DISTRICT 

2009 REASONABLY AVAILABLE CONTROL TECHNOLOGY 

STATE IMPLEMENTATION PLAN REVISION 

VENTURA COUNTY AIR POLLUTION 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 ambient air quality standards (NAAQS). The 

NAAQS are set by the U.S. Environmental Protection Agency (EPA) as the maximum 

concentrations in the atmosphere for specific air contaminants to protect public health 

and welfare. The principal mechanism at the state and local level for complying with the 

CAAA is the State Implementation Plan (SIP). A SIP outlines the programs, actions, and 

commitments a state will carry out to implement its responsibilities under the CAAA. 

Sections 182(b)(2) and 182(f) of the CAAA (42 U.S.C. §7511(a)) require ozone 

nonattainment areas to implement reasonably available control technology (RACT) 

emission standards for sources of air pollution 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 nitrogen 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 Technology State Implementation 

Plan Revision (2009 RACT SIP) is to demonstrate that all District rules applicable to 

ozone precursor emissions meet or exceed reasonably available control technology 

(RACT) and fulfill RACT requirements for the federal 8-hour ozone standard. This 

process is necessary because Ventura 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 controls 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 Act to ensure that significant source categories at 

major sources of ozone precursor emissions are controlled to a “reasonable” extent, but not necessarily to 

the more stringent best available control technology (BACT) or maximum achievable control technology 

(MACT) levels expected for new or modified major stationary sources. 

Page 1 

Attachment III 
2009 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 classified as moderate ozone nonattainment 

or higher were to certify that their rules 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 contained in a letter (March 9, 2006) from 

EPA Region 9 to the California Air Resources Board (CARB) and is presented below: 

• Describe efforts to identify all source categories within the District requiring RACT, 

including CTG sources (i.e., covered by an EPA 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 CTGs, alternative control techniques (ACT) 

guidance, MACT standards, new source performance 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 Air Pollution Control Officers Association 

(CAPCOA) September 2003 Potential All Feasible Measures (AFM) Report to 

help demonstrate RACT. If so, the RACT SIP should certify that local regulations are 

equivalent to AFM, justify the assumption that the AFM fulfilled RACT in 2003, and 

include some sort of certification or demonstration that no additional controls have 

become more reasonably available since then. 

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 III 
2009 RACT SIP 

September 15, 2009 

with more current and stringent control requirements 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 sources and major non-CTG sources with a 

potential to emit 100 tons per year or greater 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 reclassification because photochemical modeling, along with other 

analyses, conducted for the Ventura County 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 standard. 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 the 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 Ventura County either has no sources or has 

sources but the sources area below the CTG applicability thresholds. Attachment 2, 

“Ventura County APCD 2009 RACT 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 sources in the county; or, 2) no subject sources with emissions 

Page 3 

Attachment III 
2009 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 sources subject to the 

CTGs. 

Ventura County does not have sources for 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 less 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 emissions above the relevant CTG applicability 

thresholds for the following three CTG categories (see Attachment 2): 

• Offset Lithographic Printing 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 revisions, the District 

has fulfilled RACT certification requirements for a serious federal 8-hour ozone 

nonattainment area. 

Page 4 

Attachment III 
2009 RACT SIP 

September 15, 2009 

Page 5 

Attachment III 

CALIFORNIA ENVIRONMENTAL 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 1 

Source Categories, CTG Documents Issued Since Adoption of the 

Ventura County 2006 RACT SIP, and Applicable District Rules 

Page 6 

Attachment III

Source 

Category CTG Document Applicability

Subject 

Sources?

VCAPCD 

Rule

Date Last 

Amended

Industrial Cleaning Solvents 

Control Techniques Guidelines for Industrial Cleaning Solvents (EPA-453/R-06-001; 

9/06) 

Applies to industries that have to use organic solvent for cleaning unit operations such as mixing vessels (tanks), spray booths, and parts cleaners, where a facility emits at least 6.8 kg/day (15 lb/day) of VOC before consideration of controls in an ozone nonattainment area. The cleaning activities for removal of foreign material from substrate being cleaned includes actions (activities) such as wiping, flushing, or spraying. 

Yes (see Attachment 2) 

a) Various b) 74.6 - Surface Cleaning and Degreasing 

NA** 11/11/03 

Flexible Packaging Printing 

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

9/06) 

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

No (see Attachment 1) 

NA NA 

Flat Wood Paneling Coatings 

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

9/06) 

Applies to facilities that apply flat wood paneling coatings that emit at least 6.8 kg/day (15 lb/day) of VOC before consideration of controls. 

No (see Attachment 1) 

 NA NA 

Offset Lithographic Printing and Letterpress Printing 

Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing (EPA-453/R-06-002, 

9/06) 

Applies to cleaning materials and fountain solutions used in any offset lithographic printing operation where the emissions associated with 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. Also applies to heatset web offset lithographic printing operations and heatset web letterpress printing operations with potential to emit from the dryer, prior to controls, at least 25 ton/yr of VOC (petroleum ink oil) from heatset inks. 

Yes (see Attachment 2) 

Rule 74.19 - Graphic Arts 

 11/11/03 
Page 7 

Attachment III

Source 

Category CTG Document Applicability

Subject 

Sources?

VCAPCD 

Rule

Date Last 

Amended

Large Appliance Coatings 

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

9/07) 

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

No (see Attachment 1) 

NA NA 

Metal Furniture Coatings 

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

9/07) 

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

No (see Attachment 1) 

NA NA 

Paper, Film, and Foil Coatings 

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

9/07) 

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

No (see Attachment 1) 

NA NA 

Miscellaneous Metal and Plastic Parts Coatings 

Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings (EPA-453/R-08-003, 

9/08) 

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

Yes (see Attachment 2) 

74.12 – Miscellaneous Metal Parts and Products 

4/8/08 

Fiberglass Boat Manufacturing 

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

9/08) 

Applies to facilities that manufacture hulls or decks of boats from fiberglass, or build molds to make fiberglass boat hulls or decks, where the total actual VOC emissions, including cleaning activities, from all 

fiberglass boat-manufacturing operations covered by the CTG are at least 6.8 kg/day (15 lb/day) of VOC before consideration of controls. 

No (see Attachment 1) 

 NA NA 

Miscellaneous Industrial Adhesives 

Control Techniques Guidelines for Miscellaneous Industrial Adhesives (EPA-453/R-08-005, 

9/08) 

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

No (see Attachment 1) 

NA NA 
Page 8 

Attachment III

Source 

Category CTG Document Applicability

Subject 

Sources?

VCAPCD 

Rule

Date Last 

Amended

Automobile and Light-Duty Truck Assembly Coatings 

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

9/08) 

Applies to VOC emissions stemming from the use of coatings in automobile and light-duty truck assembly coating operations. 

No (see Attachment 1) 

NA NA 

* Date of EPA Federal Register Notice ** Not applicable
ATTACHMENT 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 federal Clean Air Act plan, 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 sources locate in the county, they 

will be subject to the District’s New Source Review requirements, which are more 

stringent than RACT. 

Conclusion 

Since there are no stationary sources in Ventura County for the four CTG categories 

listed above, negative declarations for these CTG categories are appropriate. 

Page 1 

Attachment 1
2009 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 Industrial Adhesives 

(EPA-453/R-08-005; 9/08) 

The 2008 CTG for miscellaneous industrial adhesives provides control recommendations 

for reducing VOC emissions from miscellaneous industrial adhesives and adhesive 

primer application processes. The miscellaneous industrial adhesives product category 

includes adhesives (including adhesive primers used in conjunction with certain types of 

adhesives) used at industrial manufacturing and repair facilities for a wide variety of 

products and equipment that operate adhesives application processes. The miscellaneous 

industrial adhesives product category does not include adhesives that are addressed by 

CTGs already issued for categories listed under CAA Section 183(e) or by earlier CTGs. 

These include the CTGs issued under Section 183(e) for aerospace coatings; metal 

furniture coatings; large appliance coatings; flat wood paneling coatings; paper, film, and 

foil coatings; offset lithographic printing and letterpress printing; and flexible package 

printing. Coil coating, fabric coating, and rubber tire manufacturing were not listed under 

CAA Section 183(e). However, they were the 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 industrial adhesive application process at a 

facility where the total actual VOC emissions from all miscellaneous industrial adhesive 

application processes at that facility, including related cleaning activities, are equal to or 

exceed 6.8 kg/day (15 lb/day), or an equivalent level such as 2.7 tons per 12-month 

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 

considered to be an incidental 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 Sealants, 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 composite partial vapor pressure. 

Page 2 

Attachment 1 
2009 RACT SIP 

September 15, 2009 

An important aspect of Rule 74.20 is its applicability to much smaller 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. Consequently, 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 their ROC emissions, are presented below in 

Table 2. As can be seen from Table 2, ROC emissions associated with each of the 

facilities are below the CTG’s applicability thresholds. It should be noted that the two 

largest sources in Table 2, Pentair 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 Products 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 permitted ROC emissions are provided for information 

purposes 

Conclusion 

None of the adhesive operations in Ventura County are subject to the 2008 CTG for 

miscellaneous industrial adhesives because their emissions are below the CTG 

Page 3 

Attachment 1 
2009 RACT SIP 

September 15, 2009 

applicability thresholds and, therefore, a negative declaration for this CTG category is 

appropriate. 

Page 4 

Attachment 1 
2009 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 paper, 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 materials 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 applicability level expressed on a monthly basis 

(e.g., 450 lb/month), an equivalent applicability level expressed 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 might conduct flexible package printing is the 

Proctor and Gamble facility in Oxnard, California, which manufactures consumer paper 

products. That facility conducts only very limited package printing. Product packages 

used at the Oxnard facility are preprinted at facilities outside 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 than CTG applicability threshold. 

Conclusion 

The only package printing operation in Ventura County that might be subject to the 2006 

CTG for flexible package printing falls below the CTG applicability thresholds and, 

therefore, a negative declaration for this CTG category is appropriate. 

Page 5 

Attachment 1 
2009 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 coating 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 substrate is the furniture or components of 

furniture constructed entirely or partially from metal. Metal furniture includes, but is not 

limited to, the following types of products: household, office, institutional, laboratory, 

hospital, public building, restaurant, barber and beauty shop, and dental furniture, as well 

as components of these products. Metal furniture also includes office and store fixtures, 

partitions, shelving, lockers, lamps and lighting fixtures, and wastebaskets. Metal 

furniture coatings include paints and adhesives and are typically applied without a 

primer. Higher solids and powder coatings are 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 activities, are equal to or exceed 6.8 kg/day (15 lb/day), or an 

equivalent level such as 2.7 tons per 12-month 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 considered an incidental level of solvent usage that 

could be expected even in facilities that use very low-solvent coatings, 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 1 
2009 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 facilities 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 applicability threshold of 15 lb/day. 

District staff contacted Artistic Design and verified that they 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 their emissions are below the CTG applicability 

thresholds and, therefore, a negative declaration for this CTG category is appropriate. 

Page 7 

Attachment 1 
2009 RACT SIP 

September 15, 2009 

RACT Source Category

Fiberglass Boat Manufacturing Materials 

RACT Guidance Document 

Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials 

(EPA-453/R-08-004; 9/08) 

The 2008 CTG for fiberglass boat manufacturing provides control recommendations for 

reducing VOC emissions from the use of gel coats, resins, and materials used to clean 

application equipment used in fiberglass boat 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 “fiberglass boat manufacturing 

facilities”). 

The CTG recommendations do not extend to facilities 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 decks, then the manufacture of 

all other fiberglass boat parts, including small parts such as hatches, seats, and lockers are 

covered. The CTG’s recommended control approaches 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 fiberglass 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 considered adhesives and are addressed in the CTG. 

As discussed in the CTG, EPA does not recommend 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 could 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, are presented in Table 4. The CTG does not 

apply to these facilities because their ROC emissions are below the CTG applicability 

thresholds. 

Page 8 

Attachment 1 
2009 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 manufacturing facilities in Ventura County, Electra 

Craft in Westlake Village (Permit No. 7360), and two Anchors Way Marine Centers in 

the Cities of Ventura and Oxnard (Permit Nos. 253 and 1391, respectively). The CTG 

does not apply to Electra Craft because the hulls 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 manufacturers in Ventura County are subject to the 2008 CTG 

for fiberglass boat manufacturing because their emissions are below the CTG 

applicability thresholds and, therefore, a negative declaration for this CTG category is 

appropriate. 

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2009 RACT SIP 

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Attachment 2 

ATTACHMENT 2 

VENTURA COUNTY APCD 

2009 RACT CERTIFICATIONS 

RACT Source Category

Industrial Cleaning Solvents 

RACT Guidance Document 

Control Techniques Guidelines for 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 removed from parts, products, tools, machinery, 

equipment, vessels, floors, walls, and other work production related work areas for a 

variety of reasons including safety, operability, and to avoid product contamination.

The recommended measures for controlling emissions of VOC from the use, storage, and 

disposal of industrial cleaning solvents includes work practice standards, limitations on 

VOC content of the cleaning materials, and an optional alternative limit on composite 

vapor pressure of the cleaning materials. They also include the use of add-on controls 

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

In terms of applicability, EPA recommends 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 consideration of controls in an ozone nonattainment 

area. Moreover, EPA also recommends exclusions from CTG applicability those 

industries relevant to the product categories listed for regulation under CAA Section 

183(e). 

In Ventura County, solvent cleaning sources operations are regulated by several 

individual District rules, which cover all the product categories 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, which 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 solvent cleaning of 25 g/l, which is more 
2009 RACT SIP 

September 15, 2009 

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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 classified 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 pressure limit of 33 mm Hg at 20o

C for application 

equipment cleanup of coatings, adhesives, inks or resins, or for cleaning of electronic 

components or aerospace components, this requirement applies to operations that are 

excluded by the CTG, including categories listed for regulation under CAA Section 

183(e), categories with specific exemptions under Bay Area AQMD Rule 8-4-16, 

categories subject to specific 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 Ventura 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 Bay Area AQMD Rule 8-4-16, categories subject to specific 

rules and exemptions under Bay Area AQMD Rule 8-4-117, or categories with special 

limits outlined in South Coast AQMD Rule 1171. 

Conclusion 

Ventura County APCD rules governing industrial solvent cleaning operations meet 

RACT requirements as recommended by the September 2006 CTG for industrial cleaning 

solvents. 
2009 RACT SIP 

September 15, 2009 

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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 several important similarities, 

including similar sources of VOC emissions and similar available VOC control 

approaches. “Lithographic printing” is a printing process 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 method differs from other printing methods, 

where the image is a raised or recessed surface. “Offset lithographic printing” is a 

printing process that transfers the ink film from the lithographic plate to an intermediary 

surface (blanket), which, in turn, transfers the ink film to the substrate. 

The CTG recommends three mechanisms to reduce VOC emissions from offset 

lithographic printing and letterpress printing. These options are add-on controls, process 

modifications or work practices, and material 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 that the control options discussed in the CTG 

for cleaning materials and fountain solutions apply to any offset lithographic printing 

operation where the emissions associated with 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 for 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 reservoir of less than one gallon. These exclusions are 

included because the recommended VOC (alcohol or alcohol substitute) content levels 

associated with such presses would yield a small emission reduction relative to the cost of 

achieving the reduction (e.g., changing and maintaining rollers). 
2009 RACT SIP 

September 15, 2009 

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Attachment 2 

Similarly, EPA recommends that the control approaches for cleaning materials discussed 

in the CTG apply to any letterpress printing operation where actual VOC emissions 

associated with all aspects of the operation equal or exceed 6.8 kg/day (15 lb/day), or an 

equivalent level, before consideration of controls. These control options include: 1) 

limits on the VOC composite vapor pressure of cleaning materials; 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 recommendation and work practices. 

EPA recommends a different applicability threshold for heatset web offset lithographic 

printing and letterpress printing operations. Specifically, EPA recommends applying the 

add-on control recommendations for heatset web offset lithographic printing operations 

and heatset web letterpress printing operations only to those presses with potential to emit 

from the dryers, prior to controls, 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 support 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 too costly for the emission reduction that would 

be achieved. EPA also recommends excluding heatset presses used for book printing and 

excluding heatset presses with a maximum web 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 from 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 available retrofit control technology requirements 

and federal RACT requirements. This analysis 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 graphic 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 applicability to much smaller sources than those 

recommended by the CTG. Graphic art sources in Ventura County that emit over 200 

lb/yr of ROC are required to meet all the requirements in the rule and must have APCD 
2009 RACT SIP 

September 15, 2009 

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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 the list in Table 5 of all currently permitted 

lithographic printing and letterpress printing sources in the county. Table 5 shows that 

only the four largest sources would have been 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 that Rule 74.19 controls these sources by 30 

percent, then Rule 74.19 reduces actual emissions by at least 7 ton/yr more than the CTG. 

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

uncontrolled sources. 

Another important difference between Rule 74.19 and the CTG is that the CTG 

recommends a 110 gal/yr cleaning solvent exemption 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 emissions reduced by Rule 74.19, when compared to the CTG, 

are at least 10 ton/yr of actual ROC emissions based on these different exemption levels. 

Rule 74.19's 80 g/l (8 percent) VOC limit for fountain solutions is less stringent than 

the Lithographic and Letterpress CTG's recommendation 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 emissions are <5 percent of the inventory. 

Fountain solution emissions are larger than 5 percent of the inventory, and there is no 

backstop in the permits, which allows fountain 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, most commonly certain glycol ethers. These 

additives have high boiling points and lower volatilities than traditional fountain 

solutions and are incorporated in small quantities (from 2 to 4 ounces per gallon of 

water) to produce a final mixed fountain solution less than 30 g/l. 
2009 RACT SIP 

September 15, 2009 

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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 

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Attachment 2 

In any case, Rule 74.19 overall is more stringent 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 increase their fountain solution emissions up to 

the Rule 74.19 limits. The potential loss was less than one ton of ROC per year from all 

facilities. This means that Rule 74.19 is still 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 heatset web offset lithographic printing and 

letterpress printing operations where the potential 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 Ventura County Star newspaper with permitted 

emissions of 10.41 ton/yr of ROC. Thus, no existing sources in the county would be 

subject to this requirement. Any new sources would be subject to VCAPCD Rule 26.2, 

New Source Review, which requires best available control technology (BACT) for all 

new sources and emission offsets for any ROC 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 ROC emissions is to require the use of 

low-vapor pressure or low-ROC content solvent cleaners. Examples include blanket 

washes, roller washes, plate cleaners, metering roller cleaners, impression cylinder 

cleaners, rubber rejuvenators, and other cleaners 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 20oC, or cleaning material containing less than 70 weight percent 

ROC. The cleaning requirements in Rule 74.19 are summarized in Table 6. 

The most common cleaners used in lithographic printing are the blanket and roller 

washes. For these two cleaning applications, the Rule 74.19 vapor pressure requirement 

is identical to the CTG at 10 mm Hg at 20o

C, but the ROC content 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 

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Attachment 2 

Table 6 

Rule 74.19, Graphic Arts Solvent Cleaning Requirements 

Solvent Cleaning Activity 

Limits 

ROC 

g/l (lb/gal) 

Limits 

ROC Composite

Partial Pressure

mm Hg @ 20o

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 printing and letterpress printing. 
2009 RACT SIP 

September 15, 2009 

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Attachment 2 

RACT Source Category

Miscellaneous Metal and Plastic Parts Coatings 

RACT Guidance Document 

Control Techniques Guidelines for Miscellaneous 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 recommendations for reducing VOC emissions from 

the use of coatings applied to miscellaneous metal products and plastic parts. The 

miscellaneous metal product and plastic parts surface coatings categories under Section 

183(e) of the CAA includes coatings that are applied to a wide range of metal and plastic 

parts and products. Such parts or products are constructed either partially or entirely of 

metal or plastic.

Miscellaneous metal product and plastic parts surface coatings serve decorative, 

protective, and functional purposes. Coatings protect metal 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 improving appearance and 

durability, and can also function to attenuate electromagnetic interference/radio 

frequency interference signals, and to conceal mold lines and flaws in substrate surfaces.

There are two general emission control techniques for reducing VOC emissions from 

miscellaneous metal product and plastic parts coatings: pollution prevention measures, 

and emission capture and add-on control systems. 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 approaches suggested in 

the CTG apply to each miscellaneous metal product and plastic parts surface coating unit 

at a facility where the total actual VOC emissions from all miscellaneous metal product 

and plastic part surface coating operations, including 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 consideration of controls. The CTG does not 

recommend the control approaches for facilities that emit below that level because of the 

very small VOC emission reductions that could be achieved. 

The District rule applicable to this CTG is Rule 74.12, Surface Coating of Metal Parts 

and Products. This RACT analysis will evaluate Rule 74.12 to determine if it meets 

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

September 15, 2009 

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Attachment 2 

Evaluation

Rule 74.12 controls ROC emissions from metal parts and product coating operations 

through ROC content limits and transfer efficiency requirements. It does not apply to 

product coating operations regulated 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 ROC 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 from 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 heavier vehicles the option of meeting either 

the state RACT requirements for miscellaneous metals and plastic parts coatings or the 

state RACT requirements for auto and light-duty truck coatings.” This facility does not 

coat new vehicles and Rule 74.12 does not apply; the applicable District rule is Rule 

74.18, Motor Vehicle and Mobile Equipment Coating Operations. Therefore, the CTG 

does not apply to this operation. 

Since actual emissions from the 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 Ventura 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 

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Attachment 2 

Table 8 

Average Actual ROC Emissions from 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 gallons 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 inspection of the facility occurred on March 

25, 2009. Being such a new facility, no meaningful 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 this 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 plastic parts. Staff has estimated that 15 

gallons of material may be used for plastic parts during the remainder 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 the aerospace industry, which is regulated by 

Rule 74.13. Plastic parts are not excluded from Rule 74.13. Therefore, plastic aerospace 

parts coating operations are subject 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 category based on the use of low-VOC content 

coatings and specified application methods to achieve good transfer efficiency. 

2) Equivalent VOC emission rate limits based on the use of a combination of low-VOC 

coatings, specified application 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 the control efficiency requirement to 90 

percent. 
2009 RACT SIP 

September 15, 2009 

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Attachment 2 

This analysis of Rule 74.12 will focus on coating 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, those in the CTG. For the six CTG categories 

in which Rule 74.12 has no limit, either the "General, One Component" or "General, 

Multi-Component" limits would apply. These general 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 Rule 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 

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Attachment 2 

Rule 74.12 transfer efficiency requirements include electrostatic application, operated at a 

minimum of 60 kV; flow coat application, dip coat application, high-volume, 

low-pressure application, hand application, or any other means demonstrated to achieve 

at least 65 percent transfer efficiency. 

In lieu of complying with the specified 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 weight and approved by the District by an 

Authority to Construct and Permit 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 equipment 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 applicability to much smaller sources than those 

recommended by the CTG. Metal parts and product coating operations in Ventura 

County that emit over 200 lb/yr of ROC are required to meet 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. 

A significant difference between the CTG and Rule 74.12 involves work practices for 

coating and cleaning activities. Rule 74.12 specifies that all ROC containing materials, 

including, but not limited to surface coatings, 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-related waste materials are kept closed at 

all times except when depositing or removing these materials; 3) minimize spills of 

VOC-containing coatings, thinners, and coating-related waste materials; and 4) convey 

VOC-containing coatings, thinners, and coating-related waste materials from one location 

to another in closed containers or pipes. 

The CTG also recommends the following work practices for cleaning materials: 1) store 

all VOC-containing cleaning materials and used shop towels in closed containers; 2) 

ensure that storage containers used for VOC-containing cleaning materials are kept 

closed at all times except when depositing or removing these materials; 3) minimize 

spills of VOC-containing cleaning materials; 4) convey VOC-containing cleaning 

materials from one location to another in closed containers or pipes; and 5) minimize 
2009 RACT SIP 

September 15, 2009 

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Attachment 2 

VOC emissions from cleaning of application, storage, mixing, and conveying equipment 

by ensuring that equipment cleaning is performed without atomizing the cleaning solvent 

and all spent solvent is captured in closed containers.

Although the CTG recommendations for coating and cleanup work practices are more 

extensive than those in Rule 74.12, it does not contain VOC-content limits 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 cleaning and for either spray equipment cleaning 

or cleanup that has an ROC content exceeding 25 g/l of material. 

Rule 74.12 also contains several recordkeeping requirements to help ensure compliance 

with the rule. The CTG does not contain 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 rules applicable to the 2006, 2007, and 2008 CTGs 

meet or exceed RACT recommendations. 
ATTACHMENT IV 

SEPTEMBER 15, 2009 

VENTURA COUNTY AIR POLLUTION CONTROL BOARD PACKET 

FOR THE 2009 REASONABLY AVAILABLE CONTROL TECHNOLOGY 

STATE IMPLEMENTATION PLAN REVISION 



























































ATTACHMENT V 

CERTIFICATE OF PUBLICATION – PUBLIC NOTICE