Ventura County Air Pollution Control District

DRAFT 2014 RACT ANALYSES ( subject to revision)

BACKGROUND

Sections 182(b)(2) and 182(f) of the federal Clean Air Act (42 U.S.C. §7511a) require that ozone nonattainment areas implement reasonably available c ontrol technology (RACT) for sources that are subject to Control Techniques Guidelines (CTG) issued by EPA and for “major sources” of VOC and NOx, which are ozone precursors. RACT is defined as the lowest emissions limitation that a particular source is c apable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility (44 FR 53762; September 17, 1979).

RACT requirements are included in the Clean Air Act to assure that significant em ission 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) , “lowest achievable emission rate” (LAER) or “maximum

achieva ble control technology” (MACT) levels expected of new or modified major stationary sources.

On June 6, 2013, the USEPA issued a proposed rule to address a range of implementation requirements for the 2008 National Ambient Air Quality Standards (NAAQS) for ground

level ozone. Among those are requirements that State Implementation Plans ( SIPs ) for ozone nonattainment areas provide for R ACT

. According to the ozone rule, areas classified as moderate or higher ozone nonattainment areas must submit revisions t o their SIPs

demonstrati ng that their current rules fulfil l 8

- hour ozone RACT for all CTG categories and all major, non

- CTG sources.

RACT demonstrations can be made with either a RACT determination, and with final implementation dates no later than the fi rst ozone season that occurs thirty months (30) later; or by a certification that previously

- required RACT controls represent RACT for

the 8

- hour ozone standard. Alternatively, air agencies in nonattainment areas may adopt “negative declarations” document ing that the area has no stationary sources in a CTG

source category.

C TGs define RACT for existing sources of air pollution. Emission sources covered by

CTGs are known as CTG sources. Some CTGs specify the minimum size of sources to which they apply. Where a CTG does not specify the minimum size of the source to which it applies

, or there is no CTG for a source category, states are required to apply RACT to sources in nonattainment areas that exceed that area’s statutory major stationary

source thresho ld for its ozone nonattainment classification. Therefore, since the Ventura County Air Pollution Control District (VCAPCD or “District”) is classified a “serious” ozone nonattainment area, a major source is defined as one with the potential to emit

greate r than 50 tons per year of volatile organic compounds ( VOC ) and/or nitrogen oxides ( NOx )

.2014 RACT Analysi s Page 2

RACT EVALUATIONS

Staff evaluated all District VOC * and/or NOx prohibitory rules that apply to CTG source categories and/or ma

jor sources of ozone precursors in Ventu ra County. All rules applicable to CTG source categories were determined to meet or exceed the CTG requirements during the 2006 and 2009 RACT SIP updates

, so the rules were not compared to CTG requirements again

. † However, since some CTGs have not been

u pdated for many years, staff compared District rules to rules adopted by districts with higher or “worse” nonattainment classifications. Staff included cost effectiveness in the

evaluations. The summaries below discuss the comparisons and provide a deter mination whether each rule meets RACT as written or if updates are needed.

RULE 59: ELECTRIC POWER GENERATING EQUIPMENT

– OXIDES OF

NITROGEN EMISSIONS ( Last R evised 7/15/1997)

Rule 59 reduces NOx emissions from electric power generating steam boilers wi th a rated heat input capacity of greater than three hundred (300) million BTU's per hour, and any auxiliary boiler used with an electri c power generating steam boiler not subject to Rule 74.15, Boilers, Steam Generators, and Process Heaters.

Rule 59 has stricter limits than the equivalent Rule 1135 in the South Coast Air Quality Management District (SCAQMD), an “Extreme” ozone nonattainment area. Although Rule 1135 is still in effect, it could be considered obsolete. SCAQMD now uses an emission trading system, called the RECLAIM system, to regulate nitrogen oxides (NOx) from electrical power generation. The RECLAIM system is difficult to compare directly to the emission reductions gained from District Rule 59. Since SCAQMD is an

“Extreme” nonattainment area, their NOx emission limitations would likely be beyond RACT in order to achieve attainment in a timely manner. RECLAIM credits regularly trade at values greater than $4,000 per ton of NOx, which significantly exceeds the

inflation

- adjusted RACT thre shold of approximately $1,700 per ton of NOx e missions reduced. The January 2014, 12

- month rolling average price for one ton of NOx RECLAIM credits was $1

, 880 (the most recent data available).

The San Joaquin Valley Air Pollution Control District (SJVAPC D) does not have a rule specifically limiting emissions of NOx from electric power generating equipment. The SJVAPCD rule that applies to boilers in general, Rule 4306, limits NOx emissions based on heat input rather than net power output. Conducting a u nit conversion using an average efficiency for a steam boiler/turbine power system of 36% ‡ shows that the

* District rules use the terms reactive organic compounds or ROC to refer to substances the USEPA

considers VOC.

† Ventura County APCD's 2006 RACT SIP certified the District's rules met RACT and the 2009 RACT SIP

Revision certified the District's rules met EPA's CTGs issued between 2006 and 2008 and re

- certified that all major non

- CTG sources of VOC or NOx were cove red by RACT Rules.

‡ Environmental Protection Agency Combined Heat and Power Partnership Program, “Technology Characterization: Steam Turbines”, December 2008, Page 8. Accessed Feb. 18, 2014 at http://www.epa.gov/chp/documents/catalog_chptech_steam_turbines.pdf . A lower efficiency would give a less conservative conversion, indicating that the Rule 59 limit is stricter than the Rule 4306 limit.2014 RACT Analysi s Page 3

District rule limit of 0.10 lb s NOx per Megawatt

- hour output is equivalent to the

SJVAPCD rule standard limit of 0.011 lb/MMBtu heat in put for boilers greater than

20 MMBtu per hour heat input. Therefore, Rule 59 meets RACT and no changes to the rule are required at this time.

RULE 62.6: ETHYLENE OXIDE

– STERILIZATION AND AERATION (Adopted 7/16/1991)

Rule 62.6 reduces ethylene oxide emissions from s terilizers using ethylene oxide. The two known, permitted facilities that employ ethylene oxide sterilizers in Ventura County have permit limitations on usage below the RACT applicability thresholds. One source is permitted to consume 150 lbs of ethylene oxide per year and the second source is permitted to consume 88 pounds of ethylene oxide per year. Since EPA has not issued a CTG for ethylene oxide sterilizers, RACT is required for major sources only. The sources subject to Rule 62.6 do not exceed th e RACT threshold and therefore Rule 62.6 is not required to meet RACT requirements.

RULE 70: STORAGE AND TRANSFER OF GASOLINE ( Last R evised 4/1/2009)

Rule 70 reduces ROC emissions from the storage and transfer of gasoline at bulk plants, terminals, an d vehicle dispensing facilities (service stations). The storage of gasoline in containers with more than 40,000 gallons capacity is also regulated by the Rule 71.2, Storage of Reactive Organic Compound Liquids.

The California Air Resources Board (CARB) s ets vapor recovery system standards and is responsible for certifying systems to meet those standards. California’s local air districts have the primary authority for regulating gasoline dispensing facilities under vapor recovery rules. CARB implemented enhanced vapor recovery requirements during the 10 years starting in 2001. Rule 70 was last updated on March 10, 2009. The March 2009 revision added exemptions for fleets using onboard refueling vapor recovery as recommended by USEPA. CARB stated in cor respondence dated July 31, 2009 that they had reviewed the revised Rule 70 and had no comments. In addition, USEPA published a direct final rule in the Federal Register Vol. 76, No. 20, pages 5277

- 5280 dated January 31, 2011 that approved revisions to the District portion of the SIP that included the latest revisions to Rule 70. No specifications or performance standards with effective dates after 2009 have been issued. Therefore Rule 70 meets RACT and no changes are required at this time.

RULE 71.1: C RUDE OIL PRODUCTION AND SEPARATION ( Last R evised 6/16/1992)

Rule 71.1 reduces ROC emissions from equipment used in the production, gathering, storage, processing, and separation of crude oil and natural gas from any petroleum production permit unit prior to custody transfer. Commented [st1]: Bay Area Rule 8

- 33 limits emissions from bulk terminals to 0.04 lb/1000 gallons (effective 1/2011). Vs 0.08 lb/1000 gallons in Rule 702014 RACT Analysi s Page 4

The SCAQMD has no equivalent provisions similar to the tank battery requirements of Rule 71.1. However, SCAQMD Rule 1178 regulates tanks greater than 20,000

- gallon storage capacity at facilities with emissions greater than 20 tons RO C per year. The provisions of Rule 71.1 Section B, Requirements

– Storage Tanks are stricter than the requirements of Rule 1178. Rule 71.1 requires a vapor recovery system on all tanks not eligible for an exemption, where Rule 1178 allows a variety of fl oating roof configurations not vented to vapor recovery. Only tanks storing low volatility liquids and those in temporary service are exempt from the vapor recovery requirements in Rule

71.1 . The District’s 2006 RACT SIP contains additional analysis of R ule 71.1, including

demonstration that fewer than 6% of over 1

, 000 permitted tanks in the District are exempt from vapor recovery requirements.

SCAQMD Rule 1148.1 requires 95% control of produced gas that is not recovered whereas Rule 71.1 requires only 9 0% control of reactive organic compound (ROC) emissions for produced gas not recovered or flared. SJVAPCD Rule 4623 tailors tank requirements based on tank size and vapor pressure of tank constituents, but the strictest requirements allow for vapor recove ry systems similar to those allowed by Rule 71.1.

This rule is not associated with a CTG but Ventura County has seven existing major sources of ROC subject to Rule 71.1. A review of the permits for these facilities showed that produced gas is collected i nto a fuel system, sales gas system, or flare at each facility. The 90% control alternative does not apply to any existing source so the requirement has no effect , and a properly designed and operated flare will achieve 98% destruction efficiency or great er. Any new source would be subject to BACT which would require a greater ROC destruction efficiency than required by Rule 71.1. Therefore, Rule 71.1 does not require revision to meet RACT.

RULE 71.2: STORAGE OF REACTIVE ORGANIC COMPOUND LIQUIDS ( Last

R evised 9/26/1989)

Rule 71.2 reduces ROC emissions from equipment used to store crude oil or reactive organic compound liquids with a M odified Reid V apor P ressure greater than 0.5 psia.

The rule does not apply to any storage equipment subject to Rule 71. 1, to any gasoline storage container with a capacity equal to or less than 40,000 gallons, or to any other storage container with a capacity equal to or less than 5,000 gallons.

SCAQMD Rules 463 (amended 11/4/2011) and 1178 (amended 4/7/2006) and SJVAPCD Rule 4623 (amended 5/19/2005) apply to similar equipment as Rule 71.2. Rule 71.2 includes an exemption for tanks <5,000 gal, while Rule 4623 applies to all tanks >1,100 gal. Rule 463 applies to above

- ground tanks >19,815 gal and above

- gro und gasoline

tan ks with capacities of between 251 and 19,815 gal. Rule 1178 applies only to tanks at petroleum facilities with greater than 20 tons of VOC emissions reported in the year 2000 and to tanks with capacities greater than 19,815 gallons. The rules contain man y similar provisions and requirements for tanks containing volatile organic liquids. The rules all have minor differences in the detailed requirements. The provisions for fixed roof tanks are equivalent in all of the above

- mentioned rules

– a pressure

- va cuum relief valve or2014 RACT Analysi s Page 5

vapor recovery system. Most of the differences relate to floating roof tanks. In some cases, the floating roof tank requirements in Rule 71.2 are stricter than the other district

rules while the other districts’ rules have stricter r equirements in other details.

The permitted emissions of the six existing floating roof tanks in Ventura County are less than 14 tons ROC per year. Since they are already controlled to previously approved RACT levels, incremental cost effectiveness of em ission reductions will be excessive. The District’s 2006 RACT SIP contains additional analysis of Rule 71.2

, including

demonstration that additional controls on these tanks would not be cost effective. Compliance with the existing rule brings emissions f rom each of the tanks to below the

RACT de minimis threshold of 2.74 tons per year (15 pounds ROC per day). Therefore, the existing tanks should be considered de minimis and not subject to RACT in this current review. Rule 71.2 does not require revision to meet RACT.

RULE 71.3: TRANSFER OF REACTIVE ORGANIC COMPOUND LIQUIDS ( Last

Revised 6/16/1992)

Rule 71.3 reduces ROC emissions from equipment used to transfer ROC liquids with a Modified Reid Vapor Pressure (MRVP) greater than or equal to 0.5 psia. Th e provisions

of this rule do not apply to the transfer of gasoline or the transfer of ROC liquids via pipeline.

SCAQMD Rule 462 (amended 5/14/1999) and SJVAPCD Rule 4624 (amended 12/20/2007) apply to similar equipment as Rule 71.3. (Note: Since Rule 71. 3 does not apply to the transfer of gasoline, the provisions of Rule 462 that apply to gasoline storage and transfer are covered under District Rule 70.) Although the vapor destruction efficiency requirements are different, all existing sources in Ventura County use vapor recovery systems that capture and return 100% of ROC emissions. Therefore, the vapor destruction requirements of this rule are irrelevant with respect to RACT

.

The throughput and vapor pressure thresholds for vapor recovery requirements are different but designed to capture sources where controls will be cost effective. Rules 462 and 4624 require vapor recovery and/or disposal at facilities transferring between 4,000 and 20,000 gallons per day . Rule 71.3 requires vapor recovery for any source that has ever exceeded 20,000 gallons per day or 150,000 gallons per year. While there might be sources that occasionally transfer 4,000 gallons in a day that do not meet the 150,000 gallon annual threshold, it is more likely that sources with les s than 4,000 gallons of daily throughput will get captured by the 150,000

- gallon annual threshold. In addition, using an annual threshold ensures the annualized cost effectiveness is appropriate. The staff report for the 1990 revision of Rule 71.3 shows the addition of the 150,000

- gallon threshold captured 20 additional crude oil loading facilities. The cost effectiveness at this threshold was between $3,660 and $9,240 per ton of ROC emissions reduced (in 1990 dollars) , depending on if the facility used splash loading or submerged fill. Rule 71.3 exempts liquids with modified Reid vapor pressure below 0.5 psia, while Rules 462 and 4624 exempt liquids with true vapor pressure less than 1.5 psia. Therefore, Rule 71.3 meets RACT and does not require revisi on at this time.2014 RACT Analysi s Page 6

RULE 71.4: PETROLEUM SUMPS, PITS, PONDS AND WELL CELLARS ( Last

Revised 6/8/1993)

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

Rule 71.4 requires covers on allowed sumps that cover 90% of the liquid surface area. The SCAQM D and SJVAPCD rules both require covers on sumps that have very limited gaps at the edges. Otherwise they must cover the liquid completely and have no open hatches, etc. However, Rule 71.4 includes a provision that the cover must not leak, with

a leak de fined in Rule 71 as 10,000 ppm ROC as methane above background. This provision effectively restricts ROC

- containing liquid exposure to the atmosphere and limits emissions by limiting ROC concentrations in exposed air. In addition, Rule 71.4 applies to li quids with significantly lower ROC concentrations (5 mg ROC/L vs 35 mg ROC/L for Rule 4402). Rule 71.4 meets RACT and does not require revision at this

time.

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

Rule 71.5 reduces ROC emissions from glycol dehydrators anywhere natural gas is dehydrated. SJVAPCD Rule 4408 (adopted 12/19/2002) applies to the same type of equipment as Rule 71.5. The rules are essentially equivalent, but Rule 71.5 has a lower exemption threshold so it applies to all glycol de hydrators in the District. SCAQMD Rule 1148.1 (adopted 3/5/2004) has a similar 95% control requirement on systems handling produced gas, but SCAQMD does not specifically regulate glycol dehydrators. Since Rule 71.5 is equivalent to the SCAQMD and SJVAPCD rules, Rule 71.5 meets RACT and does not require revision at this time.

RULE 74.2: ARCHITECTURAL COATINGS ( Last Revised 1/12/2010)

Rule 74.2 reduces ROC emissions from architectural coatings and is a pplicable to any person who supplies, sells, offers f or sale, or manufactures any architectural coating for use within the District, as well as any person who applies or solicits the application of any architectural coating within the District. Since EPA has not issued a CTG for architectural coatings,

RACT is required for major sources only. The sources subject to Rule 74.2 do not exceed the major

- source threshold of 50 tons ROC per year and therefore Rule 74.2 is not required to meet RACT requirements.

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

Rule 74.3 reduces ROC emissions to any application process involving the coating of paper, fabric or film. SCAQMD Rule 1128 (amended 3/8/1996) and SJVAPCD Rule2014 RACT Analysi s Page 7

4607 (amended 12/18/2008) apply to the same operat ions as District Rule 74.3. Their provisions compare to Rule 74.3 with a few minor differences:

 Rule 74.3 allows a 90% overall ROC control option, while Rule 1128 allows

85.5% overall and Rule 4607 allows 90% overall

 Rule 74.3 includes a maximum equivalent emission limit of 120 g/L for high ROC content coatings vented to a control system, while Rule 1128 does not include equivalent restrictions

, and Rule 4607 has a less restrictive 265 g/L

maximum

 Rule 74.3 does not include specific ROC limits for plastisol coatings but R ules

1128 an d 4607 limit plastisol to 20 g/L, however the CTG specifically excludes the application of vinyl plastisol (see page vi of the CTG document EPA

- 450/2

- 77

- 008)

 Rule 74.3 does not restrict the application methods for subject operations but Rule

11 28 and Rule 4607 both require transfer efficiencies equivalent t o HVLP and 65%, respectively

Upon review of the District sources subject to Rule 74.3, only two sources were identified. The sources use high transfer efficiency application methods (roll a nd dip coating). New sources with significant potential emissions will be subject to the New Source Review process which will require BACT, including transfer efficiency requirements. Therefore Rule 74.3 satisfies RACT for all District sources.

RULE 74. 4: CUTBACK ASPHALT ( Last Revised 7/5/1983)

Rule 74.4 reduces ROC emissions from application of rapid cure cutback asphalt for highway or street paving or maintenance, and applies to any person who manufacture s
, sell s , or offer s for sale cutback asphalt f or such use or application. Rule 74.4 is equivalent to the cutback asphalt restrictions in other air districts in California. All reviewed rules prohibit the use of cutback asphalts with greater than 0.5% organic compounds with boiling points less than 5 00 °F. Some rules, including Rule 74.4, have exemptions for material used at temperatures less than 50 °F. This rule continues to satisfy RACT and does not require an update at this time.

RULE 74.5.1: PETROLEUM SOLVENT DRY CLEANING ( Last Revised 12/4/1 990)

Rule 74.5.1 reduces ROC emissions from petroleum solvent dry cleaning operations through emission control, filtration equipment, and operating requirements.

SCAQMD Rule 1102 (amended 11/17/2000) and SJVAPCD Rule 4672 (amended 12/17/1992) apply to sim ilar equipment as District Rule 74.5.1. Rule 4672 has similar emission limits and operational requirements with the addition of a leak inspection and leak repair cycle information label requirement. Rule 1102 includes detailed leak check and repair requi rements with time limits for repairing leaks. The Ventura County rule prohibits operating leaking equipment but does not include specific leak check and repair requirements or allowances for operating leaking equipment.2014 RACT Analysi s Page 8

Rule 1102 prohibit s operati on of transfer machines effective January 1, 2005. District Rule 74.5.1 does not prohibit transfer machines and a review of District permits indicated one transfer machine remains operating in Ventura County. This machine is located in a small retail shop and has permitted potential emissions of less than 1.7 tons ROC per

year. However, CTG (EPA

- 450/3

- 82

- 009 1982/09) only applies to large industrial

facilities.

Any new petroleum solvent dry cleaning operations with significant potential emissions

will be su bject to the New Source Review process

, which will require BACT and a prohibition on transfer mac hines. Therefore Rule 74.5.1 meets RACT and does not require an update at this time.

RULE 74.5.2: SYNTHETIC SOLVENT DRY CLEANING ( Last Revised 5/9/1995)

R ule 74.5.2 reduces ROC emissions from synthetic solvent dry cleaning equipment that

do es not use percholorethylene through emission control, filtration equipment, and operating requirements.

SCAQMD Rule 1102 (amended 11/17/2000) applies to any dry cleanin g equipment not using perchloroethylene solvent. SJVAPCD Rule 4672 applies only to petroleum solvent dry cleaning equipment so is not applicable to the same sources. Rule 1102 includes detailed leak check and repair requirements with time limits for repa iring leaks. Rule

74.5.2 prohibits operating leaking equipment but does not include specific leak check and repair requirements or allowances for operating leaking equipment. Rule 1102 prohibits operation of transfer machines effective January 1, 2005. District Rule 74.5.2 prohibits installation of transfer machines effective December 4, 1990. A review of District permits indicated no transfer machines using synthetic solvent remain operating in Ventura

C ounty. Therefore Rule 74.5.2 meets RACT and does not require an update at this time.

Ru le 74.6: SURFACE CLEANING AND DEGREASING ( Last Revised 11/11/2003)

Rule 74.6 reduces ROC emissions from surface cleaning conducted outside of a degreasing tank s (e.g., hand wipe cleaning, cleaning with handheld spra y bottles ) or using cold cleaning apparatus

.

SCAQMD Rules 1122 and 1171 (both amended 5/1/20 0 9) and SJVAPCD Rules 4662 and 4663 (both amended 9/20/2007) regulate similar operations

. Rules 1171, 4662

, and 4663 include significantly lower limits on ROC co ntent of solvents used for cleaning without venting the operation to a control device. All of the rules have similar requirements for control device efficiency when using non

- compliant solvent s, except
Rules 4662 a n d 4663 , which require controlled emissio ns to be less than emissions from the operation if compliant solvents were used. These rules are all complex with details that vary only slightly between them but no other significant differences exist.

The District’s 2009 RACT SIP submittal includes a detailed evaluation of Rule 74.6. According to the 2009 evaluation, all of the industrial solvent cleaning operations in Commented [st2]: Consider adding ...(those consuming > 123,000 liters/yr or > ~106 tons/yr)

Commented [st3]: Consider adding: Rule 7 4.6 limits general solvent cleaning operations to 25 g/l; consider re

- evaluating the 33mmHg and 900 g/l limit compared to SC 1171 which reduced its 900 g/l limit for electrical devices down to 100 g/l effective 7/2005, while keeping the 800 g/l limit for m edical devices2014 RACT Analysi s Page 9

Ventura County meet CTG control recommendations, or fall within the exclusions outlined in the guidelines. In addition, the 2009 eva luation concludes VCAPCD rules governing industrial solvent cleaning operations meet RACT requirements as recommended by the September 2006 CTG for industrial cleaning solvents. Therefore Rule 74.6 meets RACT and does not require an update at this time.

RULE 74.6.1 : BATCH LOADED VAPOR DEGREASERS ( Last Revised 11/11/2003)

Rule 74.6.1 reduces ROC emissions from batch loaded vapor degreasers by specifying equipment and operating practice requirements

. SCAQMD Rule 1122 (amended 5/1/2009) and SJVAPCD Rule 4 662 (amended 9/20/2007) regulate similar sources to those regulated by Rule 74.6.1. It should be noted that Rule 74.6.1 does not regulate conveyorized vapor degreasers but no equipment of that type is currently permitted in Ventura County. The rules are all essentially equivalent

, although each has minor details in the requirements that the others do not. Therefore Rule 74.6.1 meets RACT and does not require an update at this time.

RULE 74.7: FUGITIVE EMISSIONS OF REACTIVE ORGANIC COMPOUNDS (ROC) AT PE TROLEUM REFINERIES AND CHEMICAL PLANTS ( Last Revised 10/10/1995)

Rule 74.7 reduces ROC emissions through operational and inspection requirement s at petroleum refineries and chemical plants. Historically, only one petroleum refinery and only a few chemi ca l plants have operated in Ventura County . The petroleum r efinery has not operated since 1984 . Only one facility (Facility #07519) with an SIC code meeting the chemical plant definition remains in the county . Facility #07519 is permitted to emit

2.5 tons of ROC per year from all facility sources, including but not limited to components subject to Rule 74.7. Therefore, Rule 74.7 does not apply to any sources

above the RACT threshold of 2.7 tons ROC per year and Rule 74.7 is not required to

meet RACT.

RU LE 74.8: REFINERY VACUUM PRODUCING SYSTEMS, WASTEWATER

S EPARATORS AND PROCESS TURNAROUNDS ( Last Revised 7/5/1983)

Rule 74.8 reduces ROC emissions from refinery vacuum producing systems, wastewater separators, and process turnarounds at petroleum refineri es. Historically, only a single petroleum refinery operated in the county . The petroleum refinery has not operated since

1984 . Rule 74.8 applies only to petroleum refineries. Therefore, Rule 74.7 does not apply to any existing sources in the county and therefore is not required to meet RACT.

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

Rule 74.9 reduces NOx emissions stationary spark

- ignited or diesel internal combustion engine s rated at 50 or more horsepower, operated o n any gaseous fuel, including liquid petroleum gas (LPG), or liquid fuel, and not subject to the provisions of Rule 74.16. Commented [st4]: The synthetic organic chemical, polymer, and resin manufacturing model rule for the CTG applies to all equipment, but the model rule is not applicable to facilities whose design capacity is <1100 tons of product. Maybe a candidate for a

neg ative declaration?2014 RACT Analysi s Page 10

SCAQMD Rule 1110.2 (amended 9/7/2012) and SJVAPCD Rule 4702 (amended 11/14/2013) regulate sources similar to those regulated by Rule 74.9. The emission limits in Rule 1110.2 are significantly stricter than those in Rule 74.9. The baseline NOx

and ROC emission limits in Rule 4702 are largely equivalent to Rule 74.9, though stricter emission limits are becoming effective on a schedule that allows some facilities to defer

full compliance until 2017. In addition, Rule 4702 includes a fee option for facilities unwilling to comply with the stricter limits. The fees are capped at the Carl Moyer cost

effectiveness threshold which is current ly a weighted cost of $17,380 . Of this amount, approximately 45% is assigned to NOx emissions, meaning the Carl Moyer cost effectiveness for NOx is approximately $7,820.

Rule 74.9 exempts agricultural (AG) engines and engines used in oilfield drilling

o perations. Oilfield drilling engines are not exempt from the rule requirements of Rules

1110.2 and 4702 . Oilfield drilling engines are subject to District Rule 74.16 Oilfield Drilling Operations, which requires electrification where economically feasibl e (see discussion under Rule 74.16) . A G engines are exempt from Rule 1110.2 only if they are not qualified for electrification and they have been replaced with Tier IV engines. Rule 4702 includes separate emission limits for spark

- ignited AG engines and regulates compression

- ignition AG engines the same as other compression

- ignition engines. Although AG engines are exempt from Rule 74.9, they are covered by the Air Resources Board Air Toxic Control Measure ( ATCM ) for diesel particulate s . The ATCM requi rements have eliminated Tier 0 AG engines from use in the District and will eliminate Tier 1 AG engines by the end of 2014 and Tier 2 AG engines by the end of

2015.

Equipment exempt from Rule 74.9 is covered by other District or Air Resources Board

rules that are RACT equivalent as noted above for oilfield and AG engines . The NOx

and ROC limits for units subject to Rule 74.9 are equivalent to Rule 4702 baseline limits and the fee option value exceeds the RACT NOx threshold of approximately $1

, 7 00.

Theref ore, Rule 74.9 meets RACT and does not require an update at this time.

RULE 74.10: COMPONENTS AT CRUDE OIL AND NATURAL GAS

PRODUCTION AND PROCESSING FACILITIES ( Last Revised 3/10/1998)

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

SJVAPCD Rule 4409 (amended 4/20/2005) regulate s sources similar to those regulated by Rule 74.10. Rule 4409 is essentially the same as Rule 74.10, with similar thresholds for leak classification and similar time requirements for repairs (74.10 is stricter in some categories and 4409 includes an “Extended Repair Period” which makes those catego ries the same as 74.10). SCAQMD Rule 1173 also regulates similar sources; however

, the

lion’s share of the emission reductions are from the leak reduction requirements in Commented [st5]: There is no blanket exemption for Ag engines.

Commented [st6]: Suggest removing discussion about ATCMs. It is mainly for diesel particulates/toxics (vs NOx); the ATCM regulates compression ignition engines (not spark ignited) and the

ATCM is not submit ted for SIP approval

– and therefore could change without EPA approval. Ag engines that are spark ignited would are not covered by the ATCM.

If you remove the ATCM discussion here, you may need to modify

the discussion in Rule 74.16 below which refers to this paragraph.2014 RACT Analysi s Page 11

SCAQMD Rule 1173 and are focused on refinery leaks. Since there are no refineries i n the District

, this rule is not directly comparable to Rule 74.10.

Rule 74.10 employs a two

- pronged approach to leak emission reductions. First, sources are required to employ a Leak, Detection and Repair (LDAR) Program to find and fix leaking component s. Second, the rule allows District inspectors to issue Notices of

Violations when leaks exceeding certain thresholds are detected by PID detectors. The ability of District inspectors to issue NOVs for leaks found dramatically increases rule compliance a nd provides an incentive for sources to undertake a diligent LDAR progra m to avoid potential violations. Rule 74.10 therefore meets RACT and does not require an update at this time.

RULE 74.11: NATURAL GAS

- FIRED WATER HEATERS ( Last Revised 1/12/2010)

R ule 74.11 reduces NOx emissions from residential water heaters and applies to
residential water heaters and distributers and installers. The rule’s provisions are essentially the same as SCAQMD Rule 1146.2 (amended 5/6/2006) and SJVAPCD Rule 4902 (amended 3/19/2009). Therefore Rule 74.11 meets RACT and does not require an update at this time.

RULE 74.11.1: LARGE WATER HEATERS AND SMALL BOILERS ( Last Revised 9/11/2012)

Rule 74.11.1 is a point

- of

- sale rule that reduces NOx emissions from large water hea ters and small boilers that are sold, offered for sale, or installed in Ventura County through certain requirements and limits.

SCAQMD Rule 1146.2 (amended 5/5/2006) and SJVAPCD Rule 4308 (amended 11/14/2013) apply to similar sources as Rule 74.11.1. The provisions of Rule 4308 are essentially the same as rule 74.11.1. All three rules have equivalent emission limits as ppm NOx in source exhaust, although the rules vary in expression of limits based on heat input or heat output. Rule 1146.2 includes addi tional requirements that require existing sources more than 15 years old be retrofitted or replaced if they do not meet emission

limits that were effective January 1, 2000. Moreover, s ince the SCAQMD is classified an

extreme nonattainment area , they must go beyond RACT requirements to meet ozone

standards. The SJVAPCD rule was amended in late 2013 and does not include provisions applicable to existin g units. Since Rule 74.11.1 is equivalent to Rule 4308, Rule 74.11.1 meets RACT and does not require an up date at this time.

RULE 74.12: SURFACE COATING OF METAL PARTS AND PRODUCTS ( Last

Revised 4/8/2008)

Rule 74.12 reduces ROC emissions by specifying ROC content limits in coatings used coat metal parts and products and work practice requirements

. SCAQMD Rule 1107 (amended 1/6/2006) and SJVAPCD Rule 4603 (amended 9/17/2009) apply to similar sources to Rule 74.12. The coating ROC content restrictions are mostly equivalent, with Commented [st7]: Unless you have a major source water heater, the source category is not required to meet RACT.

Commented [st8]: "to"2014 RACT Analysi s Page 12

Rule 74.12 including lower limits on a few specialty coatings. While minor dif ferences in work practice requirements and exemptions exist, the differences do not impact the RACT determination. Rule 74.12 has equivalent or stricter requirements than Rule 1107 and Rule 4603, so Rule 74.12 meets RACT and does not require an update at this time.

RULE 74.13: AEROSPACE ASSEMBLY AND COMPONENT MANUFACTURING OPERATIONS ( Last Revised 9/11/ 20 12)

Rule 74.13 reduces ROC emissions from the manufacturing, assembling, coating, masking, bonding, paint stripping, and surface cleaning of aerospace components and the

clean

- up of equipment associated with these operations.

SCAQMD Rule 1124 (amended 9/21/2001) and SJVAPCD Rule 4605 (amended

6/16/2011 ) apply to sources similar to those subject to Rule 74.13. Rule 74.13 limits the

emissions of ROC fro m the application of coatings or adhesives on aerospace components. This rule contains limits on the ROC content of coatings, adhesives and cleaners used at aerospace component manufacturing operations. The ROC control requirements of this rule are equiv alent to SC AQMD Rule 1124, Aerospace Assembly and Component Manufacturing Operation, with a few variations in limits for specialty coatings or adhesives. In addition, Rule 74.13 requirements exceed th ose of the

USEPA’s Air Toxic Rule 40 CFR Part 63 Subpar t GG

- National Emission Standards for Aerospace Manufacturing and Rework Facilities

, dated December 8 , 2000.

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

content limits in the CTG. District staff determined the C TG includes limits on sixteen (16) additional specialty coatings not addressed in Rule 74.13. However, the CTG for aerospace manufacturing and rework operations applies to sources in serious nonattainment areas that have the potential to emit greater than or equal to 25 tons per year of ROC. There are no aerospace manufacturing or rework facilities in the District with permitted ROC emissions greater than 25 tons per year ROC. Rule 74.13 applies to sources that emit greater than 200 pounds ROC in any co nsecutive twelve

- month period. Therefore, Rule 74.13 exceed s RACT requirements and no changes are required at this

time.

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

Rule 74.14 reduces ROC emissions from operations that manu facture products from or otherwise use polyester resin material. ROC emissions from this manufacturing process are controlled by limiting loss rate, monomer R OC content, application technique, or by requiring emission control equipment. Limits are also p laced on the ROC content of cleaning materials. This rule does not apply to sources in a CTG category and there are no major sources of NOx or ROC in the district subject to this rule. Therefore, RACT analysis and RACT compliance are not required

. Commented [st9]: Consider adding that more details on how

74.12 meets the 2008 CTG is contained in Ventura's 2009 RACT

SIP Revision.

Commented [st10]: Okay...if you had a ny facilities >25 tpy, the CTG would apply.2014 RACT Analysi s Page 13

RULE 74.15: BOILERS, STEAM GENERATORS AND PROCESS HEATERS ( Last

Revised 11/18/1994)

This rule reduces NOx emissions from boilers, steam generators and process heaters used in all industrial, institutional and commercial operations, except utility electric pow er generating units and any auxiliary boiler used with a utility electric power generating unit

and water heaters.

SCAQMD Rule 1146 (amended 9/5/2008) and SJVAPCD Rule 4320 (amended 10/16/2008) apply to sources similar to those subject to Rule 74.15. Rul e 74.15 prohib its

NOx and CO emissions in excess of 40 ppm and 400 ppm, respectively, from all subject

sources except those meeting a low use exemption . Both Rule 1146 and Rule 4320 include tables of NOx limits for different categories of combustion sourc es. The NOx emission limits range from 5 ppm for larger units to 25 ppm NOx for units fired on landfill gas. The limits are all expressed in ppm NOx on a dry basis and corrected to 3% oxygen, so they are directly comparable.

According to the SCAQMD boar d materials associated with the adoption of Rule 1146 in 2008, c ost effectiveness estimates range from $10,100 to $24,900 per ton for units complying with the 9 ppm NOx limit (ultralow

- NOx burner) and $13,000 to $30,800 per ton for units complying with the 5 ppm NOx limit (SCR). For atmospheric boilers, the cost effectiveness of complying with the 12 ppm NOx limit is estimated to range from $17,300 to $32,800. These cost effectiveness values are far beyond the cost effectiveness guidelines for RACT of app roximately $1

, 7 00 per ton of NOx reduced in inflation

adjusted 2012 dollars. This indicates the current cost effectiveness of these technologies exceeds RACT guidelines. Since the baseline emission limits and compliance options are

similar for all three rules, Rule 74.15 meets RACT and does not require update at this

time.

RULE 74.15.1: BOILERS, STEAM GENERATORS AND PROCESS HEATERS ( Last

R evised 9 /11/12 )

This rule is a point

- of

- sale rule that reduces NOx emissions by requiring large water

heaters and s mall boilers that are sold, offered for sale, or installed in Ventura County to meet certain requirements.2014 RACT Analysi s Page 14

SCAQMD Rule 1146 .1 (amended 9/5/2008) a nd SJVAPCD Rule 4320 (amended

5/19/2011 ) apply to sources similar to those subject to Rule 74.15 .1 , combustio n sources with maximum design heat input less than 5 MMBtu/ hr . Rule 74.15 .1 prohib its NOx and

CO in excess of 40 ppm and 400 ppm, respectively, from subject sources with annual heat input greater than 1.8 x 10 9 Btu

. Both Rule 1146.1 and Rule 4320 include similar limits as baseline limits for all subject units not eligible for a low use exemption. All three rules include a compliance option for units with total annual fuel use less than 1.8 x

10 9 Btu. Such units may comply with the rule by performing reg ular tune ups (twice per year, with different specific scheduling requirements) in accordance with rule requirements.

Rule 1146.1 includes much stricter NOx limits on all subject sources, however the SCAQMD staff report associated with the adoption of tho se limits indicate the cost effectiveness ranges from $14,400 to $33,500 per ton of NOx emissions reduced. These cost effectiveness values are far beyond the cost effectiveness guidelines for RACT of approximately $1

, 7 00 per ton of NOx reduced in inflatio n

- adjusted 2012 dollars. Rule

4320 includes similar limits for new units only; however they are not effective for many types of sources (schools, refineries, and moderate use units) until January 1, 2016. Since the baseline emission limits and compliance options are similar for all three rules, Rule 74.15.1 meets RACT and does not require update at this time.

RULE 74.16 : OILFIELD DRILLING OPERATIONS (Adopted 1/8/1991)

Rule 74.16 reduces NOx emissions by requiring oilfield drilling rigs to be powered by electric utility grid power. The rule requires the District to grant an exemption from this requirement in cases where the cost of bringing grid power to the drilling site makes electric drilling economically infeasible. In cases where the District gran ts such an exemption, Rule 74.16 requires the diesel engines used in oilfield drilling rigs to meet NOx limits equivalent to Tier 1 diesel engines. In addition, the diesel ATCM (see discussion under Rule 74.9) has stricter requirements that apply to drill ing rig engines and will eliminate Tier 1 and Tier 2 engines from use by the end of 2015.

N o oil well drilling rigs currently hold a District Permit to Operate. T o obtain a Permit to Operate, oil well drilling engines would have to comply with more strin gent BACT requirements pursuant to Rule 26, New Source Review. By definition, BACT for internal combustion engines is least as stringent as RACT.

California law adopted after adoption of Rule 74.16 preempts air districts from regulating the portable dies el engines used in oilfield drilling rigs if they are registered under the statewide Portable Equipment Registration Program (PERP). As a result, all oil well drilling rigs operating in Ventura County have opted to comply with the PERP regulation

instead of obtaining a District air permit

. Therefore, for all practical purpose s
, the requirements of Rule 74.16 do not apply and the rule is not necessary to implement RACT at oilfield drilling operations.2014 RACT Analysi s Page 15

RULE 74.1 7.1 : MUNICIPAL SOLID WASTE LANDFILLS ( Last R evised 2/9/1999)

Rule 74.17.1 reduces fugitive ROC emissions from municipal solid waste landfill s by means of landfill gas collection and control systems. All municipal solid waste landfills in Ventura County are subject to either the federal New Source Performance Standard (40 CFR part 60 subpart WWW) or Rule 74.17.1, as applicable. SCAQMD Rule 1150.1 (amended 4/1/2011) and SJVAPCD Rule 4642 (amended 4/16/1998) do not contain more stringent requirements. Therefore, Rule 74.17.1 meet s RACT and no chang es are required at this time.

RULE 74.18: MOTOR VEHICLE AND MOBILE EQUIPMENT COATING

OPERATIONS ( Last Revised 11/11/2008)

Rule 74.18 limits ROC emissions from the application of automotive refinish coatings.

This rule contains limits on the ROC content of refinish coatings used to coat both repaired auto bodies and entire vehicles, and contains ROC content limits on cleaners used for surface preparation and application equipment cleanup.

The California Air Resources Board amended the statewide Suggest ed Control Measure (SCM) for Automotive Coatings on October 20, 2005. On November 11, 2008, the

District adopted the SCM. The lion’s share of the emission reduct ions from this SCM

result from auto body shops switching from solvent

- based color base coats to new
waterborne color basecoats. O ther provisions of the SCM includ e new ROC limits of primer sealers, specialty coatings, and cleaning solvents used for cleaning application equipment . Therefore, Rule 74.18 meet s RACT and no changes are required at th is time.

RULE 74.19: GRAPHIC ARTS ( Last Revised 6/14/2011)

Rule 74.19 reduces ROC emissions from the use of inks, fountain solutions, coatings, adhesives, and cleaners used at graphic arts operations through limits on the ROC content of inks, coating, a dhesives

, fountain solutions, and solvent cleaners. On June 14, 2011

, the District adopted new ROC limits in Rule 74.19 equivalent to SCAQMD Rule 11 30, Graphic Arts (amended 10/8/1999) , and S CAQMD Rule 1171, Solvent Cleaning (amended 5/1/2009) . These ne w requirements meet RACT and no further changes are required.

RULE 74.19.1: SCREEN PRINTING OPERATIONS ( Last Revised 11/11/2003)

Rule 74.19.1 reduces ROC emissions from the use of inks, coatings, adhesives, and cleaners used at screen printing operation s. The rule specifies limits on the ROC content of inks, coating, ad hesives and fountain solutions, whereas ROC emissions from cleaning solvents are limited by ROC content and ROC composite vapor pressure requirements

. There is no CTG for this source cat egory and there are no major sources in Ventura County. Therefore, RACT analysis and RACT compliance for this rule are unnecessary.

RULE 74.20 : ADHESIVES AND SEALANTS ( Last Revised 9/11/2012) Commented [st11]: Consider referencing Ventura's 2009

RACT SIP for more details on how Rule 74.19 meets the 2006 CTG for offset Litho and Letterpress printing.

Note

- SC 1130 d oes not meet the 2006 CTG, it is being amended to

m eet the CTG.2014 RACT Analysi s Page 16

Rule 74.20 reduces ROC emissions from the use of adhesives, sealants, adhesive primers, sealant primers and cleaning solvents used at bonding operations. Rule requirement s limit ROC emissions by limiting the ROC content of adhesives, s ealants, primers, and

cleaners.

The ROC control requirements of this rule are e quivalent to SCAQMD Rule 1168 (amended 1/7/2005) and SJVAPCD Rule 4653 (Amended 9/16/2010 ) with some minor

differences. For example, the SCAQMD and SJVAPCD rules list a number of different

or additional categories of adhesives, sealants and primers with l i mits in the range of 500

to 850 g/L. Those materials would be subj ect to the general limit of 250 g/L in Rule

74.20. The SCAQMD and SJVAPCD rules include stricter limits on a few material categories

, however the differences are minor, such as ABS weldin g limits of 400 g/L in

Rule 74.20 vs 325 g/L in the other rules or Plastic Welding Primer limits of 650 g/L in

Rule 74.20 vs 550 g/L in Rule 1168. Rule 74.20 allows the use of non

- compliant

materials if the source uses add

- on controls with overall removal efficiency of 85%, which is equivalent or stricter than the control requirement for Rule 1168 (80% overall control) and Rule 4653 (85% overall control).

There are no major sources in Ventura County and Rule 74.20 meets the requirements of

the Industrial Adhesives CTG as demonstrated in the 2006 RACT SIP approved by

USEPA

. Therefore, Rule 74.20 meets RACT and no changes are required at this time.

RULE 74.21: SEMICONDUCTOR MANUFACTURING (Adopted 4/6/1993)

Rule 74.21 reduces ROC emissions from semicondu ctor manufacturing operations through various operational requirements and solvent concentration limits. This rule does not apply to sources in a CTG category and there are no major sources of ROC in Ventura County subject to this rule. Therefore, RACT a nalysis and RACT compliance

for this rule are unnecessary.

RULE 74.22: NATURAL GAS

- FIRED, FAN TYPE CENTRAL FURNACES (Adopted 11/9/1993)

Rule 74.22 reduces ROC emissions by prohibiting the sale and installation of forced air space heaters that do not mee t specified NOx limits. There is no CTG for this equipment and there are no major sources in Ventura County. Therefore, RACT analysis and RACT compliance for this rule are unnecessary.

RULE 74.23 : STATIONARY GAS TURBINES ( Last Revised 1/8/2002)

Rule 7 4.23 reduces NOx emissions from stationary turbines with rated output greater than 0.3 MW fueled with gaseous or liquid fuels. Th is applicability limit is the same as SCAQMD Rule 1134 (amended 8/8/1997) and SJVAPCD Rule 4703 (amended 9/20/2007). There ar e 18 existing turbines in the District subject to Rule 74.23. Half of the existing turbines are exempt based on a limit of less than 200 annual hours of Commented [st12]: The industrial Adhesive CTG was issued in

2008 , so please modify this language

. On 3/10/14 EPAproposed to approve Ventura's 2009 RACT SIP.

Consider referencing Ventura's 2009 RACT SIP which states there are no facilities subject to the 2008 Misc Industrial CTG because they are below the CTG threshold.2014 RACT Analysi s Page 17

operation. Eight (8) of the remaining turbines are limited by air permit conditions to

BACT emission levels. The final remaining unit has a specific permit limit due to its configuration and inability to cost

- effectively install add

- on controls such as selective catalytic reduction. This unit is required to use water injection, and the facility agreed t o over control the other, larger turbine on site to achieve additional NOx reductions beyond RACT on average. Since all other existing units subject to Rule 74.23 are controlled at BACT levels and any new sources would be required to install BACT emission controls,

Rule 74.23 meets RACT and no update is required at this time

.

RULE 74.24: MARINE COATING OPERATIONS ( Last Revised 9/11/2012)

Rule 74.24 reduces ROC emissions from coating and cleaning solvents used to coat

marine or fresh water vessels

, exclu ding boatyard repair facilities and marinas. Rule requirements limit ROC emissions by limiting the ROC content of topcoats and primers.

Emissions of ROC from cleaner s are also controlled by limiting the ROC c ontent of surface prep cleaners and applicatio n equipment cleaners.

The ROC control requirements of this rule are equivalent to South Coast AQMD Rule

1106 (amended 1/13/1995) with some minor differences. Rule 74.24 also meets the requirements for the 1996 CTG for Ship Building and Ship Repair Opera tions. This rule therefore meets RACT and no update is needed at this time.

RULE 74.24.1: PLEASURE CRAFT COATING AND COMMERCIAL BOATYARD

OPERATIONS ( Last Revised 1/8/2012)

Rule 74.24.1 reduces ROC emissions from the use of coating s and cleaning solven ts used to coat marine or fresh water vessels at commercial boatyard repair facilities and marinas. This rule also contains a sales prohibition for noncomplying coatings sold at marine stores that sell pleasure craft coatings. Rule requirement s limit ROC emissions through

ROC content limits on topcoats and primers. Emissions of ROC from cleaners are also controlled by l imits on the ROC content of surface prep cleaners, the ROC composite vapor pressure of cleaning solvents

, and requiring the use of enclos ed spray gun washers.

Also

, this rule requires use of high transfer efficiency spray equipment such as High Pressure, Low Volume (HPLV) spray equipment.

The ROC control requirements of this rule are equivalent to South Coast AQMD Rule

1106.1 (amended 2/1 2/1999) with some minor differences. There is no CTG for this source category and there are no major sources in Ventura County

. Therefore, RACT analysis and RACT compliance for this rule are unnecessary.

RULE 74.25: RESTAURANT COOKING OPERATIONS (Adop ted 10/12/2004)

Rule 74.25 reduces NOx and particulate matter emissions from conveyorized charbroilers. There is no CTG for this equipment and there are no major sources in Ventura County. Therefore, RACT analysis and RACT compliance for this rule are

unnecessary. Commented [st13]: Pleasure craft coatings are covered in the 2008 Misc Metal and Plastic Parts Coatings CTG Table 5

- Pleasure craft coatings.

Commented [st14]: T his should say ROC instead of NOx

.2014 RACT Analysi s Page 18

RULE 74.26 : CRUDE OIL STORAGE TANK DEGASSING OPERATIONS (Adopted 11/8 1994)

Rule 74.26 reduces ROC emissions by prohibiting the venting of ROC vapors to the atmosphere from above

- ground tanks used to store crude oil or produced water. When such tanks are undergoing maintenance or being decommissioned, the rule requires ROC vapors to be treated rather than released to the air.

Rule 74.26 was evaluated by the District in 2004 in an “All Feasible Measures” (AFM) analysis conducted pursuant to California Health and Safety Code Section 40914. This review was cited in the District’s 2006 RACT SIP as approved by USEPA. The conclusions of the 2004 AFM analysis remain valid. SCAQMD Rule 1149 (amended 5/2/2008) has a lower threshold of ROC for deg assed tank s , 5, 000 ppmv versus 10,000 ppmv for Rule 74.26. Howe ver, the 2004 AFM analysis st ates the incremental cost to control emissions from 10,000 ppmv to 5,000 ppmv would be excessive due to the large

amount of time and dilution air needed to reduce the concentration a further 50%. SCAQMD was able to justify the lower limit due to the much more lax conditions of Rule 1149 prior to its amendment and a cost effectiveness threshold of $13,159 per ton of

ROC reduced

, much higher than what would be consid ered for RACT in Ventura County.

SCAQMD also lowered the tank size applicability thresholds for Rule 1149 in its 2008

revision. The District’s 2004 AFM analysis also addressed the tank size applicability

threshold cost effectiveness for Rule 74.26. Assu ming a ROC vapor density of 0.004

lb /gallon of tank volume and a control efficiency of 95%, the cost effectivenes s to control degassing of a 500

- bbl tank ranges from $18

- $25 per pound of ROC reduced (equivalent to $36,000

- $50,000 per to n). Smaller tanks , such as the 500

- gallon level regulated by Rule 1149, will have worse cost effectiveness due to the fixed costs of tank degassing operations increasing relative to tank size

. Due to the high cost of reducing the tank size

and/or ROC concentration thresho lds, Rule 74.26 meets RACT and no update is

necessary at this time

.

RULE 74.27 : GASOLINE AND ROC LIQUID STORAGE TANK DEGASSING OPERATIONS (Adopted 11/8 1994)

Rule 74.27 reduces ROC emissions by prohibiting the venting of ROC vapors to the atmosphere fro m a ny gasoline storage tank that has a storage capacity greater than 5,000 gallons and any storage tank that has a storage capacity greater than 5,000 gallons that stores a reactive organic compound (ROC) liquid, excluding petroleum liquids, having a

true vapor pressure equal to or greater than that determined by: TVP @ 68 ° F (psia) = 2.3 + 23,000/V, where V is the volume of the tank in gallons. When such tanks are undergoing maintenance or being decommissioned, the rule requires ROC vapors to be

treated rather than released to the air.

Rule 74.27 was evaluated by the District in 2004 in an “All Feasible Measures” (AFM) analysis conducted pursuant to California Health and Safety Code Section 40914. This2014 RACT Analysi s Page 19

review was cited in the District’s 2006 RACT SIP as approved by USEPA. The conclusions of the 2004 AFM analysis remain valid. SCAQMD Rule 1149 (amended 5/2/2008) has a lower ROC threshold, 5, 000 ppmv versus 10,000 ppmv for Rule 74.27

. However, the 2004 AFM analysis states the incremental cost t o control emissions from 10,000 ppmv down to 5,000 ppmv would be excessive due to the large amount of time and dilution air needed to reduce the concentration a further 50%. SCAQMD was able to justify the lower limit due to the much more lax conditions of Rule 114 9 prior to its amendment and a cost effectiveness threshold ($13,159 per ton of ROC reduced) much higher than what would be considered RACT in Ventura County.

SCAQMD also lowered the tank size applicability thresholds for Rule 1149 in its 2008

revision. The 2004 AFM analysis also addres sed the tank size applicability threshold

c ost effectiveness for Rule 74.27

. Based on cost estimates of $400 (fixed cost) plus $0.04 per gallon of tank size for degassing, the cost effectiveness of degassing a 5 ,000 gall on tank is approximately $9 per pound of ROC reduced. This is equivalent to the District’s BACT cost effectiveness threshold and is by definition more stringent than RACT. Since the cost per pound of ROC removed will increase as tank size gets smaller , t he current tank size threshold in Rule 74.27 is beyond RACT requirements. Due to the high cost of reducing the tank size and/or ROC concentration thresholds , Rule 74.27 meets RACT and no update is necessary at this time

.

RULE 74.28: ASPHALT ROOFING OPER ATIONS (Adopted 5/10/1994)

Rule 74.28 reduces ROC emissions from asphalt roofing equipment and operations by requiring close fitting container lids and temperature limits. Rule 74.28 applies to equipment used for melting, heating or holding asphalt or co al tar pitch. There is no CTG for this equipment and there are no major sources in Ventura County. Therefore, RACT analysis and RACT compliance for this rule are unnecessary.

RULE 74.29: SOIL DECONTAMINATION OPERATIONS ( Last Revised 4/8/2008)

This rul e established procedures by which ROC emissions are minimized during the aeration, treatment or removal of soil contaminated with petroleum fuel

. Rule 74.29 applies to soil decontamination equipment and handling of contaminated soil. There is

no CTG for this equipment or operations and there are no major sources in Ventura County . Therefore, RACT analysis and RACT compliance for this rule are unnecessary.

RULE 74.30 : WOOD PRODUCTS COATINGS ( Last Revised 6/27/2006)

Rule 74.30 reduces ROC emissions from wood products coatings and cleaning materials by ROC content limits and by requiring certain application methods. Rule 74.30, SCAQMD Rule 1136 (amended 6/4/1996)

, and SJVAPCD Rule 4606 (amended 10/16/2008) are equivalent in stringency. Therefore, Rule 7 4.30 meets RACT and no changes are required at this time.2014 RACT Analysi s Page 20

RULE 74.31: METALWORKING FLUIDS AND DIRECT CONTACT LUBRICANTS (Adopted 11/12/2013)

Rule 74.31 applies to the production, sale and use of metalworking fluids and direct

contact lubricants and redu ces ROC emissions by requiring substitution of high

- ROC metalworking fluids with low

- ROC fluids, including medium napthenic oils, paraffinic oils, vegetable oils, synthetic or semi

- synthetic oils, or water

- reducible fluids. There is no CTG for this equipm ent or operations and there are no major sources in Ventura County . Therefore, RACT analysis and RACT compliance are unnecessary at this time

.