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 control 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 capable 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 emission 

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 

achievable 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 groundlevel ozone. Among those are requirements that State Implementation Plans (SIPs) for ozone 

nonattainment areas provide for RACT. According to the ozone rule, areas classified as 

moderate or higher ozone nonattainment areas must submit revisions to their SIPs 

demonstrating that their current rules fulfill 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 first 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” documenting that the area has no stationary sources in a CTG 

source category.

CTGs 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 threshold 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 

greater than 50 tons per year of volatile organic compounds (VOC) and/or nitrogen 

oxides (NOx).
2014 RACT Analysis Page 2

RACT EVALUATIONS

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

categories and/or major sources of ozone precursors in Ventura 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 

updated 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 determination 

whether each rule meets RACT as written or if updates are needed.

RULE 59: ELECTRIC POWER GENERATING EQUIPMENT – OXIDES OF 

NITROGEN EMISSIONS (Last Revised 7/15/1997)

Rule 59 reduces NOx emissions from electric power generating steam boilers with a rated 

heat input capacity of greater than three hundred (300) million BTU's per hour, and any 

auxiliary boiler used with an electric 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 threshold of approximately $1,700 per ton of NOx emissions 

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 (SJVAPCD) 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 unit 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 covered 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 Analysis Page 3

District rule limit of 0.10 lbs NOx per Megawatt-hour output is equivalent to the 

SJVAPCD rule standard limit of 0.011 lb/MMBtu heat input 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 sterilizers 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 the RACT threshold and therefore Rule 62.6 

is not required to meet RACT requirements.

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

Rule 70 reduces ROC emissions from the storage and transfer of gasoline at bulk plants, 

terminals, and 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) sets 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 correspondence 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: CRUDE OIL PRODUCTION AND SEPARATION (Last Revised

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 70
2014 RACT Analysis 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 ROC 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 floating 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 Rule 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 90% 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 recovery 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 into 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 greater. 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 

Revised 9/26/1989)

Rule 71.2 reduces ROC emissions from equipment used to store crude oil or reactive 

organic compound liquids with a Modified Reid Vapor Pressure 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-ground gasoline 

tanks 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 many 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-vacuum relief valve or 
2014 RACT Analysis 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 requirements 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 emission 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 from 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. The 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 less 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 revision at this time.
2014 RACT Analysis 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, separated, 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 SCAQMD 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 defined 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 liquids 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 dehydrators 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 applicable to any person 

who supplies, sells, offers for 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 OPERATIONS (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 Rule 
2014 RACT Analysis Page 7

4607 (amended 12/18/2008) apply to the same operations 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 Rules 

1128 and 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 

1128 and Rule 4607 both require transfer efficiencies equivalent to 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 and 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 manufactures, 

sells, or offers for sale cutback asphalt for 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 500 °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 12/4/1990)

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 similar 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 requirements 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 Analysis Page 8

Rule 1102 prohibits operation 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 subject to the New Source Review process, which will require BACT and a 

prohibition on transfer machines. 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)

Rule 74.5.2 reduces ROC emissions from synthetic solvent dry cleaning equipment that 

does not use percholorethylene through emission control, filtration equipment, and 

operating requirements.

SCAQMD Rule 1102 (amended 11/17/2000) applies to any dry cleaning 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 repairing 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 

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

Rule 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 tanks (e.g., hand wipe cleaning, cleaning with handheld spray bottles) or using 

cold cleaning apparatus.

SCAQMD Rules 1122 and 1171 (both amended 5/1/2009) 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 content 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 solvents, except 

Rules 4662 and 4663, which require controlled emissions 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 74.6 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 medical devices
2014 RACT Analysis Page 9

Ventura County meet CTG control recommendations, or fall within the exclusions 

outlined in the guidelines. In addition, the 2009 evaluation 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 4662 (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 PETROLEUM REFINERIES AND CHEMICAL PLANTS (Last Revised

10/10/1995)

Rule 74.7 reduces ROC emissions through operational and inspection requirements at 

petroleum refineries and chemical plants. Historically, only one petroleum refinery and 

only a few chemical plants have operated in Ventura County. The petroleum refinery 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.

RULE 74.8: REFINERY VACUUM PRODUCING SYSTEMS, WASTEWATER 

SEPARATORS 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 refineries. 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 

engines rated at 50 or more horsepower, operated on 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 

negative declaration?
2014 RACT Analysis 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 currently 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 

operations. 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 feasible (see 

discussion under Rule 74.16). AG 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 particulates. The ATCM 

requirements 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 $1,700. 

Therefore, 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) regulates 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 categories 

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 submitted 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 Analysis Page 11

SCAQMD Rule 1173 and are focused on refinery leaks. Since there are no refineries in 

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 components. 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 and provides an incentive for sources to undertake a diligent LDAR program 

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)

Rule 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 heaters 

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 additional 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, since 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 existing units. Since Rule 74.11.1 is equivalent to Rule 4308, 

Rule 74.11.1 meets RACT and does not require an update 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 Analysis Page 12

Rule 74.12 including lower limits on a few specialty coatings. While minor differences 

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 9/11/2012)

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 from 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 equivalent to SCAQMD 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 those of the 

USEPA’s Air Toxic Rule 40 CFR Part 63 Subpart 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 CTG 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 consecutive twelve-month period. 

Therefore, Rule 74.13 exceeds 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 manufacture products from or 

otherwise use polyester resin material. ROC emissions from this manufacturing process 

are controlled by limiting loss rate, monomer ROC content, application technique, or by 

requiring emission control equipment. Limits are also placed 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 any facilities >25 tpy, the 

CTG would apply.
2014 RACT Analysis 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 power 

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. Rule 74.15 prohibits 

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 sources. 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 board materials associated with the adoption of Rule 1146 in 

2008, cost 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 approximately $1,700 per ton of NOx reduced in inflationadjusted 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 

Revised 9/11/12)

This rule is a point-of-sale rule that reduces NOx emissions by requiring large water 

heaters and small boilers that are sold, offered for sale, or installed in Ventura County to 

meet certain requirements.
2014 RACT Analysis Page 14

SCAQMD Rule 1146.1 (amended 9/5/2008) and SJVAPCD Rule 4320 (amended 

5/19/2011) apply to sources similar to those subject to Rule 74.15.1, combustion sources 

with maximum design heat input less than 5 MMBtu/hr. Rule 74.15.1 prohibits NOx and 

CO in excess of 40 ppm and 400 ppm, respectively, from subject sources with annual 

heat input greater than 1.8 x 109 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 

109 Btu. Such units may comply with the rule by performing regular 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 those 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 $1,700 per ton of NOx reduced in inflation-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 grants 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 drilling rig engines 

and will eliminate Tier 1 and Tier 2 engines from use by the end of 2015.

No oil well drilling rigs currently hold a District Permit to Operate. To obtain a Permit to 

Operate, oil well drilling engines would have to comply with more stringent 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 diesel 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 purposes, the 

requirements of Rule 74.16 do not apply and the rule is not necessary to implement 

RACT at oilfield drilling operations.
2014 RACT Analysis Page 15

RULE 74.17.1: MUNICIPAL SOLID WASTE LANDFILLS (Last Revised 2/9/1999)

Rule 74.17.1 reduces fugitive ROC emissions from municipal solid waste landfills 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 meets RACT and no changes 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 Suggested 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 reductions from this SCM 

result from auto body shops switching from solvent-based color base coats to new 

waterborne color basecoats. Other provisions of the SCM include new ROC limits of 

primer sealers, specialty coatings, and cleaning solvents used for cleaning application 

equipment. Therefore, Rule 74.18 meets RACT and no changes are required at this 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, adhesives, fountain solutions, and solvent cleaners. On June 14, 2011, 

the District adopted new ROC limits in Rule 74.19 equivalent to SCAQMD Rule 1130, 

Graphic Arts (amended 10/8/1999), and SCAQMD Rule 1171, Solvent Cleaning

(amended 5/1/2009). These new 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 operations. The rule specifies limits on the ROC content 

of inks, coating, adhesives 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 category 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 does not meet the 2006 CTG, it is being amended to 

meet the CTG.
2014 RACT Analysis 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 requirements

limit ROC emissions by limiting the ROC content of adhesives, sealants, primers, and 

cleaners.

The ROC control requirements of this rule are equivalent 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 limits in the range of 500 

to 850 g/L. Those materials would be subject 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 welding 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 semiconductor 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 analysis 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 meet 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 74.23 reduces NOx emissions from stationary turbines with rated output greater 

than 0.3 MW fueled with gaseous or liquid fuels. This applicability limit is the same as 

SCAQMD Rule 1134 (amended 8/8/1997) and SJVAPCD Rule 4703 (amended 

9/20/2007). There are 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 Analysis 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 to 

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, excluding boatyard repair facilities and marinas. Rule 

requirements limit ROC emissions by limiting the ROC content of topcoats and primers. 

Emissions of ROC from cleaners are also controlled by limiting the ROC content of 

surface prep cleaners and application 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 Operations. 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 coatings and cleaning solvents 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 requirements limit ROC emissions through 

ROC content limits on topcoats and primers. Emissions of ROC from cleaners are also 

controlled by limits on the ROC content of surface prep cleaners, the ROC composite 

vapor pressure of cleaning solvents, and requiring the use of enclosed 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 2/12/1999) 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 (Adopted 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]: This should say ROC instead of NOx.
2014 RACT Analysis 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 degassed tanks, 5,000 ppmv versus 10,000

ppmv for Rule 74.26. However, the 2004 AFM analysis states 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 considered 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. Assuming a ROC vapor density of 0.004 

lb/gallon of tank volume and a control efficiency of 95%, the cost effectiveness to control 

degassing of a 500-bbl tank ranges from $18-$25 per pound of ROC reduced (equivalent 

to $36,000 - $50,000 per ton). 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 thresholds, 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 from any 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. This 
2014 RACT Analysis 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 to 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 1149 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 addressed the tank size applicability threshold 

cost 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 gallon 

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, the 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 OPERATIONS (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 coal 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 rule 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 74.30 meets RACT and no 

changes are required at this time.
2014 RACT Analysis 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 reduces 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 equipment or operations and there are no major sources in Ventura 

County. Therefore, RACT analysis and RACT compliance are unnecessary at this time.