Antelope Valley 

Air Quality Management District 

Final 

Staff Report 

Adoption Of The 

8-Hour Reasonably Available Control Technology – State 

Implementation Plan Analysis (RACT SIP Analysis)

Adopted on 

September 19, 2006 

43301 DIVISION ST., SUITE 206, 

LANCASTER, CALIFORNIA 93535-4649 

PHONE (661) 723-8070 

FAX (661) 723-3450 
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STAFF REPORT 

TABLE OF CONTENTS 

8-Hour Reasonably Available Control Technology – State Implementation Plan 

Analysis (RACT SIP Analysis) 

I. PURPOSE OF STAFF REPORT ...........................................................................................1 

II. EXECUTIVE SUMMARY....................................................................................................1

III. STAFF RECOMMENDATION............................................................................................1 

IV. LEGAL REQUIREMENTS CHECKLIST ..........................................................................2 

V. DISCUSSION OF LEGAL REQUIREMENTS...................................................................3 

A. REQUIRED ELEMENTS/FINDINGS ..........................................................................3 

1. State Findings Required for Adoption of Rules & Regulations ......................3 

a. Necessity..............................................................................................3 

b. Authority..............................................................................................3 

c. Clarity ..................................................................................................3 

d. Consistency..........................................................................................3 

e. Non-duplication ..................................................................................4 

f. Reference..............................................................................................4 

g. Public Notice & Comment, Public Hearing ........................................4 

2. Federal Elements (SIP Submittals, Other Federal Submittals)........................4 

a. Satisfaction of Underlying Federal Requirements...............................4 

b. Public Notice and Comment................................................................4 

c. Availability of Document ....................................................................5 

d. Notice to Specified Entities .................................................................5 

e. Public Hearing ......................................................................................5 

f. Legal Authority to Adopt and Implement ............................................5 

g. Applicable State Laws and Regulations Were Followed ....................5 

B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS ........................................5 

C. ECONOMIC ANALYSIS ..............................................................................................6 

1. General.............................................................................................................6 

2. Incremental Cost Effectiveness ......................................................................6 

D. ENVIRONMENTAL ANALYSIS (CEQA) ..................................................................6 

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS .................................................6 

1. Potential Environmental Impacts.....................................................................6 

2. Mitigation of Impacts ......................................................................................7 

3. Alternative Methods of Compliance................................................................7 
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F. PUBLIC REVIEW..........................................................................................................7

VI. TECHNICAL DISCUSSION...............................................................................................7 

A. SIP HISTORY................................................................................................................7 

1. SIP History.......................................................................................................7 

2. SIP Analysis.....................................................................................................8 

Apendix A – 8-Hour Reasonably Available Control Technology – State Implementation Plan 

Analysis (RACT SIP Analysis) Draft Version .................................................................... A-1 

Appendix B - Public Notice Documents .....................................................................................B-1 

Appendix C - Public Comments and Responses .........................................................................C-1 

Appendix D - California Environmental Quality Act Documentation....................................... D-1 

Appendix E - Bibliography..........................................................................................................E-1 
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STAFF REPORT 

8-Hour Reasonably Available Control Technology – State Implementation Plan 

Analysis (RACT SIP Analysis)

I. PURPOSE OF STAFF REPORT 

A staff report serves several discrete purposes. Its primary purpose is to provide a summary and 

background material to the members of the Governing Board. This allows the members of the 

Governing Board to be fully informed before making any required decision. It also provides the 

documentation necessary for the Governing Board to make any findings, which are required by law to 

be made prior to the approval or adoption of a document. In addition, a staff report ensures that the 

correct procedures and proper documentation for approval or adoption of a document have been 

performed. Finally, the staff report provides evidence for defense against legal challenges regarding 

the propriety of the approval or adoption of the document. 

II. EXECUTIVE SUMMARY 

The Antelope Valley Air Quality Management District (AVAQMD) Governing Board was requested 

to conduct a public hearing, make findings, and then adopt the 8-Hour Reasonably Available Control 

Technology – State Implementation Plan Analysis (RACT SIP Analysis), and direct staff actions. 

The Federal Clean Air Act (FCAA) requires areas designated non-attainment and classified moderate 

and above to implement Reasonably Available Control Technology (RACT) for sources subject to 

Control Technique Guidelines (CTG) documents issued by the United States Environmental Protection 

Agency (USEPA) for “major sources” of volatile organic compounds (VOCs) and oxides of nitrogen 

(NOx) which are ozone precursors. On March 9, 2006, USEPA shifted its ozone standard from 

measurement on a one-hour basis to an eight-hour basis (8-hour ozone standard). For purposes of the 

FCAA, portions of the District have been designated non-attainment for ozone and classified as 

moderate for the 8-hour standard. As a result of the shift to the 8-hour standard, USEPA is requiring 

that all non-attainment areas submit an updated RACT SIP Analysis. The purpose of the RACT SIP 

Analysis is to ensure that District Rules adequately address current RACT requirements. 

III. STAFF RECOMMENDATION 

Staff recommended that the Governing Board of the AVAQMD, after conducting a public hearing, 

adopt the 8-Hour Reasonably Available Control Technology – State Implementation Plan Analysis 

(RACT SIP Analysis). Such action was necessary because the AVAQMD has been designated ozone 

non-attainment and classified moderate for the 8-hour ozone standard, therefore the AVAQMD must 

submit a RACT SIP Analysis to the EPA pursuant to the FCAA. 

The Governing Board of the AVAQMD adopted the 8-Hour Reasonably Available Control 

Technology – State Implementation Plan Analysis (RACT SIP Analysis) on September 19, 2006 
2 AVAQMD RACT SIP Analysis 

Final Staff Report, 10/18/2006

IV. LEGAL REQUIREMENTS CHECKLIST 

The findings and analysis as indicated below was required for the procedurally correct adoption of the 

8-Hour Reasonably Available Control Technology – State Implementation Plan Analysis (RACT SIP 

Analysis). Each item is discussed, if applicable, in Section V below. Copies of documents are 

included in the appropriate Appendix. 

FINDINGS REQUIRED FOR 

RULES & REGULATIONS 

 X Necessity 

 X Authority 

 X Clarity 

 X Consistency 

 X Non-duplication 

 X Reference 

 X Public Notice & Comment 

 X Public Hearing 

REQUIREMENTS FOR STATE 

IMPLEMENTATION PLAN 

SUBMISSION (SIP): 

 X Public Notice & Comment 

 X Availability of Document 

 X Notice to Specified Entities (State, 

Air Districts, USEPA, Other States) 

 X Public Hearing 

 X Legal Authority to adopt and 

implement the document. 

 X Applicable State laws and 

regulations were followed. 

ELEMENTS OF A FEDERAL 

SUBMISSION 

 X Elements as set forth in applicable 

Federal law or regulations. 

CALIFORNIA ENVIRONMENTAL 

QUALITY ACT REQUIREMENTS 

(CEQA):

N/A Ministerial Action 

 X Exemption 

N/A Negative Declaration 

N/A Environmental Impact Report 

N/A Appropriate findings, if necessary. 

 X Public Notice & Comment 

SUPPLEMENTAL ENVIRONMENTAL 

ANALYSIS (RULES & REGULATIONS 

ONLY): 

 X Environmental impacts of 

compliance. 

N/A Mitigation of impacts. 

N/A Alternative methods of compliance. 

OTHER: 

 X Written analysis of existing air 

pollution control requirements 

 X Economic Analysis 

 X Public Review 
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V. DISCUSSION OF LEGAL REQUIREMENTS 

A. REQUIRED ELEMENTS/FINDINGS 

This section discusses the State of California statutory requirements that apply to the adoption 

of the 8-Hour Reasonably Available Control Technology – State Implementation Plan Analysis 

(RACT SIP Analysis). Since this document is required to be adopted pursuant to public notice 

and other requirements under 42 USC 7410(a)(2), the district considers the rule adoption 

process pursuant to H & S Code §40702 to be a proper way to meet these requirements. 

Therefore, these are actions, that needed to be performed, and/or information, that needed to be 

provided in order to adopt this document in a procedurally correct manner. 

1. State Findings Required for Adoption of Rules & Regulations: 

Before adopting, amending, or repealing a rule or regulation, the AVAQMD Governing 

Board is required to make findings of necessity, authority, clarity, consistency, nonduplication, and reference based upon relevant information presented at the hearing. 

The information below was provided to assist the Board in making these findings. 

a. Necessity: 

The adoption of the 8-Hour Reasonably Available Control Technology – State 

Implementation Plan Analysis (RACT SIP Analysis) is necessary because the 

AVAQMD has been designated as an ozone non-attainment area and classified 

moderate for the 8-hour ozone standard. Therefore, the AVAQMD must submit 

a RACT SIP Analysis to the EPA pursuant to the FCAA.

b. Authority: 

AVAQMD has the authority pursuant to California Health and Safety Code (H 

& S Code) §40702, 40725-40728 to adopt, amend or repeal rules and 

regulations that are necessary or proper to execute the powers and duties granted 

to and imposed upon AVAQMD. 

c. Clarity: 

The proposed RACT SIP Analysis is clear in that it is written so that people 

subject to the Analysis can easily understand it. 

d. Consistency: 

The adoption of the 8-Hour Reasonably Available Control Technology – State 

Implementation Plan Analysis (RACT SIP Analysis) is in harmony with, and not 

in conflict with or contradictory to any State law or regulation, Federal law or 

regulation, or court decisions. 
4 AVAQMD RACT SIP Analysis 

Final Staff Report, 10/18/2006

e. Non-duplication: 

The adoption of the 8-Hour Reasonably Available Control Technology – State 

Implementation Plan Analysis (RACT SIP Analysis) does not impose the same 

requirements as an existing State or Federal law or regulation because Federal 

law requires the adoption of the RACT SIP Analysis. 

f. Reference: 

AVAQMD has the authority pursuant to H & S Code §40702 to adopt, amend or 

repeal rules and regulations. 

g. Public Notice & Comment, Public Hearing: 

Notice for the public hearing for the proposed adoption of the 8-Hour Reasonably 

Available Control Technology – State Implementation Plan Analysis (RACT 

SIP Analysis) was published August 19, 2006. See Appendix “B” for a copy of the 

public notice. See Appendix C for copies of comments, if any, and AVAQMD 

responses. 

2. Federal Elements (SIP Submittals, Other Federal Submittals). 

Submittals to USEPA are required to include various elements depending upon the type 

of document submitted and the underlying Federal law which requires the submittal. 

The information below indicates which elements were required for the adoption of the 

8-Hour Reasonably Available Control Technology – State Implementation Plan 

Analysis (RACT SIP Analysis) and how they were satisfied. 

a. Satisfaction of Underlying Federal Requirements: 

The adoption of the 8-Hour Reasonably Available Control Technology – State 

Implementation Plan Analysis (RACT SIP Analysis) is subject to all the 

requirements for a SIP submittal because the RACT SIP Analysis is to be 

included in the AVAQMD SIP. The criteria for determining completeness of 

SIP submissions are set forth in 40 CFR Part 51, Appendix V, 2.0. 

b. Public Notice and Comment: 

Notice for the public hearing for the proposed adoption of the 8-Hour Reasonably 

Available Control Technology – State Implementation Plan Analysis (RACT SIP 

Analysis) was published August 19, 2006. See Appendix “B” for a copy of the 

public notice. 
AVAQMD RACT SIP Analysis 5

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c. Availability of Document: 

Copies of the proposed adoption of the 8-Hour Reasonably Available Control 

Technology – State Implementation Plan Analysis (RACT SIP Analysis) and the 

accompanying draft staff report were made available to the public on August 19, 

2006. 

d. Notice to Specified Entities 

Copies of the proposed adoption of the 8-Hour Reasonably Available Control 

Technology – State Implementation Plan Analysis (RACT SIP Analysis) and the 

accompanying draft staff report were mailed to all affected agencies, including 

but not limited to CARB and USEPA. The proposed RACT SIP Analysis was 

sent to CARB and USEPA on August 15, 2006. 

e. Public Hearing: 

A public hearing to consider the proposed adoption of the 8-Hour Reasonably 

Available Control Technology – State Implementation Plan Analysis (RACT SIP 

Analysis) was conducted on September 19, 2006. 

f. Legal Authority to Adopt and Implement: 

The AVAQMD has the authority pursuant to H&S Code §40702 to adopt, 

amend, or repeal rules and regulations and to do such acts as may be necessary 

or proper to execute the duties imposed upon the AVAQMD. 

g. Applicable State Laws and Regulations Were Followed: 

Public notice and hearing procedures pursuant to H&S Code §§40725-40728 

have been followed. See Section (V)(A)(1) above for compliance with state 

findings required pursuant to H&S Code §40727. See Section (V)(B) below for 

compliance with the required analysis of existing requirements pursuant to H&S 

Code §40727.2. See Section (V)(C) for compliance with economic analysis 

requirements pursuant to H&S Code §40920.6. See Section (V)(D) below for 

compliance with provisions of the California Environmental Quality Act 

(CEQA). 

B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS 

H & S Code §40727.2 requires air districts to prepare a written analysis of all existing federal 

air pollution control requirements that apply to the same equipment or source type as the rule 

proposed for modification by the district. The adoption of the 8-Hour Reasonably Available 

Control Technology – State Implementation Plan Analysis (RACT SIP Analysis) is to ensure 

that District Rules adequately address current RACT requirements. Therefore the preparation 
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of a written analysis of existing pollution control requirements that apply to the same 

equipment or source type is not required. 

C. ECONOMIC ANALYSIS 

1. General 

Adoption of the RACT SIP Analysis will affect those facilities subject to rules requiring 

amendment to meet RACT requirements. The RACT SIP Analysis identifies necessary 

rule actions. Cost analysis will be addressed on a rule specific basis for those actions 

identified in the RACT SIP Analysis through the rule amendment process. 

2. Incremental Cost Effectiveness 

Pursuant to H&S Code §40920.6, incremental cost effectiveness calculations are 

required for rules and regulations which are adopted or amended to meet the California 

Clean Air Act requirements for Best Available Retrofit Control Technology (BARCT) 

or “all feasible measures” to control volatile compounds, oxides of nitrogen or oxides of 

sulfur. 

The adoption of the 8-Hour Reasonably Available Control Technology – State 

Implementation Plan Analysis (RACT SIP Analysis) is not subject to incremental cost 

effectiveness calculations because this document does not impose BARCT or “all 

feasible measures”. 

D. ENVIRONMENTAL ANALYSIS (CEQA) 

Through the process described below, it was determined that a Notice of Exemption would be 

the appropriate CEQA process for the adoption of the 8-Hour Reasonably Available Control 

Technology – State Implementation Plan Analysis (RACT SIP Analysis). 

1. The adoption of the 8-Hour Reasonably Available Control Technology – State 

Implementation Plan Analysis (RACT SIP Analysis) meets the CEQA definition 

of "project." It is not a "ministerial" action. 

2. The adoption of the 8-Hour Reasonably Available Control Technology – State 

Implementation Plan Analysis (RACT SIP Analysis) is exempt from CEQA 

review because it will not create any adverse impacts on the environment. 

Because there is no potential that the adoption might cause the release of 

additional air contaminants or create any adverse environmental impacts, a Class 

8 categorical exemption (14 Cal. Code Reg. §15308) applies. 

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS 

1. Potential Environmental Impacts 

There are no potential negative environmental impacts of compliance with the proposed 

adoption of the RACT SIP Analysis. 
AVAQMD RACT SIP Analysis 7

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2. Mitigation of Impacts 

N/A 

3. Alternative Methods of Compliance 

N/A 

F. PUBLIC REVIEW 

See Staff Report Section (V)(A)(1)(g) and (2)(b), as well as Appendix B. 

VI. TECHNICAL DISCUSSION 

The FCAA requires that ozone non-attainment areas implement RACT for sources that are 

subject to Control Techniques Guidelines (CTGs) and for major sources of ozone precursors. 

This document: (1) reviews all available instances of RACT for applicability to the AVAQMD; 

(2) reviews all AVAQMD major sources for RACT applicability; and (3) identifies any actions 

the AVAQMD must take to address applicable RACT requirements. This document satisfies 

42 U.S.C. §§7511a (FCAA §182) regarding RACT requirements for the eight-hour ozone 

National Ambient Air Quality Standard (NAAQS). 

The AVAQMD has evaluated its adopted rules and all of its major sources of ozone precursors 

to ensure that current rules meet the definition of RACT. 

This section gives a brief overview of the proposed adoption of the 8-Hour Reasonably 

Available Control Technology – State Implementation Plan Analysis (RACT SIP Analysis). 

A. SIP HISTORY 

1. SIP History. 

The AVAPCD came into existence pursuant to statute on July 1, 1997 Health & Safety 

Code 40106, A.B. 266-Knight Ch. 542, statutes of 1996). The rules and regulations of 

the SCAQMD remain in effect within the AVAPCD until the AVAPCD Governing 

Board adopts, amends or rescinds new ones Health & Safety Code 40106(e)). Since the 

SIP applies to the territory for which it was approved at the time it was approved, the 

AVAPCD also inherited the SCAQMD SIP applicable to the Los Angeles County 

portion of the South East Air Basin (now called the Mojave Desert Air Basin) prior to 

July 1, 1997. On January 1, 2002 the AVAQMD was created pursuant to statute H&S 

Code 41300 et seq.) to replace the AVAPCD. Once again the SIP in effect at the time of 

the change remained in effect until the AVAQMD Governing Board superceded, 

amended or rescinded it. There is no equivalent document currently in the AVAQMD 

SIP.
8 AVAQMD RACT SIP Analysis 

Final Staff Report, 10/18/2006

2. SIP Analysis. 

The RACT SIP Analysis will be submitted to the USEPA for inclusion into the State 

Implementation Plan. 
AVAQMD RACT SIP Analysis A-1

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APPENDIX "A"

8-Hour Reasonably Available Control Technology – State Implementation Plan 

Analysis (RACT SIP Analysis) 

Draft Version 

Please see the AVAQMD 8-Hour Reasonable Available Control Technology – State Implementation Plan 

Analysis (RACT SIP Analysis) as contained in the September 19, 2006 adoption package. 
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APPENDIX "B" 

PUBLIC NOTICE DOCUMENTS

1. Proof of Publication for Notice of Public Hearing – Antelope Valley Press, August 19, 2006 
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APPENDIX "C" 

PUBLIC COMMENTS AND RESPONSES

1. USEPA letter dated September 11, 2006 
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District response to USEPA comments 

General Comments

 (1) “Rules needing further clarification that they still represent RACT if needed for RACT” 

The set of rules in Table 1 was evaluated against the document provided by the USEPA 

provided to help establish RACT: “Beyond VOC RACT CTG Requirements” (EPA-453/R95-010, 4/95. NTIS PB-95-239-497), CTG. The Antelope Valley Air Pollution Control 

District (AVAPCD) was created July 1, 1997 pursuant to statute (former H&S Code 

§40106, A.B. 266-Knight Ch. 542, statutes of 1996) and assumed all air pollution control 

responsibilities from the SCAQMD for the area of Los Angeles County outside the South 

Coast Air Basin. The SCAQMD rules in effect within the jurisdiction of the AVAPCD 

remained in effect until the AVAPCD Governing Board superceded, amended, or 

rescinded them. On January 1, 2002 the Antelope Valley Air Quality Management 

District (AVAQMD) was created pursuant to statute (H&S Code §41300 et seq.) to replace 

the AVAPCD. Once again the rules in effect at the time of the change remained in effect 

until the AVAQMD Governing Board superceded, amended or rescinded them. The rules 

listed in table 1 are the SCAQMD rules adopted by the AVAQMD upon its formation. At 

the time the SCAQMD rules were evaluated by USEPA, they were determined to be 

“Beyond RACT’, hence no further evaluation was deemed necessary by the District. The 

District is not aware of any significant changes in technology for the categories in 

question. 

 (2) “Rules that should be submitted for SIP approval if needed for RACT”

Rule 1110.2 – Emissions from Gaseous and Liquid Fueled ICEs as amended 5/15/01 

submitted as a SIP revision on 4/01/2003. 

Rule 1128 – Paper Fabric and Film Coating Operations as amended by SCAQMD on 

03/08/1996 was submitted as a SIP Revision by CARB on 07/23/1996. Such submission 

applies to the jurisdiction of the SCAQMD as it existed on 07/23/1996. The SIP approval of 

this rule (if it has occurred) should include the territory now known as the AVAQMD 

(which occurred on 07/01/1997). 

Rule 1130 – Graphic Arts as amended by SCAQMD on 03/08/1996 was submitted as a SIP 

revision by CARB on 07/23/1996. Such submission applies to the jurisdiction of the 

SCAQMD as it existed on 07/23/1996. The SIP approval of this rule (if it has occurred) 

should include the territory now known as the AVAQMD (which occurred on 07/01/1997). 

Rule 1134 – Emissions of NOx from Stationary Gas Turbines as amended by SCAQMD on 

04/11/1997, before the creation of the AVAPCD, was submitted as a SIP revision by CARB 

on 08/01/1997 after the statutory creation of the AVAPCD (predecessor agency to the 

AVAQMD). Such submission applies to the jurisdiction of SCAQMD as it existed on 

08/01/1997 that excludes the jurisdiction of the AVAQMD. Since the amendment occurred 
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before the creation of the AV District the rule itself was statutorily rolled over on 

07/01/1997 as an AVAPCD (now AVAQMD) rule. However, the AVAQMD does not 

have or maintain any records regarding the amendment and does not have access to such 

documentation and therefore can not submit the rule as a SIP revision. 

USEPA has never provided specific guidance regarding rules that were adopted or amended 

by SCAQMD prior to 07/1/1997 but submitted after the statutory creation of the AVAPCD 

(AVAQMD). If USEPA can provide such guidance in writing regarding the steps needed 

to be taken (absent re-adopting the rule which is unnecessary) to submit such a rule the 

AVAQMD will be happy to request CARB take the appropriate action or actions. 

Rule 1141.1 – Coatings and Ink Manufacturing as amended by SCAQMD on 03/06/1992, 

before the creation of the AVAPCD, was submitted as a SIP revision by CARB on 

09/14/1992. The approval of this rule into the SIP was not until 05/04/1999 after the 

statutory creation of the AVAPCD (predecessor agency to the AVAQMD). Since the 

amendment occurred before the creation of the AV District the rule itself was statutorily 

rolled over on 07/01/1997 as an AVAPCD (now AVAQMD) rule. However, the 

AVAQMD does not have or maintain any records regarding the amendment and does not 

have access to such documentation and therefore can not submit the rule as a SIP revision. 

USEPA has never provided specific guidance regarding rules that were adopted or amended 

by SCAQMD prior to 07/01/1997 but submitted or approved after the statutory creation of 

the AVAPCD (AVAQMD). If USEPA can provide such guidance in writing regarding the 

steps needed to be taken (absent re-adopting the rule which is unnecessary) to submit such 

a rule the AVAQMD will be happy to request CARB take the appropriate action or actions. 

Rule 1145 – Plastic, Rubber and Glass Coatings and Adhesives as amended by SCAQMD 

on 02/14/1997 (before creation of the AVAPCD) was submitted by CARB on 08/01/97, 

after the creation of the AVAQMD. Such submission applies to the jurisdiction of 

SCAQMD as it existed on 08/01/1997 that excludes the jurisdiction of the AVAQMD. 

Since the amendment occurred before the creation of the AV District the rule itself was 

statutorily rolled over on 07/01/1997 as an AVAPCD (now AVAQMD) rule. However, the 

AVAQMD does not have or maintain any records regarding the amendment and does not 

have access to such documentation and therefore can not submit the rule as a SIP revision. 

USEPA has never provided specific guidance regarding rules that were adopted or amended 

by SCAQMD prior to 07/01/1997 but submitted after the statutory creation of the 

AVAPCD (AVAQMD). If USEPA can provide such guidance in writing regarding the 

steps needed to be taken (absent re-adopting the rule which is unnecessary) to submit such 

a rule the AVAQMD will be happy to request CARB take the appropriate action or actions. 

Rule 1168 – Control of VOC from Adhesive Application was amended by SCAQMD on 

04/11/1997 (before the creation of the AVAQMD) and was most likely submitted by 

CARB after the creation of the AVAQMD on 07/01/1997. Such submission applies to the 

jurisdiction of SCAQMD as it existed on the submission date that excludes the jurisdiction 

of the AVAQMD. Since the amendment occurred before the creation of the AV District the 
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rule itself was statutorily rolled over on 07/01/1997 as an AVAPCD (now AVAQMD) rule. 

However, the AVAQMD does not have or maintain any records regarding the amendment 

and does not have access to such documentation and therefore can not submit the rule as a 

SIP revision. 

USEPA has never provided specific guidance regarding rules that were adopted or amended 

by SCAQMD prior to 07/01/1997 but submitted after the statutory creation of the 

AVAPCD (AVAQMD). If USEPA can provide such guidance in writing regarding the 

steps needed to be taken (absent re-adopting the rule which is unnecessary) to submit such 

a rule the AVAQMD will be happy to request CARB take the appropriate action or actions. 

Rule 1176 – Sumps and Wastewater Separators was amended by SCAQMD on 09/13/1996 

by SCAQMD before the creation of the AVAQMD. It is unknown at this time if and when 

it was submitted as a SIP revision by CARB. 

CTG Sources – Negative Declaration

(3) A separate “Proposed Adoption Of The Federal Negative Declarations For 51 Source 

Categories” will be submitted to the USEPA that includes the requested FND language 

as follows: 

“The AVAQMD has examined its permit files, emissions inventory and other 

documentation and has determined that there are no sources in the fifty-one source 

categories referenced in attachment A, located within the jurisdiction of the AVAQMD 

and none are anticipated in the near future”. 

 (4) See response to comment 3 above. 

(4) The District does not have sources in any of the categories identified. 

In the USEPA comment letter, enclosure (3) page 1 it is suggested that an addition FND 

should be adopted for the source category “ Surface Coating Operations At 

Shipbuilding and Ship Repair Facilities”. We have determined that this source category 

is already covered by the “Marine Coating Operations” FND. 

Required RACT Actions

 (6) The District will forward the proposed rules to the State for SIP submission as soon as 

possible. 

Future CTGs

 (7) The District will submit SIP revisions within one year after the CTGs referenced are 

finalized. 
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APPENDIX "D" 

CALIFORNIA ENVIRONMENTAL QUALITY ACT 

DOCUMENTATION

(to be included as available) 

1. Notice of Exemption – Los Angeles County, 09/26/2006 
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APPENDIX "E" 

BIBLIOGRAPHY

The following documents were consulted in the preparation of this staff report and the proposed 

adoption of the 8-Hour Reasonably Available Control Technology – State Implementation Plan 

Analysis (RACT SIP Analysis):

1. Environmental Protection Agency – Final Rule to Implement the 8-Hour Ozone 

NAAQS (70 FR 71617, November 29, 2005) 

2. EPA – various CTGs, ACTs, and other documents 

3. EPA – letter from Andrew Steckel, EPA Region IX to Kurt Karperos, ARB dated 

March 9, 2006 – RACT SIP 

4. EPA – letter from Andrew Steckel, EPA Region IX to Kurt Kaperos, ARB dated 

April 4, 2006 – RACT CTG table 

5. California Health and Safety Code – various sections 
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