San Joaquin Valley 

Air Pollution 

Control District

 

2009 RACT SIP 

Reasonably Available Control Technology (RACT) 

Demonstration for Ozone State Implementation Plans (SIP) 

April 16, 2009
San Joaquin Valley Unified Air Pollution Control District 

1990 E. Gettysburg Avenue 

Fresno, California 93726 

(559) 230-6100 

www.valleyair.org
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Table of Contents 

RACT Demonstration for Ozone SIP 

i 

Table of Contents

Table of Contents 

Acknowledgements 

Chapter 1: Overview 

1.1 Introduction........................................................................................................ 1-1 

1.2 Reason For This Project .................................................................................... 1-2 

1.2.1 One-Hour Ozone Requirements................................................................ 1-2 

1.2.2 Eight-Hour Ozone Requirements .............................................................. 1-3 

1.2.3 Additional Requirements ........................................................................... 1-3 

1.3 Eight-hour Ozone RACT Demonstration Elements............................................ 1-4 

1.4 Process for Developing This RACT Demonstration SIP .................................... 1-5 

1.4.1 RACT Demonstration Process .................................................................. 1-5 

1.4.1.1 Federal Applicability of RACT ......................................................... 1-5 

1.4.1.2 Definition and Stringency of RACT.................................................. 1-6 

1.4.1.3 Purpose of Federal RACT............................................................... 1-6 

1.4.1.4 RACT Guidance from EPA Region IX ............................................. 1-8 

1.4.1.5 Issues Regarding Federal Expectations for RACT.......................... 1-8 

1.4.2 RACT Demonstration Process .................................................................. 1-8 

1.4.3 Public Process........................................................................................... 1-9 

1.5 Glossary ............................................................................................................1-9 

Chapter 2: CTG Source Categories and Applicable District Rules 

2.1 District Implementation of EPA CTGs................................................................ 2-1 

2.1.1 CTG Sources............................................................................................. 2-1 

2.1.2 CTGs Without Subject Facilities ................................................................ 2-5 

2.1.2.1 Surface Coating Operations at Ship Building and Ship Repair Facilities .. 2-5 

2.1.2.2 Pharmaceutical Manufacturing Operations ..................................... 2-6 

2.1.2.3 References...................................................................................... 2-7 

Chapter 3: Major Sources and Applicable RACT Rules 

3.1 Major Source Listing .......................................................................................... 3-1 

Chapter 4: Rule Analysis 

4.1 Rules Analyzed for RACT.................................................................................. 4-1 

4.2 Rules On A Schedule to Implement RACT/CTG Requirements .................... 4-376 

4.2.1 Rules Implementing RACT Requirements............................................. 4-376 

4.2.2 Rules Implementing CTG Requirements............................................... 4-376 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

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Appendices 

Appendix A: Comments and Responses 

A.1 EPA Comments...............................................................................A-1 

A.2 ARB Comments ..............................................................................A-5 

A.3 Stakeholder Comments...................................................................A-5 

Appendix B: Rule 4570 BACT Analysis 
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List of Tables 

Table 2-1 Control Techniques Guidelines ........................................................ 2-2 

Table 3-1 Major Sources and Applicable RACT Rules..................................... 3-2 

Table 4-1 District Rules Analyzed and Rule History......................................... 4-2 

Table 4-2 District NOx and VOC Rules Not Analyzed...................................... 4-6 

Table 4-3 Schedule for District Rules Needing Amendments....................... 4-377 
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Acknowledgments 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009 

Acknowledgments 

RACT Demonstration for Ozone SIP

ACKNOWLEDGMENTS 

The District wishes to acknowledge the leadership and effort of those 

who contributed to the RACT Demonstration for Ozone SIP Report. 

Project Management and Supervision

Rick McVaigh, Deputy Air Pollution Control Officer 

Scott Nester, Director of Planning 

Dave Warner, Director of Permit Services 

Errol Villegas, Planning Manager 

Jim Swaney, Permit Services Manager 

Sheraz Gill, Supervising Air Quality Engineer 

Contributors

Ross Badertscher, Air Quality Specialist

Sandra Lowe-Leseth, Air Quality Engineer

Joe Nazareno, Senior Air Quality Engineer 

Brian Clements, Senior Air Quality Engineer 

Kamaljit Sran, Senior Air Quality Engineer 

Derek Fukuda, Air Quality Engineer 

Jonah Aiyabei, Air Quality Engineer 
RACT Demonstration for Ozone SIP

Chapter 1 

 

Overview 
RACT Demonstration for Ozone SIP

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Chapter 1: Overview 

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Chapter 1: Overview

1.1 INTRODUCTION 

The San Joaquin Valley Air Basin (SJVAB) is an inter-mountain valley comprised of 

eight counties in California’s San Joaquin Valley: Fresno, Kings, Madera, Merced, San 

Joaquin, Stanislaus, Tulare, and the Valley portion of Kern. The SJVAB is 

approximately 250 miles long, averages 80 miles wide, and is partially enclosed by the 

Coast Range on the west, the Tehachapi Mountains on the south, and the Sierra 

Nevada on the east. These surrounding mountains trap pollution. The region’s low 

wind speeds, combined with low-level temperature inversions in the winter, are 

conducive to trapping particulates, and the region’s hot, sunny, and dry summers are 

conducive to ozone formation. Due to the topography and meteorological conditions, 

the SJVAB faces air quality challenges unmatched by any other air basin. 

The SJVAB is currently designated as nonattainment for the PM2.5 (Particulate Matter 

2.5 microns or less in diameter) National Ambient Air Quality Standard (NAAQS) and 

extreme nonattainment for the eight-hour ozone NAAQS. Prior to the United States 

Environmental Protection Agency’s (EPA’s) implementation of the eight-hour ozone 

standard, the SJVAB was also classified as an extreme nonattainment area for the onehour ozone NAAQS. Although EPA revoked the one-hour ozone NAAQS, the San 

Joaquin Valley Air Pollution Control District (District) is still required to meet certain 

related requirements mandated by the federal Clean Air Act. In addition to being 

designated as nonattainment of federal air standards, SJVAB is designated as 

nonattainment for the California ozone air quality standards and nonattainment for the 

California PM10 and PM2.5 air quality standards. 

Since its formation in 1992, the San Joaquin Valley Unified Air Pollution Control District 

(District) has adopted about 500 rules and rule amendments. The District was the 

nation’s first air district to adopt a progressive Indirect Source Review (ISR) program, 

and was the first air district to adopt rules to control emissions of volatile organic 

compound (VOC) from wine production and storage operations and residential 

fireplaces. In addition, the District leads the nation with its stringent oxides of nitrogen 

(NOx) emission limits on engines, boilers, turbines, and glass-melting furnaces. 

Air quality improvements evidence the success of the District’s innovative and effective 

rules. Significant progress has been made towards the attainment of the ozone and 

PM2.5 NAAQS and the EPA has redesignated the SJVAB from nonattainment to 

attainment for the PM10 NAAQS. 
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1.2 REASON FOR THIS PROJECT 

Despite the progress towards attainment, the SJVAB remains in nonattainment for 

ozone and Sections 182(b)(2) and 182(f) of the federal Clean Air Act require ozone 

nonattainment areas to implement RACT for sources that are subject to Control 

Techniques Guidelines (CTG) documents issued by EPA and for “major sources” of 

volatile organic compounds (VOCs) and oxides of nitrogen (NOx), which are ozone 

precursors. RACT requirements are included in the Clean Air Act to assure that 

significant source categories at major sources in the nation’s nonattainment areas are 

controlled to a “reasonable” extent. 

This document demonstrates that all federal RACT requirements have been satisfied in 

the SJVAB. 

1.2.1 One-hour Ozone Requirements 

In June of 2004, United States Environmental Protection Agency (EPA) designated San 

Joaquin Valley Air Basin as nonattainment for the new 8-hour ambient air quality 

standard for ozone. Subsequently, in June of 2005, EPA revoked the previous 1-hour 

ambient air quality standard. However, prior to EPA's revocation of the 1-hour ozone 

standard, in October 2004, the District had submitted an Extreme Ozone Attainment 

Demonstration Plan (EOADP) for the 1-hour ozone standard. Within the EOADP, was a 

RACT discussion (Section 4.2.5) which satisfied all the requirements that EPA had 

specified at the time. 

In November 2005, EPA changed its policy for RACT in SIPs, as outlined in their Final 

Rule to Implement the 8-hr Ozone National Ambient Air Quality Standard-Phase 2 (70 

FR 71612). In 2008, EPA notified the District that the 2004 EOADP RACT discussion 

did not meet the requirements of the new policy. District staff, in discussions with EPA 

staff, determined that the most prudent course of action to address this discrepancy was 

to formally withdraw the RACT discussion from the 2004 EOADP, thereby removing it 

from EPA's review and approval process for the 1-hr ozone SIP requirements. 

Therefore, on August 21, 2008, the District’s Governing Board approved agenda item 

“Adopt the Clarifications and Documentation Regarding the 2004 Extreme Ozone 

Attainment Demonstration Plan for the Revoked Federal I-Hour Ozone Standard”, which 

provided EPA with the necessary documentation and clarification needed to take final 

action on the 2004 1-hour ozone plan. Contained within this Governing Board item was 

the withdrawal of the RACT portion of that plan (Section 4.2.5) and a commitment to 

replace it with a new RACT analysis. 

Then on January 21, 2009, EPA published in the Federal Register a “Finding of Failure 

to Submit a Required State Implementation Plan Revision for 1-Hour Ozone Standard, 

California--San Joaquin Valley – Reasonably Available Control Technology”. This 

action triggered sanction "clocks" under the Clean Air Act. The first sanction clock runs 

for 18 months and, if not stopped, imposes a 2:1 ratio on offsets for new major 
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stationary sources. The second sanction runs for 24-months and, if not stopped, would 

restrict the use of federal highway funds in the area, with the exception of certain safety 

and air quality projects. The District can avoid sanctions by submitting a completed 

RACT plan that meets the federal expectations. 

This RACT demonstration report will satisfy the commitment for a new RACT analysis 

for the 1-hour ozone plan and prevent all sanctions that could be imposed by the 

“finding of failure to submit”. 

1.2.2 Eight-hour Ozone Requirements 

According to the EPA’s Final Rule to Implement the Eight-Hour Ozone NAAQS (70 FR 

71612, November 29, 2005), areas classified as moderate nonattainment or higher 

must submit a demonstration that their current rules fulfill eight-hour ozone RACT for all 

CTG categories and all major, non-CTG sources. This demonstration would be a 

revision to their State Implementation Plan (SIP). States can demonstrate that RACT is 

being fulfilled with either a new RACT determination or a certification that previously 

required RACT controls also represent RACT for eight-hour ozone. Areas may rely on 

previous analyses written for one-hour ozone plans and EPA guidance documents. 

On August 17, 2006 the District Governing Board adopted a RACT SIP analysis for its 

eight-hour ozone serious nonattainment classification. Per Section 182 (c) of the 

federal Clean Air Act, areas classified as serious nonattainment have a 50 tons per year 

(tpy) major source definition. The Valley did not, however, experience a 50 tpy 

threshold because of state law and the federal revocation of the 1-hour ozone 

standard.1

 The August 2006 RACT SIP analysis showed that the District’s rules met or 

exceeded RACT requirements for all applicable EPA source categories. The final eighthour ozone attainment plan (2007 Ozone Plan), adopted on April 30, 2007, requested 

an extreme nonattainment classification for the District. For areas classified as extreme 

nonattainment, the major source definition is 10 tpy VOC or NOx (Section 182 (e) of the 

federal Clean Air Act). 

To assess the District’s rules based on the adjusted major source definition of 10 tpy, on 

December 28, 2007 the District published a revised RACT SIP analysis for public 

comment. The analysis also evaluated District rules against four new CTGs 

promulgated between August 2006 and December 2007 and reviewed additional rules 

and rule amendments for RACT that were adopted by the District’s Governing Board 

between August 17, 2006 and December 2007. The District received comment letters 

from EPA and Earthjustice which suggested that the District conduct a more thorough 

analysis for each rule to address RACT and evaluate how emission limits found 

reasonable in other areas have changed since EPA approval of the District’s rules. 

 

1

 Section 42504 of the California Health and Safety Code stipulates that any major source threshold in effect as of 

December 30, 2002 cannot be relaxed to a higher threshold. On December 30, 2002 the Valley was classified as 

severe nonattainment for 1-hour ozone, so the threshold remained at 25 tpy. This state law prevented the Valley’s 

major source threshold from rising to 50 tpy upon classifying the Valley as serious nonattainment for 8-hour ozone. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

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This RACT demonstration report therefore, replaces both the original August 17, 2006 

RACT SIP analysis and the December 28, 2007 revised RACT SIP analysis as it 

assesses the District’s rules based on the adjusted major source definition of 10 tpy, 

evaluates District rules against new CTGs promulgated since August 2006, and also 

reviews additional rules and rule amendments for RACT that have been adopted by the 

District’s Governing Board since August 17, 2006. 

1.2.3 Additional Requirements 

As part of the August 2006 RACT SIP analysis, District staff identified eight rules2

 that 

were not previously submitted to EPA for inclusion into the SIP. In May 2007, District 

staff submitted the rules to the California Air Resources Board (ARB) for transmittal to 

EPA for inclusion into the SIP. On January 2, 2008, EPA published in the Federal 

Register (73 FR 48) a direct final approval of the rules into the SIP. The direct final 

action was published without prior proposal because EPA anticipated no adverse 

comment. The direct final rule stated that if adverse comments were received by 

February 1, 2008, EPA would publish a timely removal in the Federal Register. EPA 

received a timely adverse comment which suggested that the rules did not meet the 

federal Clean Air Act, Section 172(c)(1) requirements for RACT and consequently 

removed the direct final approval of the rules. It should be noted that the EPA did not 

determine that these rules do not satisfy RACT. 

This RACT demonstration report also addresses EPA’s request for additional 

information regarding the eight rules proposed for direct final approval 

1.3 EIGHT-HOUR OZONE RACT DEMONSTRATION ELEMENTS 

A letter from EPA, Region IX outlined a possible RACT SIP submittal strategy. The 

strategy included five main points: 

3⁄4 A description of efforts to identify all source categories within the District requiring 

RACT, including CTG sources (i.e., covered by an EPA Control Technique Guideline 

document) and major non-CTG sources. 

3⁄4 A submission of negative declarations where there are no facilities (major or minor) 

within the District subject to a CTG. 

3⁄4 A list of the state/local regulation that implements RACT for all categories needing 

RACT, including the date EPA approved these regulations as fulfilling RACT. 

 

2

 Rule 4104 (Reduction of Animal Matter); Rule 4402 (Crude Oil Production Sumps); Rule 4404 (Heavy Oil Test 

Station – Kern County); Rule 4453 (Refinery Vacuum Producing Devices or Systems); Rule 4454 (Refinery Process 

Unit Turnaround); Rule 4625 (Wastewater Separators); Rule 4641 (Cutback, Slow Cure, and Emulsified Asphalt, 

Paving and Maintenance Operations); and Rule 4672 (Petroleum Solvent Dry Cleaning Operations) 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

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3⁄4 A description of the basis for concluding that the regulations fulfill RACT. 

Documents useful in establishing RACT include CTGs, Alternative Control 

Technique guidelines (ACT), Maximum Achievable Control Technology (MACT) 

standards, New Source Performance Standards (NSPS), California Suggested 

Control Measures (SCM) and RACT/Best Available Retrofit Control Technology 

(BARCT) determinations, regulations adopted in other Districts, and guidance and 

rules developed by other state and local agencies. 

3⁄4 If a district uses CAPCOA’s September 2003 Potential All Feasible Measures (AFM) 

Report to help demonstrate RACT, the RACT SIP should certify that local 

regulations are equivalent to AFM, justify the assumption that the AFM fulfilled 

RACT in 2003, and include some sort of certification/demonstration that no 

additional controls have become more reasonably available since then. 

Pursuant to EPA’s guidance, this RACT Demonstration report is composed of several 

main elements: 

• A demonstration that EPA’s CTGs are being implemented appropriately in the 

SJVAB, and a discussion of two CTG categories that do not exist in the SJVAB. 

(See Chapter 2) 

• A demonstration that all major sources in the SJVAB are covered by RACT rules. 

(See Chapter 3) 

• A demonstration that the District’s rules for ozone precursors (NOx and VOC) 

satisfy RACT levels of stringency, applicability, and enforceability. (See Chapter 

4) 

1.4 PROCESS FOR DEVELOPING THIS RACT DEMONSTRATION SIP 

1.4.1 Review Of Federal RACT Requirements 

1.4.1.1 Federal Applicability of RACT 

The Clean Air Act (CAA) Section 182(b)(2) states that ozone attainment plans shall assure 

that RACT for volatile organic compounds (VOC) is applied at certain sources. 

“The State shall submit a revision to the applicable implementation plan to 

include provisions to require the implementation of reasonably available 

control technology under section 172(c)(1) of this title with respect to each 

of the following: 

(A) Each category of VOC sources in the area covered by a CTG 

document issued by the Administrator between November 15, 1990, and 

the date of attainment. 
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(B) All VOC sources in the area covered by any CTG issued before 

November 15, 1990. 

(C) All other major stationary sources of VOCs that are located in the 

area.” 

Section 182(f) extends federal RACT requirements to NOx rules and major NOx 

sources. Because the San Joaquin Valley Air Basin is classified as an extreme ozone 

area, “major sources” are those that generate more than 10 tons per year of NOx or 

VOC. 

1.4.1.2 Definition and Stringency of RACT 

Although the Clean Air Act itself does not define Reasonably Available Control 

Technology, 40 CFR 51.100(o) defines RACT as: 

”devices, systems, process modifications, or other apparatus or techniques 

that are reasonably available, taking into account (1) the necessity of 

imposing such controls in order to attain and maintain a national ambient air 

quality standard; (2) the social, environmental, and economic impact of such 

controls; and (3) alternative means of providing for attainment and 

maintenance of such a standard.” 

The foregoing definition applies to a specific federal provision regarding approval of 

extension requests for attainment plans for secondary air quality standards, but in the 

absence of a more definitive regulatory description, it is concise and useful. EPA also 

defined RACT in the Strelow memorandum3

 as: 

“the lowest emission limitation that a particular source is capable of meeting 

by the application of control technology that is reasonably available, 

considering technological and economic feasibility”. 

1.4.1.3 Purpose of Federal RACT 

The Clean Air Act requires RACT for certain sources in all nonattainment areas 

nationwide, regardless of the severity of the ozone problem. 

“172(c) Nonattainment plan provisions 

The plan provisions (including plan items) required to be submitted under 

this part shall comply with each of the following: 

(1) In general 

 

3

 The Strelow RACT Memorandum, published in BNA Environmental Reporter, December 9, 1976, pages 1210-1212 
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Such plan provisions shall provide for the implementation of all reasonably 

available control measures as expeditiously as practicable (including such 

reductions in emissions from existing sources in the area as may be 

obtained through the adoption, at a minimum, of reasonably available control 

technology) and shall provide for attainment of the national primary ambient 

air quality standards.” 

From this section, it is clear that RACT is intended as the minimum level of control that 

all ozone nonattainment areas must achieve for existing sources. It is also clear that 

RACT is not intended as the only level of control needed for all nonattainment areas to 

attain the ozone standard. Two key conclusions are drawn from the section above: 

first, states must adopt RACT for existing sources regardless if they are needed for 

attainment, and second, states may need additional measures beyond RACT to attain 

the standard. This second conclusion leads to the understanding that RACT is not 

intended to be the most stringent level of control in an area’s attainment strategy. 

In the greater context of air pollution control levels, RACT is understood as the “floorlevel” of air pollution controls, not the “ceiling-level.” More effective levels of emissions 

control are termed Best Available Control Technology (BACT) and Lowest Achievable 

Emission Rate (LAER). BACT and LAER are required for new sources, and for existing 

sources undergoing modification. Under state and federal air pollution programs, new 

facilities face more stringent pollution control requirements than existing facilities, with 

the understanding that better controls can be more easily implemented before a facility 

is built, than after it is built. New sources must generally implement BACT4

 and existing 

sources must implement a less stringent level of control such as Reasonably Available 

Control Technology (RACT). Additionally, California law establishes an intermediate 

level of control that is the “best available” for “retrofit” to existing sources (entitled Best 

Available Retrofit Control Technology – BARCT5), recognizing that the state’s worst 

ozone problems demands more effective pollution control than what is usually 

considered “reasonably available.” 

As discussed above, the purposes of BACT, RACT, and BARCT are different. BACT is 

designed to minimize the growth in future stationary source emissions with the 

installation of best available controls; RACT is designed to reduce current stationary 

source emissions from existing sources with the application of reasonably available 

controls; and BARCT is designed to reduce current stationary source emissions even 

further with the application of best available retrofit controls. BACT is identified and 

prescribed in the permitting process on a case-by-case administrative basis. RACT and 

 

4

 Federal regulations for permitting new facilities require Best Available Control Technology (BACT) for new sources 

in attainment areas, and Lowest Achievable Emission Rate (LAER) – a generally more stringent level –for new 

sources in nonattainment areas. LAER differs from BACT in that economic costs are not considered for candidate 

LAER controls that are considered “Achieved in Practice.” Under California state law, the District is required to apply 

“BACT” for new sources under essentially the same requirements as federal LAER. The District’s “BACT” 

determinations thus fulfill the federal LAER requirements. 5

 California Health and Safety Code (CH&SC) 40406: ... "best available retrofit control technology" means an 

emission limitation that is based on the maximum degree of reduction achievable, taking into account environmental, 

energy, and economic impacts by each class or category of source. 
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BARCT are developed on an industry-wide basis in the rule development process, 

which concludes with quasi-legislative action by the District Governing Board. 

1.4.1.4 RACT Guidance from EPA Region IX 

A letter from EPA, Region IX6

 outlined documents that could be useful in establishing 

RACT. Those documents include EPA’s Control Techniques Guidelines (CTGs), 

Alternative Control Techniques (ACTs), New Source Performance Standards (NSPS), 

National Emissions Standards for Hazardous Air Pollutants (NESHAPs), EPA Best 

Available Control Technology (BACT) Clearinghouse, California Suggested Control 

Measures (SCM) and RACT/Best Available Retrofit Control Technology (BARCT) 

determinations, regulations adopted in other Districts, and guidance and rules 

developed by other state and local agencies. 

1.4.1.5 Issues Regarding Federal Expectations for RACT 

RACT is inherently a “moving target.” Technology considered to meet RACT at the time 

of SIP-approval is generally rendered obsolete by more effective technology that is 

introduced at a later date. This view of moving-target RACT requirements precludes 

comparing District rules only to CTGs/ACTs or simply relying on EPA SIP-approval of 

rules as satisfying RACT requirements; therefore, other adopted air pollution control 

requirements, such as other districts’ rules, must be considered. 

It should also be noted that since District rules usually fulfill BARCT requirements for 

state purposes, and the control technology established by a BARCT rule is by definition 

the most effective retrofit control for the source category; it can be assumed to, at a 

minimum, satisfy RACT requirements, if not go beyond RACT. 

1.4.2 RACT Demonstration Process 

The preparation of this report required intensive effort by numerous District staff 

including engineers and specialists from the Planning and Permit Services 

Departments. The analysis required careful and wide-ranging examination of individual 

rules against multiple federal rules, regulations, and technology guidelines as well as 

evaluating District rules against comparable rules from California’s most technologically 

progressive air districts. 

The process began by comparing District rules to EPA’s CTGs. There are a total of 42 

CTGs, twelve of which were promulgated by EPA after the original August 17, 2006 

RACT SIP analysis was adopted. Chapter 2 of this report links the EPA-promulgated 

CTGs with the District rules that cover the same source category,and discusses two 

CTGs that have no applicable facilities in the SJVAB. 

 

6

 United States Environmental Protection Agency – letter from Andrew Steckel, EPA Region IX to Kurt Karperos, ARB 

dated March 9, 2006 – RACT SIP 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 1: Overview 

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1-9 

The next part of the process was to identify the major sources of NOx and VOCs in the 

SJVAB. For this demonstration, District staff began with the federal Clean Air Act 

definition of major source. In the Clean Air Act, what constitutes a major source 

depends on the nonattainment classification of the area where the source is located. 

With its 2007 Ozone Plan, the District has requested that its nonattainment classification 

be changed to extreme nonattainment, meaning that the definition of major source for 

NOx or VOC is one that has the potential to emit of at least 10 tons per year. The 

connection between the SJVAB’s major sources and applicable District rules is outlined 

in Chapter 3 of this report The District’s database of current Permits-to-Operate was 

queried to find those sources that have the potential to emit at least ten tons per year of 

either NOx or VOC. Chapter 3 contains a list of all of the facilities that have the 

potential to emit of at least ten tons per year of either NOx or VOCand the NOx and 

VOC rules to which the facility’s equipment is subject. 

Finally, in Chapter 4 are RACT evaluations of current District rules. All of the District’s 

NOx and VOC prohibitory rules are addressed in this RACT demonstration. The rules 

were rigorously compared to federal and state regulations and guidance on emission 

controls. As agreed to by EPA staff, the rules were also compared to analogous 

regulations adopted by California’s most technologically progressive air districts: South 

Coast Air Quality Management District, Bay Area Air Quality Management District, 

Sacramento Metropolitan Air Quality Management District, and Ventura County Air 

Pollution Control District. 

1.4.3 Public Process 

In keeping with the District’s philosophy of public accountability, the results of the 

comprehensive analysis became available for public review on March 16, 2009. Public 

comments will be accepted and incorporated into the analysis as appropriate. The 

District’s Governing Board will consider this report at the April 16, 2009 meeting. The 

report will subsequently be transmitted to ARB who will then submit the report to EPA 

by May 15, 2009. EPA staff will then evaluate the submission. The demonstration 

would: 

• Fulfill a District obligation under the one-hour ozone planning requirements to show 

that District rules implement RACT; 

• Fulfill a District obligation under the eight-hour ozone planning requirements to show 

that District rules implement RACT; 

• Demonstrate the eight District rules currently in limbo at EPA implement RACT; and 

• Stop the two sanction clocks started by the EPA’s finding of “failure to submit”. 

1.5 GLOSSARY 

The following terms are used in discussion of the control measure and technology 

requirements in this report: 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

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RACT Demonstration for Ozone SIP 

1-10 

3⁄4 Best Available Control Technology (BACT): The most up-to-date methods, 

systems, techniques, and production processes available to achieve the greatest 

feasible emission reductions for given regulated air pollutants and processes. 

Federal BACT is a requirement of New Source Review (NSR) and Prevention of 

Significant Deterioration (PSD). 

3⁄4 Best Available Retrofit Control Technology (BARCT): A California emission 

standard that applies to existing sources and is based on the maximum degree of 

reduction achievable, taking into account environmental, energy, and economic 

impacts by each class or category of source (California Health and Safety Code 

(CH&SC) Section 40406). 

3⁄4 Reasonably Available Control Technology (RACT): Devices, systems, process 

modifications, or other apparatus or techniques that are reasonably available, 

taking into account the necessity of imposing such controls in order to attain and 

maintain a national ambient air quality standard; the social, environmental, and 

economic impact of such controls; and alternative means of providing for 

attainment and maintenance of such a standard. These control techniques, 

which are defined in EPA guidelines for limiting emissions from existing sources 

in nonattainment areas, are adopted and implemented for nonattainment areas 

by state analysis. 
RACT Demonstration for Ozone SIP

Chapter 2 

 

CONTROL TECHNIQUES GUIDANCE 

(CTG) SOURCE CATEGORIES AND APPLICABLE 

DISTRICT RULES 
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Chapter 2: CTG Source Categories and Applicable District Rules 

RACT Demonstration for Ozone SIP 

2-1 

Chapter 2: CTG Source Categories and 

Applicable District Rules

2.1 DISTRICT IMPLEMENTATION OF EPA CTGS 

As a part of its RACT SIP analysis, the District is required to assure that EPA’s CTGs 

are being appropriately implemented though District regulations, . For this part of the 

analysis, staff matched the list of CTGs to District rules that apply to CTG source 

categories. 

2.1.1 CTG Sources 

There are a total of 42 CTGs, twelve of which have been promulgated by EPA after the 

original August 17, 2006 RACT SIP analysis was adopted. For this demonstration, 

District staff reviewed District rules for matching CTG source categories, and then 

compared the rule requirements to the CTG recommendations. The demonstration that 

District rules implement CTGs is part of Chapter 4. 

Table 2-1 shows the CTGs promulgated by the EPA to-date, and the corresponding 

District rules. 
San Joaquin Valley Unified Air Pollution Control District 

Chapter 2: CTG Source Categories and Ap

RACT Demon

2-2 

Table 2-1: Control Techniques Guidelines 

Description Pollutant EPA Report Date 

Design Criteria for Stage I Vapor Control Systems – Gasoline Service Stations VOC EPA-450/R-75-102 1975/11 4622 Control of Volatile Organic Emissions from Existing Stationary Sources – Volume I: Control Methods for Surface Coating Operations VOC EPA-450/2-76-028 1976/11 

Note – Awith the reasonsnot definsource. control t

Control of Volatile Organic Emissions from Existing Stationary Sources – Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks 

VOC EPA-450/2-77-008 1977/05 4602, 46

Control of Volatile Organic Emissions from Solvent Metal Cleaning VOC EPA-450/2-77-022 1977/11 4662 Control of Refinery Vacuum Producing Systems, Wastewater Separators, and Process Unit Turnarounds VOC EPA-450/2-77-025 1977/10 4453, 44Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals VOC EPA-450/2-77-026 1977/10 4621, 462Control of Volatile Organic Emissions from Existing Stationary Sources – Volume III: Surface Coating of Metal Furniture VOC EPA-450/2-77-032 1977/12 4603 Control of Volatile Organic Emissions from Existing Stationary Sources – Volume IV: Surface Coating of Insulation of Magnet Wire VOC EPA-450/2-77-033 1977/12 4605 Control of Volatile Organic Emissions from Existing Stationary Sources – Volume V: Surface Coating of Large Appliances VOC EPA-450/2-77-034 1977/12 4603 Control of Volatile Organic Emissions from Bulk Gasoline Plants VOC EPA-450/2-77-035 1977/12 4621 Control of Volatile Organic Emissions from Storage of Petroleum Liquids in Fixed-Roof Tanks VOC EPA-450/2-77-036 1977/12 4623 Control of Volatile Organic Emissions from Use of Cutback Asphalt VOC EPA-450/2-77-037 1977/12 4641 Control Techniques for Volatile Organic Emissions from Stationary Sources VOC EPA-450/2-78-022 1978/05 

Note – Tlisted wnot definparticula

Control of Volatile Organic Emissions from Existing Stationary Sources – Volume VI: Surface Coating of Miscellaneous Metal Parts and Products VOC EPA-450/2-78-015 1978/06 4603 Control of Volatile Organic Emissions from Existing Stationary Sources – Volume VII: Factory Surface Coating of Flat Wood Paneling VOC EPA-450/2-78-032 1978/06 4606 Control of Volatile Organic Compound Leaks from Petroleum Refinery Equipment VOC EPA-450/2-78-036 1978/06 4453, 44
San Joaquin Valley Unified Air Pollution Control District 

Chapter 2: CTG Source Categories and Ap

RACT Demon

2-3 

Table 2-1: Control Techniques Guidelines 

Description Pollutant EPA Report Date 

Control of Volatile Organic Emissions from Manufacture of Synthesized Pharmaceutical Products VOC EPA-450/2-78-029 1978/12 Negative Control of Volatile Organic Emissions from Manufacture of Pneumatic Rubber Tires VOC EPA-450/2-78-030 1978/12 4681 Control of Volatile Organic Emissions from Existing Stationary Sources – Volume VIII: Graphic Arts-Rotogravure and Flexography VOC EPA-450/2-78-033 1978/12 4607 Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating Roof Tanks VOC EPA-450/2-78-047 1978/12 4623 Control of Volatile Organic Compound Leaks from Gasoline Tank Trucks and 

Vapor Collection Systems VOC EPA-450/2-78-051 1978/12 4621 

Control of Volatile Organic Compound Emissions from Large Petroleum Dry Cleaners VOC EPA-450/3-82-009 1982/09 4672 Control of Volatile Organic Compound Emissions from Manufacture of HighDensity Polyethylene, Polypropylene, and Polystyrene Resins VOC EPA-450/3-83-008 1983/11 4682, 46Control of Volatile Organic Compound Equipment Leaks from Natural Gas/Gasoline Processing Plants VOC EPA-450/3-83-007 1983/12 4409, 44Control of Volatile Organic Compound Leaks from Synthetic Organic Chemical Polymer and Resin Manufacturing Equipment VOC EPA-450/3-83-006 1984/03 4682, 46Control of Volatile Organic Compound Emissions from Air Oxidation Processes in Synthetic Organic Chemical Manufacturing Industry VOC EPA-450/3-84-015 1984/12 4455 Control of Volatile Organic Compound Emissions from Reactor Processes and Distillation Operations in Synthetic Organic Chemical Manufacturing Industry VOC EPA-450/4-91-031 1993/08 4455 Control of Volatile Organic Compound Emissions from Wood Furniture Manufacturing Operations VOC EPA-453/R-96-007 1996/04 4606 Control Techniques Guidelines for Shipbuilding and Ship Repair Operations (Surface Coating) VOC 61 FR-44050 1996/08 Negative Aerospace (CTG & MACT) VOC EPA-453/R-97-004 1997/12 4605 Control Techniques Guidelines for Industrial Cleaning Solvents VOC EPA-453/R-06-001 2006/09 

4601, 464663, 46mfg) 

Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing VOC EPA-453/R-06-002 2006/09 4607 Control Techniques Guidelines for Flexible Package Printing VOC EPA-453/R-06-003 2006/09 4607 Control Techniques Guidelines for Flat Wood Paneling Coatings VOC EPA-453/R-06-004 2006/09 4606 Control Techniques Guidelines for Paper, Film, and Foil Coatings VOC EPA 453/R-07-003 2007/09 4607 
San Joaquin Valley Unified Air Pollution Control District 

Chapter 2: CTG Source Categories and Ap

RACT Demon

2-4 

Table 2-1: Control Techniques Guidelines 

Description Pollutant EPA Report Date 

Control Techniques Guidelines for Large Appliance Coatings VOC EPA 453/R-07-004 2007/09 4603 Control Techniques Guidelines for Metal Furniture Coatings VOC EPA 453/R-07-005 2007/09 4603 Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings VOC EPA 453/R-08-003 2008/09 4603 Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials VOC EPA 453/R-08-004 2008/09 4684 Control Techniques Guidelines for Miscellaneous Industrial Adhesives VOC EPA 453/R-08-005 2008/09 4653 Control Techniques Guidelines for Automobile and Light-Duty Truck Assembly Coatings VOC EPA 453/R-08-006 2008/09 4612 Protocol for Determining the Daily Volatile Organic Compound Emission Rate of Automobile and Light-Duty Truck Primer-Surfacer and Topcoat Operations VOC EPA 453/R-08-002 2008/09 

Not applirecommepractices 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 2: CTG Source Categories and Applicable District Rules 

RACT Demonstration for Ozone SIP 

2-5 

2.1.2 CTGs Without Subject Facilities 

If there are no facilities within the District’s boundaries that are subject to a particular 

CTG, the District Governing Board has two options. The first option is to create and 

implement a RACT rule for the CTG source category, even though there would be no 

source subject to the rule. The second option requires the District’s Governing Board to 

approve a negative declaration as a signed, Governing Board resolution, stating that 

there are no major sources and no minor sources that would be subject to a given CTG. 

As required by the implementation rule for the eight-hour NAAQS, District staff reviewed 

all of the CTGs and found two CTGs without applicable facilities in the SJVAB: 

• Surface coating at shipbuilding and ship repair facilities 

• Pharmaceutical manufacturing 

In its August 2006 RACT SIP analysis, District staff investigated whether major or minor 

sources that could be subject to these CTGs existed within the District’s boundaries. If 

District staff had found sources, the District would have had to adopt and implement 

prohibitory rules for these sources. At that time, District staff found no sources that 

could be subject to the CTGs listed above and prepared a negative declaration in the 

form of a Governing Board resolution. With this submission, District staff has reevaluated whether there are major or minor sources subject to these CTGs within the 

District’s boundaries, and found that there are none. Therefore, District staff is 

recommending that the Governing Board re-affirm the August 2006 negative declaration 

for these source categories with another signed resolution. 

2.1.2.1 Surface Coating Operations at Ship-Building and Ship Repair Facilities 

(61 FR-44050) 

The only port in the SJVAB large enough to support a shipbuilding or ship repair facility 

for vessels 20 meters or more in length is the Port of Stockton. Located on the Stockton 

Deepwater Ship Channel, 75 nautical miles due east of the Golden Gate Bridge, the 

Port of Stockton, California, owns and operates a diversified and major transportation 

center that encompasses a 2,000-acre operating area. The Port is one mile from 

Interstate 5, and all interconnecting major highway systems. Rail service is provided by 

two transcontinental railroads, Union Pacific and the Burlington Northern Santa Fe. 

The Port has berthing space for 17 vessels. There is no width restriction of vessels, 

and ships up to 900 feet (275 meters) in length can navigate the Stockton Ship 

Channel. Vessels in the 45,000 to 55,000-ton class, and maximum 60,000-ton class 

(for certain wide-beam vessels) can use the channel fully loaded. Up to 80,000-ton 

class vessels can transit the channel partially loaded. The Port has first class 

warehouse storage and handling facilities for both dry and liquid bulk materials, facilities 

and equipment to handle break-bulk and containerized cargoes by land or by sea. 

Immediate access to two transcontinental railroads is complemented by two loop 

railroads, one on-dock, for accommodating unit trains for export of coal, petroleum coke, 

and ores, plus consolidation of rail shipments of inbound and outbound steel coils. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 2: CTG Source Categories and Applicable District Rules 

RACT Demonstration for Ozone SIP 

2-6 

All of the Port's services are directed through one administrative complex. The Port of 

Stockton publishes tariffs, stevedores cargoes, assigns berths, supervises cargo 

activity, provides shipping documentation, accounting and rate quotations. It is a broad 

hands-on effort that includes marketing, traffic, property management, warehousing, 

distribution, data processing and police protection services to its customers. (Reference 

1) 

Although the Port of Stockton that can handle large marine vessels, the Port has no 

surface coating operations associated with shipbuilding or ship repair. A survey of the 

District’s emissions inventory found minor amounts of marine coatings. However, 

further analysis determined that these emissions were associated with the surface 

coating of pleasure craft, a different source category than shipbuilding or ship repair. 

District staff assigned to inspect various operations at the Port of Stockton reported that 

there were no coatings operations related to shipbuilding or ship repair within the port. 

The management at the Port of Stockton has verbally re-confirmed this fact. On this 

basis, District staff recommends that the District Governing Board declare that there are 

no major or minor sources for surface coating operations at shipbuilding and ship repair 

facilities. 

2.1.2.2. Pharmaceutical Manufacturing Operations (EPA-450/2-78-029) 

The pharmaceutical industry includes the manufacture, extraction, processing, 

purification, and packaging of chemical materials to be used as medication for humans 

or animals. Pharmaceutical manufacturing is divided into two major processing stages, 

primary and secondary. Primary processing or manufacture is the production of the 

active ingredient or drug. Secondary processing is the conversion of the active drugs 

into products suitable for administration. Major pharmaceutical groups manufactured 

include: 

• prescription-only medicines (POM), which usually are patented products; 

• standard prescription-only medicines made to a recognized formula, which may 

be specified in standard industry reference books; and 

• over-the-counter (OTC) or non-prescription products. 

The principal manufacturing steps are: (a) preparation of process intermediates; (b) 

introduction of functional groups; (c) coupling and esterification; (d) separation 

processes (such as washing and stripping); and (e) purification of the final product. In 

addition, other product preparation steps include granulation; drying; tablet pressing, 

printing, and coating; filling; and packaging. Each of these steps may generate air 

emissions, liquid effluents, and solid wastes. (Reference 2) 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 2: CTG Source Categories and Applicable District Rules 

RACT Demonstration for Ozone SIP 

2-7 

District staff searched for pharmaceutical manufacturing within the District by looking for 

VOC emissions in emission inventory code (EIC) 410-995-5520-000 in the District’s 

emission inventory. This EIC is used specifically for emissions from pharmaceutical 

manufacturers. There were no emissions in this EIC. A search of the Districts permits 

database found that there are no facilities for any of the standard industrial codes (SICs) 

associated with pharmaceutical manufacturing, namely SICs in the range of 2830 

through 2839. An Internet search for pharmaceutical manufacturers in the San Joaquin 

Valley yielded no results. Therefore, District staff concludes that there are no 

pharmaceutical manufacturers in the District and recommends that District Governing 

Board declare that there are no major or minor sources for pharmaceutical 

manufacturing within the SJVAB. 

2.1.2.3 References 

1. Port of Stockton website - http://www.portofstockton.com 

2. “Environmental Guidelines for Pharmaceutical Manufacturing” Multilateral 

Investment Guarantee Agency; Fruit and Vegetable Processing. January 31, 

1996. http://www.miga.org/miga_documents/PharmaceuticalManufacturing.pdf 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 2: CTG Source Categories and Applicable District Rules 

RACT Demonstration for Ozone SIP 

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Chapter 3 

 

MAJOR SOURCES AND APPLICABLE RACT RULES 
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San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 3: Major Sources and Applicable RACT Rules 

RACT Demonstration for Ozone SIP 

3-1 

Chapter 3: Major Sources 

and Applicable RACT Rules

3.1 MAJOR SOURCE LISTING 

As discussed in Chapter 2, the District is required to evaluate the rules that apply to 

major sources. Staff began by querying the District’s database of current Permits to 

Operate to identify the facilities that have the potential to emit at least ten tons per year 

of either NOx or VOC. The individual facilities are listed in Table 3-1, along with the 

NOx and VOC rules that apply to the facility’s equipment. 

Two clarifications should be noted in Table 3-1. 

• First, several facilities shown in Table 3-1 will become subject to VOC rules that 

the District is currently developing. These facilities are identified with a mark in 

the column titled “New.” For example, the District is currently developing Rule 

4566 (Organic Waste Operations) and Rule 4694 (Brandy and Wine Aging 

Operations). These are the first rules of their kind anywhere (no other agency 

has an existing rule), and EPA has not promulgated a CTG for the category. 

When the District rule is adopted, it will in essence, establish RACT nationwide 

for those source categories. 

• Second, in Table 3-1, there are several facilities where the units or processes are 

so small (or have such low throughputs), that the units are exempt from the 

District’s prohibitory rule. These facilities are marked with an “o” instead of an “x” 

for a specific rule. It should be emphasized that a facility’s exemption from a rule 

does not signify that the rule does not meet RACT. The District goes through a 

methodical and reasoned process as it develops the emission limits and 

applicability thresholds for its prohibitory rules, with input from EPA and 

stakeholders from numerous and diverse groups. Chapter 4 demonstrates how 

District rules meet or exceed RACT requirements, including exemption 

thresholds. 
San Joaquin Valley Unified Air Pollution Control District 

 Region

 ID # Facility Name Facility Description 4103

 4104

 4106

 4301

 4306

 4307

 4308

 4309

 4311

 4313

 4352

 4354

 4401

 4402

 4404

 4407

 4408

 4409

 4453

 4454

 4455

 4565

 4570

 4601

 4602

 4603

 4604

 4605

 4606

 4607

 4610

 4612

 4621

 4622

 4623

 4624

 4625

 4641

 4642

 4651

 4652

 4653

4661

C 14 FRESNO COGENERATION PARTNERS COGENERATION x x C 17 ALBRECHT FARMS AGRICULTURAL PRODUCTS PROCESSING oC 26 ALTA OIL COMPANY BULK PLANT xC 36 PACTIV CORPORATION PLASTIC FOAM PRODUCTS x x C 72 BAKER COMMODITIES, INC. RENDERING x x x x xC 73 BALTIMORE AIRCOIL OF CAL AIR CONDITIONING AND HEATING EQUIPMENT MFR xC 120 THE WINE GROUP, INC. WINERY xC 149 BROADVIEW COOP GIN COTTON GINNING oC 150 NEWBY ISLAND LANDFILL MUNICIPAL WASTE LANDFILL xC 194 WOOLF ENTERPRISES AGRICULTURAL CROP PRODUCTION xx C 195 CALIF STATE PRISON - AVENAL CORRECTIONAL INSTITUTION x x x x x x x x C 214 CALIF STATE PRISON - CORCORAN CORRECTIONAL INSTITUTION x x x xx C 218 CALIFORNIA ARMY NATIONAL GUARD MILITARY INSTALLATION xC 246 HUBBELL LENOIR CITY INC POLYMER CONCRETE/FIBERGLASS MANUFACTURING xx C 261 CERTAINTEED CORPORATION FIBERGLASS MANUFACTURING OPERATION x x C 264 EXOPACK LLC COMMERCIAL PRINTING x xC 282 GUTHRIE PETROLEUM INC BULK PLANT x xC 283 CHEMICAL WASTE MANAGEMENT, INC WASTE DISPOSAL x xx x C 306 CHEVRON PIPELINE CO -TANK FARM CRUDE PETROLEUM PIPELINES x xC 311 CHEVRON USA INC OIL PRODUCTION x x x x x x x C 336 GENERAL PETROLEUM DBA BRYANT PETROLEUM BULK PLANT x xC 343 CLOVIS UNIFIED SCHOOL DISTRICT ELEMENTARY AND SECONDARY SCHOOLS xx x xx C 354 COALINGA COGENERATION CO ELECTRIC AND OTHER SERVICES COMBINED x C 366 DEL MONTE CORPORATION AGRICULTURAL PRODUCTS PROCESSING x x C 393 SILVAS OIL COMPANY, INC. BULK PLANT x xC 402 CALIFORNIA DAIRIES, INC. MILK PROCESSING PLANT x C 406 DARLING INTERNATIONAL INC. RENDERING PLANT xC 443 DUREY LIBBY EDIBLE NUTS INC AGRICULTURAL PRODUCTS PROCESSING DEHYDRATING xC 447 E & J GALLO WINERY WINERY x x x x x x x C 495 FLORESTONE PRODUCTS CO, INC PLASTICS PLUMBING FIXTURE MANUFACTURING xx C 497 JOHN BEAN TECHNOLOGIES CORPORATION FOOD PROCESSING EQUIPMENT MANUFACTURING x x C 528 FRESNO AREA EXPRESS BUS LINE OPERATION x 

C 535 FRESNO/CLOVIS REGIONAL WWTP WASTEWATER RECLAMATION FACILITY x x x x C 540 FRESNO COMMUNITY HOSPITAL HOSPITAL x C 568 GEORGIA-PACIFIC CORRUGATED LLC C0RRUGATED AND SOLID FIBER BOXES x xx x C 581 GOLDEN STATE VINTNERS WINERY xx C 591 GRAYLIFT, INC. EQUIPMENT RENTAL xC 597 GRUNDFOS PUMPS CORPORATION PUMP MANUFACTURING x C 598 GUARDIAN INDUSTRIES CORP GLASS MANUFACTURING x x C 603 HANFORD L P ELECTRICAL GENERATION x x xC 628 C W US INC DBA MISSION BELL WINERY WINERY x x x C 629 O'NEILL BEVERAGES CO LLC WINERY x C 646 CON AGRA FOODS AGRICULTURAL PRODUCTS PROCESSING xC 650 CALMAT CO. ASPHALT PAVING MIXTURES xC 651 CALMAT CO. ASPHALT PAVING MIXTURES xC 652 CALMAT CO. ASPHALT PAVING MIXTURES xC 705 J R SIMPLOT COMPANY FERTILIZER PRODUCTION x x x x xC 713 KEENAN FARMS INC AGRICULTURAL PRODUCTS PROCESSING, PISTACHIOS xC 722 KINGSBURG COGEN FACILITY COGENERATION x x x x C 724 KINGS COUNTY PUBLIC WORKS DEPT GOVERNMENTAL AGENCY xx C 741 LAMANUZZI & PANTALEO AGRICULTURAL PRODUCTS PROCESSING xC 782 LIFTCO CAPS SANDBLASTING METAL PARTS AND PRODUCTS COATING C 790 CAVALLETTO RANCHES AGRICULTURAL PRODUCTS PROCESSING - ALMONDS xC 799 MADERA POWER, LLC POWER GENERATION x x xC 801 SAINT-GOBAIN CONTAINERS, INC GLASS MANUFACTURING x x x C 825 COVANTA MENDOTA LP POWER GENERATION x x x x x C 847 MODERN WELDING STEEL STORAGE TANK FABRICATION x x 

C 898 PACIFIC BELL TELEPHONE CO (DBA AT&T CA) TELECOMMUNICATIONS C 904 PACIFIC GAS & ELECTRIC CO PUBLIC UTILITY x C 948 PPG INDUSTRIES GLASS MANUFACTURING x xC 954 PRISON INDUSTRY AUTHORITY-AVENAL CORRECTIONAL INSTITUTION xx x 

C 986 QUINN COMPANY INDUSTRIAL EQUIPMENT SALES x xx C 996 EARTHGRAINS BAKING COMPANIES INC BAKERY x C 999 VAN DE POL ENT INC DBA RATHAMANN OIL CO BULK PLANT x x

C 1027 R L VERNON BULK PLANT x xC 1037 ROE OIL COMPANY BULK PLANT x xC 1042 BATTH DEHYDRATOR LLC AGRICULTURAL PRODUCTS PROCESSING - DEHYDRATING oC 1046 GUTHRIE PETROLEUM INC BULK PLANT xC 1059 SAINT AGNES MEDICAL CENTER HOSPITAL x C 1066 J G BOSWELL COMPANY COTTON GINNING oC 1069 RAGHBIR S BATTH DBA SANGER DEHYDRATOR AGRICULTURAL PRODUCTS PROCESSING xC 1074 SANGER BOATS, INC. BOAT MANUFACTURING x xC 1077 SFPP, L.P. PETROLEUM TRANSPORTATION x x xx C 1089 SEALED AIR CORPORATION PLASTIC FOAM PRODUCTS MANUFACTURING C 1121 AERA ENERGY LLC PETROLEUM PRODUCTION x x x x x x C 1163 SK FOODS INC AG PRODUCTS PROCESSING - FRUITS/VEGETABLES x x C 1179 SPRECKELS SUGAR COMPANY BEET SUGAR MANUFACTURING x x x x x x x xC 1203 SURABIAN PACKING COMPANY, INC. AGRICULTURAL PRODUCTS PREPARATIONC 1234 SHELL PIPELINE COMPANY LP PETROLEUM TRANSPORTATION x x x x C 1243 TOMA-TEK INC TOMATO PROCESSING xC 1244 GENERAL PETROLEUM BULK PLANT x xC 1259 MODERN CUSTOM FABRICATION, INC METAL FABRICATION x xx C 1301 CONOCOPHILLIPS PIPE LINE COMPANY PETROLEUM PIPELINES x 

Table 3-1: Major Sources and Applicable RACT Rules

 3-2

Chapter 3: Major S
San Joaquin Valley Unified Air Pollution Control District 

 Region

 ID # Facility Name Facility Description 4103

 4104

 4106

 4301

 4306

 4307

 4308

 4309

 4311

 4313

 4352

 4354

 4401

 4402

 4404

 4407

 4408

 4409

 4453

 4454

 4455

 4565

 4570

 4601

 4602

 4603

 4604

 4605

 4606

 4607

 4610

 4612

 4621

 4622

 4623

 4624

 4625

 4641

 4642

 4651

 4652

 4653

4661

Table 3-1: Major Sources and Applicable RACT Rules

C 1306 US ARMY CORPS/PINE FLAT HDQTR RECREATIONAL PROGRAM ADMINISTRATION - GOV xx C 1326 VALLEY FIG GROWERS AGRICULTURAL PRODUCTS PROCESSING - DEHYDRATING xC 1336 VA MEDICAL CENTER HOSPITALS x C 1344 VIE-DEL WINERY #1 AGRICULTURAL PRODUCTS PROCESSING, WINERY x C 1353 THE WINE GROUP LLC DBA ALMADEN-MADERA WINERY x x x C 1355 V/M CUSTOM BOAT TRAILERS TRANSPORTATION EQUIPMENT MANUFACTURING xC 1356 VOGEL FRAME CO INC WOOD PRODUCTS xC 1361 WASCO HARDFACING METALS PARTS & PRODUCTS COATING xC 1371 WESTERN STAR SANDBLASTING CO. NONCLASSIFIABLE ESTABLISHMENTS C 1383 WESTSIDE FARMERS COOP #2 & #3 COTTON GINNING oC 1385 ANDERSON CLAYTON CORP/SILVER C COTTON GINNING oC 1387 WEST HILLS OIL, INC. BULK PLANT WITH GASOLINE DISPENSING x xC 1396 INTERNATIONAL PAPER COMPANY CORRUGATED CARDBOARD BOX MANUFACTURER x xxC 1555 J G BOSWELL COMPANY AGRICULTURAL PRODUCTS PROCESSING x x x x C 1562 WESTERN WASTE INDUSTRIES REFUSE TRANSPORTING xC 1594 DEL MONTE CORPORATION AG PRODUCTS PROCESSING - FRUITS/VEGETABLES x C 1658 EXARO ENERGY LLC OIL AND GAS PRODUCTION xC 1683 HOLMES WESTERN OIL CORPORATION PETROLEUM PRODUCTION x C 1694 SUNSWEET DRYERS AGRICULTURAL PRODUCTS PROCESSING - DEHYDRATING oC 1713 J W MYERS, INCORPORATED BULK PLANT WITH GASOLINE DISPENSING xC 1820 RIO BRAVO FRESNO ELECTRICAL SERVICES COGENERATION x x x xC 1854 C CASE COMPANY OIL AND GAS PRODUCTION x C 2012 STEEL STRUCTURES INC METAL FABRICATION x xxC 2041 VALLEY GRAIN/AZTECA MILLING AGRICULTURAL PRODUCTS PROCESSING xC 2106 NAS LEMOORE/ PUBLIC WORKS MILITARY BASE xxx xx C 2249 SAMSON RESOURCES COMPANY OIL AND GAS PRODUCTION xC 2253 SILGAN CONTAINERS MANUFAC CORP CAN COATING xC 2265 GARY V. BURROWS INC. BULK PLANT x xC 2272 OLSON & COMPANY STEEL METAL FABRICATION x xxC 2283 CALIF STATE PRISON- CHOWCHILLA CORRECTIONAL INSTITUTION x xx C 2341 NAS LEMOORE MILITARY INSTALLATION x x xx xx C 2349 CLOVIS-SANGER CABINET MFG WOOD PRODUCTS xC 2444 ITO PACKING COMPANY INC AG PRODUCTS PROCESSING - FRUITS/VEGETABLES C 2471 STURDY SAFE METAL PARTS & PRODUCTS COATING xC 2646 PB LOADER CORPORATION FARM MACHINERY AND EQUIPMENT xC 2675 WHOLESALE EQUIPMENT OF FRESNO MOBILE EQUIPMENT COATING xC 2696 CALAVERAS MATERIALS INC ASPHALT PAVING MIXTURES xC 2709 PACIFIC PRINTING COMMERCIAL PRINTING, LITHOGRAPHIC x xC 2852 TRI BORO FRUIT CO INC CROP PREPARATION SERVICE oC 2872 CHEVRON USA, INC. OIL AND GAS PRODUCTION xC 2883 COUNTY OF KINGS GOVERNMENT SERVICES C 2885 CHEVRON USA, INC. NATURAL GAS PRODUCTION x x C 2902 CHILDRENS HOSPITAL OF CENTRAL CALIFORNIA HOSPITAL x C 2908 SALWASSER INC AGRICULTURAL PRODUCTS PROCESSINGC 2913 MADERA COUNTY RESOURCE MGMT AGENCY WASTE DISPOSAL x C 3062 ANDERSON PUMP CO, INC INDUSTRIAL EQUIPMENT SALES - PUMPS C 3071 WARMERDAM PACKING AGRICULTURAL PRODUCTS PROCESSING - FRUITS C 3115 COUNTY OF FRESNO PUBLIC WORKS LANDFILL (EG SOURCE) x xC 3375 TRI-COUNTIES WALNUT CO AGRICULTURAL PRODUCTS PROCESSING xC 3402 JCW CO. WOOD KITCHEN CABINETS x xC 3549 INTERIOR SERVICES AND DESIGN METAL PARTS AND PRODUCTS COATING xC 3591 WESTERN MANUFACTURING CORP. METAL PARTS AND PRODUCTS COATING xC 3649 CHIN-CHING HSU DBA POLYCELL PACKAGING PLASTICS, FOAM PRODUCTS MANUFACTURING C 3775 CALIFORNIA POWER HOLDINGS LLC POWER GENERATION C 3811 CAL PEAK POWER, LLC POWER GENERATION x C 3839 AVENAL REGIONAL LANDFILL LANDFILL (EG SOURCE) xC 3843 WELLHEAD POWER LLC POWER GENERATION x 

C 3844 WELLHEAD POWER PANOCHE, LLC. POWER GENERATION C 3929 GWF ENERGY LLC - HENRIETTA ELECTRICAL GENERATION x 

C 3955 LEPRINO FOODS COMPANY CHEESE PRODUCTION x x C 4051 COALINGA STATE HOSPITAL HOSPITAL x xx C 4140 GWF ENERGY LLC POWER GENERATION x C 4261 PACIFIC ETHANOL MADERA LLC INDUSTRIAL ORGANIC CHEMICALS x x x C 4305 KINGS RIVER CONSERVATION DISTRICT POWER GENERATION C 4352 CSATF/CA SUBSTANCE ABUSE TREATMENT FACIL CALIFORNIA SUBSTANCE ABUSE TREATMENT FACILITY x xx xx xx C 4998 TERRANOVA RANCH INC AGRICULTURAL CROP PRODUCTION x xC 5097 MANZANILLO RANCH AGRICULTURAL CROP PRODUCTION C 5163 DLM PARTNERS AGRICULTURAL CROP PRODUCTION x xC 5166 HARRIS FARMS INC AGRICULTURAL CROP PRODUCTION C 5169 MOUREN FAMILY FARMS, INC AGRICULTURAL CROP PRODUCTION C 5191 CENTRAL GREEN COMPANY AGRICULTURAL CROP PRODUCTION x xC 5202 LOUIS D CAVALLETTO DBA CAVALLETTO RANCH AGRICULTURAL CROP PRODUCTION xx C 5218 ZONNEVELD FARMS #1 AGRICULTURAL CROP PRODUCTION xx C 5225 CMA GENERAL PARTNERSHIP AGRICULTURAL CROP PRODUCTION C 5226 SHEIN RANCH AGRICULTURAL CROP PRODUCTION, DAIRY x 

C 5289 DIAMOND H DAIRY DAIRY FARM x xx C 5318 DON HEADRICK AGRICULTURAL CROP PRODUCTION x xC 5326 KANWARJIT & GAGANDIP BATTH FARMS AGRICULTURAL CROP PRODUCTION xx C 5356 JOHN VISSER DAIRY AGRICULTURAL CROP PRODUCTION, DAIRY x xxC 5370 LOVELACE & SONS FARMING AGRICULTURAL CROP PRODUCTION xx C 5417 VLOT BROTHERS DAIRY & HEIFER RANCH AGRICULTURAL CROP PRODUCTION, DAIRY,FEEDLOT x xC 5427 DAVID TEVELDE DAIRY AGRICULTURAL CROP PRODUCTION, DAIRY x xxC 5469 JOHANN DAIRY DAIRY FARM xx 

 3-3

Chapter 3: Major S
San Joaquin Valley Unified Air Pollution Control District 

 Region

 ID # Facility Name Facility Description 4103

 4104

 4106

 4301

 4306

 4307

 4308

 4309

 4311

 4313

 4352

 4354

 4401

 4402

 4404

 4407

 4408

 4409

 4453

 4454

 4455

 4565

 4570

 4601

 4602

 4603

 4604

 4605

 4606

 4607

 4610

 4612

 4621

 4622

 4623

 4624

 4625

 4641

 4642

 4651

 4652

 4653

4661

Table 3-1: Major Sources and Applicable RACT Rules

C 5472 JESSE SILVA DAIRY AGRICULTURAL CROP PRODUCTION, DAIRY C 5513 FRED RAU DAIRY INC AGRICULTURAL CROP PRODUCTION C 5524 RIVER RANCH DAIRY AGRICULTURAL CROP PRODUCTION, DAIRY x xx C 5613 CHARANJIT S BATTH AGRICULTURAL CROP PRODUCTION xx C 5658 OPC EQUIPMENT COMPANY, INC AGRICULTURAL CROP PRODUCTION C 5715 VINTAGE DAIRY AGRICULTURAL CROP PRODUCTION, DAIRY x 

C 5749 J G BOSWELL (HOMELAND RANCH SOURCE) AGRICULTURAL CROP PRODUCTION C 5858 AVILA FAMILY DAIRY LLC DAIRY FARMS C 6029 FERNANDES DAIRY DAIRY FARM xx C 6046 MARTIN RANCH DAIRY LLC DAIRY FARM C 6047 TURNER RANCH FAMILY DAIRY DAIRY FARM C 6426 F & B RANCHES AG OPERATION C 6529 HIGARD FARMS LLC VEGETABLES AND MELONS C 6537 BORBA BROTHERS FARMS AG OPERATION C 6894 LEMSTRA CATTLE COMPANY, LLC DAIRY C 6927 MADDOX FARMS AGRICULTURAL CROP PRODUCTION C 7020 HOLLANDIA FARMS DAIRY FARM x 

C 7021 CLOVERDALE DAIRY, LLC DAIRY FARM x 

C 7057 VALLEY VIEW FARMS DAIRY FARMS xx C 7066 WREDEN RANCH DAIRY DAIRY FARM xC 7075 PINE FLAT LAKE MARINA INC MARINA x xC 7253 HERITAGE ORCHARDS LLC FRUITS AND TREE NUTS C 7307 WHITNEY OAKS AGRICULTURAL CROP PRODUCTION, DAIRY x xx C 7310 RIVER RANCH FARMS AGRICULTURAL CROP PRODUCTION C 7656 DE GROOT DAIRY FARM (SOUTH) DAIRY FARM C 7679 JERSEYLAND FARMS AGRICULTURAL CROP PRODUCTION, DAIRY N 33 ANGKOR AUTO BODY & PAINT METAL PARTS AND PRODUCT COATING x xN 164 CALIFORNIA SPRAY DRY CO RENDERING PLANT x x xN 180 CARPENTER CO. FOAM MANUFACTURING x x x N 188 ROBERTSON CECO II CORP/STAR BLDG SYSTEMS METAL BUILDING MANUFACTURING FACILITY x xN 199 CHEVRON USA GASOLINE DISTRIBUTION x x xx N 222 COMMERCIAL BLDG COMPONENTS, INC METAL FABRICATION xN 238 CORN PRODUCTS GRAIN MILLING AND PROCESSING - WET CORN MILLING x x N 257 DART CONTAINER CORPORATION STYROFOAM CONTAINERS MANUFACTURING x x x N 266 DELICATO VINEYARDS WINERY x xx 

N 285 DIAMOND FOODS INCORPORATED AGRICULTURAL PRODUCTS PROCESSING - WALNUTS x x 

N 298 EARTHGRAINS BAKING COMPANIES INC BAKERY x N 314 H. J. HEINZ COMPANY, L.P. AG PRODUCTS PROCESSING - FRUITS/VEGETABLES x xN 339 FORWARD INC LANDFILL x xxx xN 355 GENERAL MILLS INC CEREAL MANUFACTURER x x x N 366 GRANITE CONSTRUCTION ASPHALTIC CONCRETE PRODUCTION x xN 367 GRANITE CONSTRUCTION CO AGGREGATE AND ASPHALTIC CONCRETE PRODUCTION N 408 HOLZ RUBBER COMPANY, INC SYNTHETIC RUBBER x x xN 421 TIN INC DBA TEMPLE-INLAND CORRUGATED PAPERBOARD CONTAINER MANUFACTURER x x 

N 474 LEPRINO FOODS FOOD PROCESSOR x N 477 PILKINGTON NORTH AMERICA INC FLAT GLASS MANUFACTURER x x x N 479 MONIERLIFETILE LLC CONCRETE PRODUCTS - ROOFING TILE MANUFACTURING N 493 LODI IRON WORKS, INC IRON FOUNDRY x xN 524 N.J. MCCUTCHEN, INC. METAL PARTS AND PRODUCT COATING xN 556 MONIERLIFETILE L.L.C. CONCRETE PRODUCTS - ROOFING TILE MANUFACTURING x xN 566 MUNN AND PERKINS, INC ASPHALT PAVING MIXTURES AND BLOCKS x

N 583 NORTHERN CALIFORNIA POWER AGENCY POWER GENERATION N 593 OWENS-BROCKWAY GLASS CONTAINER GLASS CONTAINER MANUFACTURER x x N 594 PACIFIC COAST PRODUCERS AGRICULTURAL PRODUCTS PROCESSING x xN 608 PG&E - CGO/ ENVRN CORD NATURAL GAS DISTRIBUTION x x xxx N 645 POSDEF POWER COMPANY, L.P. POWER GENERATION FACILITY x x x x N 672 UNILEVER SUPPLY CHAIN INC AGRICULTURAL PRODUCTS PROCESSING x x N 717 A. SAMBADO & SON, INC. AGRICULTURAL PRODUCTS PROCESSINGN 758 EQUILON ENTERPRISES LLC BULK TERMINAL x xN 767 J R SIMPLOT COMPANY FERTILIZER MANUFACTURING x x x x x x x x N 770 RIPON COGENERATION LLC COGENERATION FACILITY x x x N 802 STOCKTON COGEN COMPANY ELECTRICAL POWER PLANT x x x xN 811 STOCKTON MUNICIPAL UTIL DEPT WASTEWATER TREATMENT FACILITY x x x x N 812 THE HERRICK CORPORATION METAL FABRICATION xN 823 STOCKTON EAST WATER DISTRICT WATER TREATMENT FACILITY x xx N 829 ST SERVICES, LLC BULK FUEL STORAGE TERMINAL x xx xN 846 SHELL PIPELINE COMPANY LP PETROLEUM PIPELINES x x x xN 886 TUFF BOY, INC. TRUCK TRAILER MANUFACTURING x xN 956 THE WINE GROUP INC WINERY x x N 964 GEORGE REED INC. ASPHALTIC CONCRETE MANUFACTURING xN 994 8309 TUJUNGA AVENUE CORPORATION POWER GENERATION N 1002 LODI METAL TECH INC METAL PARTS AND PRODUCT COATING OPERATION x xN 1026 THERMAL ENERGY DEV PARTNERSHIP LP ELECTRICAL GENERATION FACILITY x x x N 1027 COLORADO ENERGY MGMT/ENVIRO COGENERATION FACILITY x N 1044 GB INDUSTRIAL SPRAY METAL PARTS AND PRODUCTS COATING x xN 1045 HUBBARD FEEDS, INC. ANIMAL FEED PROCESSING xN 1075 B&C PAINTING SOLUTIONS INC METAL PARTS AND PRODUCTS COATING OPERATION x N 1100 U S INTEC, INC. ASPHALT ROOFING PRODUCTS MANUFACTURING FACILITY x N 1119 NORTH COUNTY SANITARY LANDFILL LANDFILL x xN 1174 SUN GARDEN-GANGI CANNING CO AGRICULTURAL PRODUCTS PROCESSING xN 1237 E & J GALLO WINERY WINERY x x x x x x N 1246 FINELINE INDUSTRIES INC MANUFACTURER OF FIBERGLASS BOATS x N 1248 FOSTER POULTRY FARMS-KOPRO MANURE COMPOSTING STORAGE FACILTIY x

 3-4

Chapter 3: Major S
San Joaquin Valley Unified Air Pollution Control District 

 Region

 ID # Facility Name Facility Description 4103

 4104

 4106

 4301

 4306

 4307

 4308

 4309

 4311

 4313

 4352

 4354

 4401

 4402

 4404

 4407

 4408

 4409

 4453

 4454

 4455

 4565

 4570

 4601

 4602

 4603

 4604

 4605

 4606

 4607

 4610

 4612

 4621

 4622

 4623

 4624

 4625

 4641

 4642

 4651

 4652

 4653

4661

Table 3-1: Major Sources and Applicable RACT Rules

N 1252 FOSTER FOOD PRODUCTS MEAT PROCESSING AND RENDERING FACILITY x x x N 1276 INGOMAR PACKING COMPANY PRODUCE PROCESSING PLANT x x xN 1302 MCCONNELL RECREATION AREA PARKS AND RECREATION x xN 1326 MORNING STAR PACKING COMPANY AGRICULTURAL PRODUCTS PROCESSING x N 1351 MORNING STAR MERCED LLC AGRICULTURAL PRODUCTS PROCESSING x N 1399 LIBERTY PACKING CO - THE MORNING STAR CO AGRICULTURAL PRODUCTS PROCESSING x N 1646 QUEBECOR WORLD COMMERCIAL PRINTING x x 

N 1647 CALAVERAS MATERIALS INC. ASPHALT PAVING MIXTURES x xN 1657 SENSIENT DEHYDRATED FLAVORS COMPANY DEHYDRATED VEGETABLE PROCESSING x x x x x N 1662 GALLO GLASS COMPANY GLASS MANUFACTURING PLANT x x N 1665 BRONCO WINE COMPANY WINERY x x xx N 1679 SANTA FE AGGREGATES, INC. AGGREGATE AND ASPHALTIC CONCRETE PRODUCTION xN 1680 STANISLAUS FOOD PRODUCTS TOMATO PROCESSING FACILITY x x N 1719 SILGAN CONTAINERS MFR. CORP. METAL CANS xN 1787 GILROY FOODS VEGETABLE PROCESSING AND DEHYDRATING x x xN 1919 FRITO-LAY NORTH AMERICA INC FOOD PROCESSING FACILITY x xN 1931 GAYLORD MANUFACTURING CO METAL PARTS & PRODUCTS MANUFACTURING xN 1976 CONAGRA FOODS FOOD PRODUCTS PROCESSING x N 1980 EVERGREEN BEVERAGE PACKAGING CONVERTED PAPER PRODUCTS MANUFACTURER x xN 1982 INTERNATIONAL PAPER COMPANY CORRUGATED AND SOLID FIBER BOXES x xN 2010 GEORGE W. LOWRY, INC. GASOLINE DISTRIBUTION x xN 2022 MEMORIAL HOSPITAL NORTH HOSPITAL AND MEDICAL CENTER x x N 2052 MID - ATTN: GENERAL MANAGER ELECTRIC POWER GENERATION x N 2073 COVANTA STANISLAUS, INC MUNICIPAL SOLID WASTE COMBUSTOR xN 2107 DARLING INTERNATIONAL, INC. RENDERING x x xN 2149 CALIFORNIA DAIRIES, INC. MILK PROCESSING x x N 2174 SILGAN CONTAINERS MFR. CORP. CAN AND CONTAINER MANUFACTURING xx x N 2224 SHELL PIPELINE COMPANY LP CRUDE PETROLEUM PIPELINES x x xN 2232 SENECA FOODS LLC FRUIT CANNING FACILITY x x N 2246 TURLOCK IRRIGATION DISTRICT POWER GENERATION FACILITY x N 2253 BALL METAL FOOD CONTAINER CORP. CAN & COIL MANUFACTURING xx xN 2274 VARCO PRUDEN BUILDINGS, INC. PREFABRICATED METAL BUILDINGS AND COMPONENTS x xN 2279 GEORGE W. LOWRY, INC. GASOLINE DISTRIBUTION x xN 2303 CALAVERAS MATERIALS INC. ASPHALT PAVING MIXTURES x xN 2305 INTERNATIONAL PAPER COMPANY PAPERBOARD CONTAINER MANUFACTURER x xN 2321 RME INC - WOODBRIDGE WINERY WINERY xx x N 2355 RECYCLE TO CONSERVE ANIMAL FEED PROCESSING xN 2360 GALLO GLASS COMPANY NONCLASSIFIABLE ESTABLISHMENTS xN 2369 BP WEST COAST PRODUCTS, LLC CLASS 1 ORGANIC LIQUID LOADING FACILITY x xx N 2697 NORTHERN CALIFORNIA POWER COGENERATION FACILITY x N 2835 TEICHERT AGGREGATES SAND AND GRAVEL xN 3006 R & B PAINTING & SANDBLASTING METAL PARTS AND PRODUCTS COATING xN 3038 MONSCHEIN INDUSTRIES INC CABINET MANUFACTURING FACILITY xN 3075 JRW & ASSOCIATES COGENERATION ELECTRICAL SERVICES N 3095 SAN JOAQUIN DELTA COLLEGE COLLEGES AND UNIVERSITIES x x N 3104 GEER RD LANDFILL C/O FINK ROAD LANDFILL LANDFILL xx xN 3202 BIRCHWOOD CABINETS, MODESTO WOOD PRODUCTS xN 3233 MID - GENERATION MANAGER POWER GENERATION FACILITY x N 3243 SILGAN CONTAINERS MFR. CORP. CAN AND CONTAINER MANUFACTURER x xN 3299 TURLOCK IRRIGATION DISTRICT POWER GENERATION FACILITY x N 3309 G-3 ENTERPRISES, LABEL DIVISION GRAPHIC ARTS FACILITY x 

N 3386 E & J GALLO WINERY/LINK PLANT MAINT WINERY x x x x x N 3433 AMERICAN MODULAR SYSTEMS, INC. MODULAR BUILDING MANUFACTURING x xN 3500 MATTHEWS REDWOOD, INC. WOOD CONTAINERS xN 3585 VALLEY PRINTING GRAPHIC ARTS PRINTING OPERATION xN 3606 PACIFIC SOUTHWEST CONTAINER PRINTING OF CONTAINERS & PACKAGING MATERIALS x x

N 3696 MERCED CO DEPT OF PUBLIC WORKS LANDFILL x xx xN 3715 CUSTOM MARBLE & ONYX POLYESTER RESIN CASTING OPERATION N 3780 ENVIROPLEX INC MODULAR BUILDING MANUFACTURING x xN 3791 MARBLE PALACE INC SYNTHETIC MARBLE MANUFACTURING N 3852 LABEL TECHNOLOGY, INC. COMMERCIAL PRINTING xN 3941 MALIBU BOATS LLC FIBERGLASS BOAT MANUFACTURING x xN 3969 GEER RD LANDFILL C/O FINK RD LANDFILL LANDFILL xx x xxxN 4013 JAXON ENTERPRISES SAND, GRAVEL, AND ASPHALT PROCESSING xN 4065 BARBOSA CABINETS, INC. MANUFACTURER OF WOODEN CABINETS x N 4070 SAN JOAQUIN COUNTY LANDFILL x xN 4080 OAKDALE COMMERCIAL FEED YARD ANIMAL FEED MANUFACTURING N 4148 WELDWAY INC. STEEL FABRICATOR xN 4238 LODI GAS STORAGE LLC NATURAL GAS TRANSMISSION x x N 4247 TEICHERT AGGREGATES ASPHALT PAVING MIXTURES xN 4316 AMERICAN HIGHWAY TECHNOLOGY METAL FABRICATION xN 4338 PREMIER COATINGS DBA PREMIER FINISHING METAL PARTS AND PRODUCT COATING xx x N 4390 WASTEQUIP MFG CO/MCLAUGHLIN REFUSE EQUIP METAL PARTS AND PRODUCTS COATING xN 4422 DESIGNED MOBILE SYSTEMS IND GENERAL BUILDING CONTRACTORS-NONRESIDENTIAL x xN 4473 DSS COMPANY ASPHALT BATCH PLANT xN 4592 SPORT BOAT TRAILERS TRANSPORTATION EQUIPMENT, NEC x xN 4597 GWF ENERGY LLC-TRACY PEAKER POWER PLANT ELECTRIC POWER GENERATION x N 4680 DOPACO, INC BEVERAGE CONTAINER MANUFACTURING xN 4939 C W US INC DBA TURNER ROAD VINTNERS WINERY x 

N 4940 MODESTO IRRIGATION DISTRICT POWER GENERATION FACILITY N 4968 CITY OF CERES WATER SUPPLY N 5177 FRAZIER NUT FARMS INC AGRICULTURAL CROP PRODUCTION N 5526 RAINBOW FARMS CHICKEN EGGS xx 

 3-5

Chapter 3: Major S
San Joaquin Valley Unified Air Pollution Control District 

 Region

 ID # Facility Name Facility Description 4103

 4104

 4106

 4301

 4306

 4307

 4308

 4309

 4311

 4313

 4352

 4354

 4401

 4402

 4404

 4407

 4408

 4409

 4453

 4454

 4455

 4565

 4570

 4601

 4602

 4603

 4604

 4605

 4606

 4607

 4610

 4612

 4621

 4622

 4623

 4624

 4625

 4641

 4642

 4651

 4652

 4653

4661

Table 3-1: Major Sources and Applicable RACT Rules

N 5635 WILLOW DAIRY DAIRY FARM N 5636 COTTONWOOD DAIRY DAIRY FARM x 

N 5638 BEAR CREEK DAIRY DAIRY FARM N 5639 BAMBOO DAIRY DAIRY FARM N 5695 CASTELANELLI BROS AGRICULTURAL CROP PRODUCTION x x x x N 7105 AUGUST RANCH POULTRY RANCH x 

N 7172 WALNUT ENERGY CENTER AUTHORITY POWER GENERATION FACILITY N 7478 E & J GALLO WINERY - BRANDY DISTILLED SPIRITS o N 7737 ROY JOHNSON FARMS, INC. ALMOND FARMING N 7827 CITY OF MODESTO COMPOSTING FACILITY COMPOSTING FACILITY N 7899 SCONZA CANDY COMPANY CANDY AND CONFECTIONARY MANUFACTURING x 

S 4 TEHACHAPI-CUMMINGS WATER DIST WATER SUPPLY x S 33 BIG WEST PETROLEUM REFINERY x x x x x x x x x x x S 34 BIG WEST OF CA, LLC PETROLEUM REFINERY x x x x x x x x x S 35 L P O D, INC PETROLEUM OILS DEHYDRATION OPERATION x x x x x x xS 36 SAN JOAQUIN REFINING COMPANY PETROLEUM REFINING x x x x x x x x xS 37 KERN OIL & REFINING COMPANY PETROLEUM REFINING x x x x x x x xxxxx S 39 INERGY PROPANE LLC MIXED, MANUFACTURED OR LPG PRODUCTION x x x x x x S 40 CENTRAL RESOURCES INC NATURAL GAS PRODUCTION x x x x x S 44 TRICOR REFINING, LLC PETROLEUM REFINERY x x x x x xxxxxx S 46 TRICOR REFINING, LLC PETROLEUM REFINING x xS 48 CRIMSON RESOURCE MANAGEMENT GAS PLANT x xx S 55 CHEVRON USA INC NATURAL GAS PRODUCTION x x x S 71 PLAINS LPG SERVICES, L.P. NATURAL GAS LIQUIDS x x x x x S 73 OILDALE ENERGY LLC ELECTRIC POWER GENERATION x x x S 75 COVANTA DELANO INC ELECTRIC SERVICES - POWER GENERATION x x xS 77 SHELL PIPELINE COMPANY LP CRUDE PETROLEUM PIPELINE x x S 83 SHELL PIPELINE COMPANY LP CRUDE PETROLEUM PIPELINE x x x x S 88 KERN RIVER COGENERATION CO COGENERATION x 

S 91 MT POSO COGENERATION COMPANY COGENERATION xx x S 132 PROVISIONS FOOD COMPANY INC MILK PROCESSING/DAIRY PRODUCTS MANUFACTURER xS 146 KAWNEER COMPANY INC METAL PARTS AND PRODUCTS COATING xS 169 GLEN WELLS CONSTRUCTION CO ASPHALT PAVING MIXTURES AND BLOCKS S 172 LIVE OAK LIMITED OIL & GAS PRODUCTION x S 205 CONSOLIDATED FIBERGLASS ASPHALT FELTS AND COATINGS x xS 254 PLAINS PIPELINE LP CRUDE PETROLEUM PIPELINES x x x S 285 CRES INC DBA DINUBA ENERGY ELECTRIC SERVICES - POWER GENERATION x xS 287 PETROLEUM PRODUCTION TESTING TRANSPORTABLE WELL TEST FLARE xS 334 PREGIS INNOVATIVE PACKAGING INC PLASTIC FOAM PRODUCTS MANUFACTURING xx S 348 WEST KERN WATER DISTRICT WATER DISTRICT x S 349 WEST KERN WATER DISTRICT WATER DISTRICT x S 350 WEST KERN WATER DISTRICT WATER DISTRICT x S 353 WEST KERN WATER DISTRICT WATER DISTRICT x S 360 LIBERTY COMPOSTING INC CO-COMPOSTING S 364 CALMAT CO., DBA VULCAN MATERIALS CO. ASPHALT PAVING MIXTURES xS 377 PARAMOUNT FARMS TREE NUT PROCESSING FACILITY x x x x x S 381 HECK CELLARS WINERY x 

S 382 OCCIDENTAL OF ELK HILLS, INC (OEHI) OIL AND NATURAL GAS PRODUCTION x x x x x x xxxx S 498 AMERICAN YEAST CORPORATION YEAST PRODUCTION x x x xS 511 SYCAMORE COGENERATION CO COGENERATION x 

S 512 SETTON PISTACHIO OF TERRA BELLA AGRICULTURAL PRODUCTS PROCESSING x S 525 LAND O' LAKES, INC. MILK PROCESSING/DAIRY PRODUCTS MANUFACTURER x x x x xS 548 TULARE CITY WASTEWATER PLANT WASTEWATER TREATMENT x x S 623 CAL MAT DBA VULCAN MATERIALS COMPANY ASPHALTIC PAVING MIXTURES xS 637 JOSTENS INC GRAPHICS ARTS PRINTING OPERATION x x S 713 PARAMOUNT KING LLC AGRICULTURAL PRODUCTS PROCESSING, PISTACHIOS xS 723 CHALK CLIFF LIMITED COGENERATION x S 724 DAI OILDALE INC OIL & GAS PRODUCTION x x x x S 834 SIERRA POWER CORPORATION ELECTRICAL SERVICES x x xS 848 AGRI-CEL INC PLASTIC FOAM PRODUCTS x S 883 RIO BRAVO POSO ELECTRIC SERVICES x x x xx S 892 PACTIV CORPORATION PLASTICS FOAM PRODUCTS x x S 984 VISALIA WASTEWATER TREATMENT WASTEWATER TREATMENT x xx S 1075 STYROTEK INC PLASTICS FOAM PRODUCTS x x x S 1114 SENECA RESOURCES CORPORATION OIL AND NATURAL GAS PRODUCTION x x x x x x S 1115 VICTORY OIL CO OIL & GAS PRODUCTION x x x x

S 1118 HIGH SIERRA LIMITED OIL AND NATURAL GAS PRODUCTION x 

S 1119 DOUBLE C LIMITED OIL AND NATURAL GAS PRODUCTION x S 1120 KERN FRONT LIMITED OIL AND NATURAL GAS PRODUCTION x S 1121 NAFTEX OPERATING COMPANY OIL AND GAS PRODCTION x x x xS 1126 UPF CORPORATION FIBERGLASS INSULATION MANUFACTURING S 1127 CHEVRON USA INC OIL AND NATURAL GAS PRODUCTION x x x x x x S 1128 CHEVRON USA INC OIL AND NATURAL GAS PRODUCTION x x x x x x x S 1129 CHEVRON U S A INC OIL AND NATURAL GAS PRODUCTION x x x x x x x S 1130 CHEVRON U S A INC OIL AND NATURAL GAS PRODUCTION x xS 1131 CHEVRON USA INC OIL AND NATURAL GAS PRODUCTION x x x x x x x x S 1135 AERA ENERGY LLC CRUDE PETROLEUM AND NATURAL GAS PRODUCTION x x x x x x x S 1141 CHEVRON USA INC OIL AND NATURAL GAS PRODUCTION x x x x x x x S 1188 NESTLE PURINA PETCARE COMPANY AGGREGATE/MINERAL PROCESSING xS 1199 PLAINS MARKETING LP CRUDE PETROLEUM PIPELINE x x x x S 1203 SAPUTO CHEESE USA INC DRY, CONDENSED, EVAPORATED DAIRY PRODUCTS x x S 1216 OCCIDENTAL OF ELK HILLS, INC. OIL AND GAS PRODCTION x x x x x S 1234 TAFT PRODUCTION COMPANY AGGREGATE/MINERAL PROCESSING x x

 3-6

Chapter 3: Major S
San Joaquin Valley Unified Air Pollution Control District 

 Region

 ID # Facility Name Facility Description 4103

 4104

 4106

 4301

 4306

 4307

 4308

 4309

 4311

 4313

 4352

 4354

 4401

 4402

 4404

 4407

 4408

 4409

 4453

 4454

 4455

 4565

 4570

 4601

 4602

 4603

 4604

 4605

 4606

 4607

 4610

 4612

 4621

 4622

 4623

 4624

 4625

 4641

 4642

 4651

 4652

 4653

4661

Table 3-1: Major Sources and Applicable RACT Rules

S 1242 SENECA RESOURCES OIL AND GAS PRODUCTION x x S 1246 BERRY PETROLEUM COMPANY OIL AND NATURAL GAS PRODUCTION x x x x x x x x x S 1247 EMJAYCO OIL & NATURAL GAS PRODUCTION x xS 1250 BADGER CREEK LIMITED GAS TURBINE ENGINE COGENERATION SYSTEM x 

S 1251 MCKITTRICK LIMITED COGENERATION x S 1259 CLEAN HARBORS BUTTONWILLOW, LLC HAZARDOUS & NONHAZARDOUS WASTE DISPOSAL FACILITY xxx S 1326 VINTAGE PRODUCTION CALIFORNIA LLC OIL AND NATURAL GAS PRODUCTION x x x x x x x S 1327 VINTAGE PRODUCTION CALIFORNIA LLC OIL AND NATURAL GAS PRODUCTION x x x xS 1328 EXXONMOBIL CORPORATION PETROLEUM AND NATURAL GAS PRODUCTION x x x x x x S 1329 HUNTER EDISON OIL DEVELOPMENT OIL & GAS PRODUCTION x x x x S 1346 CALIFORNIA DAIRIES, INC. DRY, CONDENSED, EVAPORATED DAIRY PRODUCTS x x x x S 1372 PLAINS EXPLORATION & PRODUCTION COMPANY OIL AND NATURAL GAS PRODUCTION x x x x x x x x x x S 1379 PACIFIC FIBERGLASS INC PLASTICS PRODUCTS S 1385 DELTA TRADING ICO CRIMSON RESOURCE MGMT PETROLEUM BLENDING FACILITY x xx S 1388 DELTA TRADING ICO CRIMSON RESOURCE MGMT PETROLEUM REFINING xS 1399 CHEVRON USA INC PIPELINE PUMP STATION xS 1405 EXXONMOBIL PIPELINE COMPANY PIPELINE PUMP STATION xS 1406 EXXONMOBIL OIL CORPORATION PIPELINE PUMP STATION xS 1413 SHELL PIPELINE COMPANY LP PIPELINE PUMP STATION x x x xS 1415 SHELL CALIFORNIA PIPELINE COMPANY LLC PIPELINE PUMP STATION x x S 1416 SHELL CALIFORNIA PIPELINE COMPANY LLC PIPELINE PUMP STATION x x S 1509 VAQUERO ENERGY, INC. OIL & GAS PRODUCTION x x xS 1510 VAQUERO ENERGY INC OIL & GAS PRODUCTION x xS 1518 CONOCOPHILLIPS PIPE LINE COMPANY PETROLEUM PIPELINES xx S 1520 CONOCOPHILLIPS PIPE LINE COMPANY PIPELINE FACILITY x x S 1521 CONOCOPHILLIPS PIPE LINE COMPANY PETROLEUM PIPELINES x x S 1525 CONOCOPHILLIPS PIPE LINE COMPANY PIPELINE FACILITY x S 1543 AERA ENERGY LLC GAS PLANT x x x x S 1547 AERA ENERGY LLC CRUDE PETROLEUM AND NATURAL GAS x x x x x x x x x x S 1548 AERA ENERGY LLC LIGHT OIL PRODUCTION x x x x x S 1550 MCFARLAND ENERGY INC OIL AND NATURAL GAS PRODUCTION x xS 1610 GRANITE CONSTRUCTION COMPANY ASPHALT PAVING MIXTURES x x xS 1612 GRANITE CONSTRUCTION COMPANY ASPHALT PAVING MIXTURES xS 1624 E&B NATURAL RESOURCES MGMT CRUDE PETROLEUM AND NATURAL GAS x x x x x x x S 1630 SENECA RESOURCES OIL & GAS PRODUCTION x S 1678 KERN MEDICAL CENTER HOSPITALS x S 1703 MACPHERSON OIL COMPANY OIL AND NATURAL GAS PRODUCTION x x x x x x x xS 1737 VINTAGE PRODUCTION CALIFORNIA LLC CRUDE OIL AND NATURAL GAS PRODUCTION x x xS 1738 VINTAGE PRODUCTION CALIFORNIA LLC CRUDE OIL AND NATURAL GAS PRODUCTION x x xxxx S 1751 RIO BRAVO JASMIN ELECTRIC SERVICES x x S 1807 E&B NATURAL RESOURCES MGMT CORP CRUDE PETROLEUM AND NATURAL GAS x x xS 1810 CONTAINMENT SOLUTIONS INC. TANK MANUFACTURING x x S 1876 BLUESCOPE BUILDINGS NORTH AMERICA INC METAL FABRICATION xS 2010 CHEVRON USA INC OIL AND NATURAL GAS PRODUCTION x x x x xS 2033 ELK CORPORATION OF TEXAS ASPHALT FELTS AND COATINGS x xS 2049 BEAR MOUNTAIN LIMITED OIL AND NATURAL GAS PRODUCTION x S 2076 FRITO-LAY NORTH AMERICA INC SNACK FOODS MANUFACTURING x x x S 2197 MAGEE INVESTMENT COMPANY OIL AND GAS FIELD SERVICE xS 2199 CHEVRON USA PRODUCTION INC NATURAL GAS PRODUCTION x S 2234 OCCIDENTAL OF ELK HILLS, INC. (OEHI) NATURAL GAS PROCESSING x x x x x x x x S 2246 SAN JOAQUIN FACILITIES MGMT OIL & GAS PRODUCTION x xS 2265 BERRY PETROLEUM COMPANY OIL & NATURAL GAS PRODUCTION x S 2273 BAKERSFIELD CITY WASTEWATER #2 SEWERAGE SYSTEMS x S 2286 US OIL & GAS CRUDE OIL AND NATURAL GAS PRODUCTION xS 2329 VINTAGE PRODUCTION CALIFORNIA, LLC OIL AND GAS PRODUCTION x x x x x xS 2392 JACO HILL GASOLINE DISPENSING x xS 2584 SEQUOIA EXPLORATION OIL AND GAS PRODUCTION xS 2585 SEQUOIA EXPLORATION OIL AND NATURAL GAS PRODUCTION xS 2592 MID-SET COGEN C/O G.M.THOMSON OIL AND NATURAL GAS PRODUCTION x S 2622 TRC OPERATING COMPANY INC CRUDE OIL AND NATURAL GAS PRODUCTION x x x xS 2645 A & P GROWERS NUT HULLING, SHELLING, SORTING, AND GRADING xS 2717 CAPCO RESOURCE CORPORATION OIL AND GAS PRODUCTION xS 2742 SUN MOUNTAIN OIL & GAS OIL AND GAS PRODUCTION xS 2814 SUN-GRO COMMODITIES INC AGRICULTURAL IMPLEMENTS & MACHINERY 

S 2865 J P OIL COMPANY INC OIL & GAS PRODUCTION x S 2890 MM TULARE ENERGY, LLC ELECTRIC POWER GENERATION x S 2896 PACIFIC PROCESS SYSTEMS OIL WELL TESTING xS 2918 CRIMSON RESOURCE MANAGEMENT OIL AND NATURAL GAS PRODUCTION x xx S 2980 SAN JOAQUIN FACILITIES MGMT LIGHT OIL PRODUCTION x x x S 2996 NEO TULARE LLC/TULARE COUNTY LANDFILL xS 3012 APTCO LLC PLASTICS FOAM PRODUCTS x S 3027 EAGLE SANDBLASTING & PAINTING ABRASIVE BLASTING OPERATION xxx xS 3036 SUN MOUNTAIN OIL & GAS OIL AND GAS PRODUCTION xS 3079 CRIMSON RESOURCE MANAGEMENT OIL AND NATURAL GAS PRODUCTION x xS 3088 TRC CYPRESS GROUP LLC CRUDE OIL AND NATURAL GAS PRODUCTION x x x xS 3103 BAKERSFIELD CITY WASTEWATER #3 SEWERAGE SYSTEMS S 3232 KERN COUNTY WASTE MANAGEMENT SANITARY LANDFILL x xS 3303 BIG WEST OF CA, LLC GASOLINE TERMINAL WITHOUT BULK STORAGE FACILITIES x x xxS 3317 CHEVRON U S A INC NATURAL GAS TRANSMISSION & DISTRIBUTION x S 3322 N. W. LOST HILLS PETROLEUM HOLDINGS, LLC OIL AND GAS PRODUCTION x xS 3342 CAMBRIAN ENERGY WOODVILLE LLC SANITARY LANDFILL x S 3412 LA PALOMA GENERATING CO LLC POWER PLANT x x x S 3431 KERN COUNTY WASTE MANAGEMENT SANITARY LANDFILL xx x

 3-7

Chapter 3: Major S
San Joaquin Valley Unified Air Pollution Control District 

 Region

 ID # Facility Name Facility Description 4103

 4104

 4106

 4301

 4306

 4307

 4308

 4309

 4311

 4313

 4352

 4354

 4401

 4402

 4404

 4407

 4408

 4409

 4453

 4454

 4455

 4565

 4570

 4601

 4602

 4603

 4604

 4605

 4606

 4607

 4610

 4612

 4621

 4622

 4623

 4624

 4625

 4641

 4642

 4651

 4652

 4653

4661

Table 3-1: Major Sources and Applicable RACT Rules

S 3432 KERN COUNTY WASTE MANAGEMENT SANITARY LANDFILL xx xS 3433 KERN COUNTY WASTE MANAGEMENT SANITARY LANDFILL xx xS 3461 BUILDING MATERIALS MANUF. CORP FIBERGLASS MAT MANUFACTURING OPERATION S 3523 ELK HILLS POWER LLC ELECTRIC POWER GENERATION x S 3553 SALT CREEK OIL LLC OIL PRODUCTION x x xS 3570 DUNKIN & BUSH INC METAL PARTS AND PRODUCTS COATING xS 3577 JIM'S FORMAL WEAR INDUSTRIAL LAUNDERERS S 3585 BERRY PETROLEUM COMPANY OIL AND GAS PRODCTION x x x xS 3611 TULARE COUNTY RMA SANITARY LANDFILL xx x xS 3636 PASTORIA ENERGY FACILITY, LLC POWER GENERATION S 3663 CITY OF DELANO GOVERNMENT SERVICES S 3694 TRI VALLEY OIL & GAS OIL AND GAS FIELD SERVICES xS 3720 KERN COUNTY WASTE MANAGEMENT DEPT SANITARY LANDFILL xx xS 3724 HEALTHSOUTH PHYSICIANS PLAZA SURGERY CTR HOSPITALS S 3728 TULARE COUNTY RESOURCE MGMT AGENCY SANITARY LANDFILL xx xS 3729 TULARE COUNTY RESOURCE MGMT AGENCY SANITARY LANDFILL xx xS 3746 SUNRISE POWER COMPANY POWER PLANT x 

S 3878 BIG WEST OF CALIFORNIA LLC OIL AND GAS PRODUCTION xS 3914 TS LEASING OPERATIONS INC OIL & GAS PRODUCTION xS 3995 PATRICK HOLMES INDUSTRIAL PAINTING xS 4001 PRIMEX FARMS LLC AGRICULTURAL PRODUCTS PROCESSING S 4026 ELCO INC FABRICATED METAL PRODUCTS xS 4034 E&B NATURAL RESOURCES OIL & GAS PRODUCTION xx S 4073 NATIONS PETROLEUM USA LTD OIL & NATURAL GAS PRODUCTION x x x xS 4080 LONGBOW, LLC. OIL PRODUCTION xS 4126 SUNRAY PETROLEUM INC CRUDE OIL PRODUCTION xS 4212 SOUTH KERN INDUSTRIAL CENTER LLC CO-COMPOSTING S 4214 PIXLEY ETHANOL LLC ETHANOL PRODUCTION FACILITY xx S 4294 WORLD OIL CORP. SOIL AND GROUNDWATER REMEDIATION x xS 4434 FERNANDES BROTHERS DBA LEGACY RANCH AGRICULTURAL CROP PRODUCTION x xx S 4548 FARMLAND MANAGEMENT SERVICES AGRICULTURAL CROP PRODUCTION xx S 4554 WESTERN SKY DAIRY AGRICULTURAL CROP PRODUCTION xS 4670 EJ DE GROOT FARMS AGRICULTURAL CROP PRODUCTION x xS 4692 BELLANAVE CORPORATION DAIRY FARM xx S 4693 WEST KERN DAIRY DAIRY FARM xS 4702 VANDER EYK & SONS DAIRY AGRICULTURAL CROP PRODUCTION, DAIRY xS 4719 GRACELAND DAIRY INC AGRICULTURAL CROP PRODUCTION x 

S 4737 VINCENT B. ZANINOVICH & SONS, INC. AGRICULTURAL FIELD CROPS S 4749 MILKY WAY DAIRY DAIRY FARMS x xx S 4751 BIDART DAIRY LLC AGRICULTURAL CROP PRODUCTION, DAIRY S 4751 BIDART DAIRY, LLC AGRICULTURAL CROP PRODUCTION, DAIRY S 4800 MARTIN HEIN RANCH COMPANY AGRICULTURAL CROP PRODUCTION S 4802 AGTOPROF INC FOR PA 4,8,9 AGRICULTURAL CROP PRODUCTION S 4853 WEST COAST GRAPE FARMING INC-TEHACHAPI AGRICULTURAL CROP PRODUCTION S 4877 KOETSIER DAIRY DAIRY FARM S 5058 HILARIDES DAIRY AGRICULTURAL CROP PRODUCTION, DAIRY x xx S 5060 TJAARDA DAIRY DAIRY FARM x xx S 5064 KOOTSTRA DAIRY AGRICULTURAL CROP PRODUCTION S 5068 POSO CREEK DAIRY DAIRY FARM xx S 5069 CARLOS ECHEVERRIA & SONS DAIRY DAIRY FARM x xxS 5134 COUNTRY SIDE DAIRY DAIRY S 5209 MELVIN SIMOES DAIRY DAIRY FARMS xx S 5213 COSTA DAIRY FARMS DAIRY x S 5252 PAUL FARMS AGRICULTURAL CROP PRODUCTION S 5265 MAPLE DAIRY DAIRY OPERATION xx S 5294 WEST KERN WATER DISTRICT WATER DISTRICT S 5324 ANGIOLA DAIRY DAIRY FARM xx S 5325 ATSMA DAIRIES DAIRY FARM xx S 5346 WESTHILL DAIRY DAIRY FARM S 5348 RICHARD D WESTRA DAIRY FARMS xx S 5439 GREEN ACRES FARM AGRICULTURAL CROP PRODUCTION xx S 5446 PAUL FARMS AGRICULTURAL CROP PRODUCTION S 5688 MONROVIA GROWERS, VISALIA AGRICULTURAL CROP PRODUCTION x S 5712 D & J FARM MGMT / FABBRI FARMING CO AGRICULTURAL CROP PRODUCTION S 6331 WM. BOLTHOUSE FARMS INC AGRICULTURAL CROP PRODUCTION x S 6375 BOSMAN-PIXLEY DAIRY (FARMLAND) AGRICULTURAL CROP PRODUCTION S 6509 HATHAWAY LLC CRUDE OIL STORAGE OPERATION xS 6592 BOSMAN DAIRY AGRICULTURAL CROP PRODUCTION, DAIRY x xS 6622 SOUTH LAKES DAIRY DAIRY S 6644 ALVIN SOUZA DAIRY DAIRY FARMS x xS 6673 MEADOWLAKE EAST DAIRY DAIRY FARMS S 6706 C & R VANDERHAM DAIRY DAIRY FARM S 6718 ARTESIA DAIRY DAIRY FARM xx S 6723 JOE MACEDO & SONS DAIRY DAIRY FARM x xx S 6911 ALVIN SOUZA - DEER CREEK AGRICULTURAL CROP PRODUCTION S 6918 BROTHERS FARMS, LLC AGRICULTURAL CROP PRODUCTION S 6978 MEADOWLAKE WEST DAIRY DAIRY FARM xx S 6983 CORE ENERGY, LLC OIL PRODUCTION x x xS 6991 G J TEVELDE RANCH AGRICULTURAL CROP PRODUCTION xx S 7045 ANATESCO WEST OIL WELL TESTING xS 7063 CALIFORNIA DAIRIES, INC MILK PROCESSING/DAIRY PRODUCTS MANUFACTURER x xS 7112 WASCO REAL PROPERTIES I, LLC AGRICULTURAL CROP PRODUCTION S 7117 BORBA DAIRY DAIRY FARM xx 

 3-8

Chapter 3: Major S
San Joaquin Valley Unified Air Pollution Control District 

 Region

 ID # Facility Name Facility Description 4103

 4104

 4106

 4301

 4306

 4307

 4308

 4309

 4311

 4313

 4352

 4354

 4401

 4402

 4404

 4407

 4408

 4409

 4453

 4454

 4455

 4565

 4570

 4601

 4602

 4603

 4604

 4605

 4606

 4607

 4610

 4612

 4621

 4622

 4623

 4624

 4625

 4641

 4642

 4651

 4652

 4653

4661

Table 3-1: Major Sources and Applicable RACT Rules

S 7164 FELICITA DAIRY DAIRY FARM x S 7214 BONANZA CREEK ENERGY OPERATION COMPANY OIL & GAS PRODUCTION xS 7241 K & M VISSER AGRICULTURAL CROP PRODUCTION, DAIRY xx S 7469 ETCHEGARAY FARMS AGRICULTURAL CROP PRODUCTION 

 3-9

Chapter 3: Major S
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 3: Major Sources and Applicable RACT Rules 

RACT Demonstration for Ozone SIP 

3-10 

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RACT Demonstration for Ozone SIP

Chapter 4 

Rule Analysis 
RACT Demonstration for Ozone SIP

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San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-1 

Chapter 4: Rule Analysis

4.1 RULES ANALYZED FOR RACT 

The bulk of the District’s RACT Demonstration effort was to review the District’s 

numerous NOx and VOC regulations for compliance with federal RACT requirements. 

Except for the rules shown in Table 4-2, District staff reviewed the applicability, 

stringency, and enforceability of every District NOx or VOC prohibitory rule. Table 4-1 

shows the rules that District staff analyzed for RACT. 

As discussed in Chapter 1, criteria for determining that RACT is satisfied included the 

RACT guidance from EPA, requirements per California law, and a comparison against 

multiple federal rules, regulations, and technology guidelines as well as evaluating 

District rules against comparable rules from California’s most technologically 

progressive air districts. District staff, upon application of the criteria, was then able to 

determine RACT status for each rule. 

It should be noted that if a District rule had been recently SIP-approved, it was 

understood that the rule had been evaluated by the EPA and found to fulfill RACT, and 

no detailed analysis was conducted. However, since RACT is a moving target, if there 

were no recent SIP-approvals for a rule, District staff performed a detailed analysis to 

evaluate rule requirements against current technology. 
San Joaquin Valley Unified Air Pollution Control District 

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RACT Demon

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Table 4-1 District Rules Analyzed and Rule History 

Rule # Rule Title Pollutants Controlled CTG Source? Date Adopted Date Last Amended

Federal 

Register 

Publication 

Date 

4103 Open Burning 

minimize 

smoke impact 

N 6/18/1992 5/17/2007 4/11/2006 

4104 Reduction of Animal Matter air contaminants N 5/21/1992 - 1/2/2008 4106 Prescribed Burning and Hazard Reduction Burning VOC, NOx, SOx, PM N 6/21/2001 - 2/27/2002 4301 Fuel Burning Equipment 

NOx, SOx, 

combustion 

contaminant 

N 5/21/1992 12/17/1992 5/18/1999 

4306 Boilers, Steam Generators, and Process Heaters – Phase 3 NOx, CO Y 9/18/2003 10/16/2008 5/18/2004 4307 

Boilers, Steam Generators, and Process Heaters - 2.0 MMBtu/hr to 5.0 MMBtu/hr 

NOx, CO Y 12/15/2005 10/16/2008 5/30/2007 

4308 

Boilers, Steam Generators, and Process Heaters - 0.075 MMBtu/hr to 2.0 MMBtu/hr 

NOx, CO Y 10/20/2005 - 5/30/2007 

4309 Dryers, Dehydrators and Ovens NOx, CO N 12/15/2005 - 5/30/2007 4311 Flares NOx, VOC N 6/20/2002 6/15/2006 2/26/2003 4313 Lime Kilns NOx N 3/27/2003 - 9/4/2003 4354 Glass Melting Furnaces NOx, CO, VOC N 9/14/1994 10/16/2006 8/1/2007 4401 Steam-Enhanced Crude Oil Production Well Vents VOC N 4/11/1991 12/14/2006 6/22/1998 4402 Crude Oil Production Sumps VOC N 4/11/1991 12/17/1992 1/2/2008 
San Joaquin Valley Unified Air Pollution Control District 

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Table 4-1 District Rules Analyzed and Rule History 

Rule # Rule Title Pollutants Controlled CTG Source? Date Adopted Date Last Amended

Federal 

Register 

Publication 

Date 

4404 Heavy Oil Test Station – Kern County VOC N 5/21/1992 12/17/1992 4407 In-situ Combustion Well Vents VOC N 5/19/1994 - 3/6/1995 4408 Glycol Dehydration Systems VOC N 12/19/2002 - 8/26/2003 4409 

Components at Light Crude Oil Production Facilities, Natural Gas 

Production Facilities, and Natural Gas Processing Facilities 

VOC Y 4/20/2005 - 3/23/2006 

4453 Refinery Vacuum Producing Devices or Systems VOC Y 5/21/1992 12/17/1992 1/2/2008 4454 Refinery Process Unit Turnaround VOC Y 5/21/1992 12/17/1992 1/2/2008 4455 

Components at Refineries, Gas Processing Facilities, and Chemical Plants 

VOC Y 4/20/2005 - 3/23/2006 

4565 Biosolids, Animal Manure, and Poultry Litter Operations VOC N 3/15/2007 - 4570 Confined Animal Facilities VOC N 6/15/2006 - 4601 Architectural Coatings VOC N 4/11/1991 10/31/2001 1/2/2004 4603 Surface Coating of Metal Parts and Products VOC Y 4/11/1991 10/16/2008 6/25/2002 4604 Can and Coil Coating Operations VOC Y 4/11/1991 9/20/2007 5/19/2005 4605 Aerospace Assembly and Component Coating Operations VOC Y 12/19/1991 9/20/2007 11/14/2003 4606 Wood Products Coating Operations VOC Y 12/19/1991 10/16/2008 6/26/2002 4607 Graphic Arts VOC Y 4/11/1991 12/18/2008 6/26/2002 
San Joaquin Valley Unified Air Pollution Control District 

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Table 4-1 District Rules Analyzed and Rule History 

Rule # Rule Title Pollutants Controlled CTG Source? Date Adopted Date Last Amended

Federal 

Register 

Publication 

Date 

4610 Glass Coating Operations VOC N 5/16/2002 4/17/2003 10/14/2004 4612 

Motor Vehicle and Mobile Equipment Coating OperationsPhase II VOC Y 9/21/2006 9/20/2007 

4621 

Gasoline Transfer into Stationary Storage Containers, Delivery Vessels, and Bulk Plants 

VOC Y 4/11/1991 12/20/2007 4/19/2000 

4622 Gasoline Transfer into Motor Vehicle Fuel Tanks gasoline vapors Y 5/21/1992 12/20/2007 3/24/2003 4623 Storage of Organic Liquids VOC Y 4/11/1991 5/19/2005 9/13/2005 4624 Organic Liquid Loading VOC N 4/11/1991 12/20/2007 4625 Wastewater Separators VOC Y 4/11/1991 12/17/1992 1/2/2008 4641 

Cutback, Slow Cure, and Emulsified Asphalt Paving and Maintenance Operations 

VOC Y 4/11/1991 12/17/1992 1/2/2008 

4642 Solid Waste Disposal Sites VOC N 7/20/1995 4/16/1998 7/26/2001 4651 Soil Decontamination Operations VOC N 4/16/1992 9/20/2007 7/25/1996 4652 Coatings and Ink Manufacturing VOC 5/21/1992 12/17/1992 4653 Adhesives VOC N 3/17/1994 9/20/2007 5/7/2002 4661 Organic Solvents VOC Y 5/21/1992 9/20/2007 9/16/2003 4662 Organic Solvent Degreasing Operations VOC Y 4/11/1991 9/20/2007 7/22/2002 4663 Organic Solvent Cleaning, Storage, and Disposal VOC Y 12/20/2001 9/20/2007 7/22/2002 4672 Petroleum Solvent Dry Cleaning Operations VOC Y 4/11/1991 12/17/1992 1/2/2008 4681 Rubber Tire Manufacturing VOC Y 5/16/1991 12/16/1993 8/17/1998 
San Joaquin Valley Unified Air Pollution Control District 

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Table 4-1 District Rules Analyzed and Rule History 

Rule # Rule Title Pollutants Controlled CTG Source? Date Adopted Date Last Amended

Federal 

Register 

Publication 

Date 

4682 

Polystyrene, Polyethylene, and Polypropylene Products Manufacturing 

VOC, CFC11, CFC-12 Y 5/21/1992 9/20/2007 6/13/1995 

4684 Polyester Resin Operations VOC Y 5/19/1994 9/20/2007 6/26/2002 4691 Vegetable Oil Processing Operations VOC 4/11/1991 12/17/1992 4692 Commercial Charbroiling VOC, PM 3/21/2002 - 6/3/2003 4693 Bakery Ovens VOC N 5/16/2002 - 4/26/2004 4694 Wine Fermentation and Storage Tanks VOC N 12/15/2005 - 4702 Internal Combustion Engines – Phase 2 NOx, CO, VOC N 8/21/2003 1/18/2007 1/10/2008 4703 Stationary Gas Turbines NOx N 8/18/1994 9/20/2007 5/18/2004 4902 Residential Water Heaters NOx N 6/17/1993 - 2/17/2004 4905 Natural Gas Fired, Fan-type, Residential Central Furnaces NOx N 10/20/2005 - 5/30/2007 
San Joaquin Valley Unified Air Pollution Control District 

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4-6 

Table 4-2 District NOx and VOC Rules Not Analyzed 

Rule # Rule Title Pollutants Controlled CTG Source? Date Adopted Date Last Amended N

4304 

Equipment Tuning Procedure for Boilers, Steam Generators, and Process Heaters 

NOx, CO N 10/19/1995 - There are no NOx and VO

associated with this rule. 

4305 

Boilers, Steam Generators, and Process Heaters – Phase 2 

NOx, CO Y 12/16/1993 8/21/2003 This rule was superceded 

4308 

4351 

Boilers, Steam Generators, and Process Heaters – Reasonably Available Control Technology 

NOx N 10/20/1994 8/21/2003 This rule was superceded 

4308 

4403 

Components Serving Light Crude Oil or Gases at Light Crude Oil and Gas Production Facilities and Components at Natural Gas Processing Facilities 

VOC N 4/11/1991 4/20/2005 This rule was superceded 

4405 

Oxides of Nitrogen Emissions from Existing Steam Generators Used in Thermally Enhanced Oil Recovery – Central and Western Kern County Fields 

NOx N 5/21/1992 12/17/1992 This rule was superceded 

4451 

Valves, Pressure Relief Valves, Flanges, Threaded Connections and Process Drains at Petroleum Refineries and Chemical Plants 

VOC N 4/11/1991 4/20/2005 This rule was superceded 
San Joaquin Valley Unified Air Pollution Control District 

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Table 4-2 District NOx and VOC Rules Not Analyzed 

Rule # Rule Title Pollutants Controlled CTG Source? Date Adopted Date Last Amended N

4452 

Pump and Compressor Seals at Petroleum Refineries and Chemical Plants 

VOC N 4/11/1991 4/20/2005 This rule was superceded 

4602 

Motor Vehicle and Mobile Equipment Coating Operations 

VOC Y 4/11/1991 7/21/2006 This rule was superceded 

4701 Internal Combustion Engines – Phase 1 NOx, CO, VOC N 5/21/1992 8/21/2003 This rule was superceded 9310 School Bus Fleets NOx, PM N 9/21/2006 - This rule does not regula

sources 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-8 

Rule 4103 – Open Burning 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 4.8 4.8 4.7 4.7 4.7 4.6 4.6 4.5 

VOC 5.7 5.7 5.6 5.6 5.6 5.5 5.5 5.4 

(Source: District 2007 Ozone Plan) 

District Rule 4103 Description

District Rule 4103 applies to open burning conducted within the San Joaquin Valley Air 

Basin, with the exception of prescribed burning and hazard reduction burning which are 

subject to Rule 4106 (Prescribed Burning and Hazard Reduction Burning). District Rule 

4103 includes the following requirements and prohibitions 

General Requirements 

• Prohibits open outdoor fire for disposal of or burning of petroleum wastes; 

demolition or construction debris; residential rubbish; garbage or vegetation; 

tires; tar; trees; woodwaste; or other combustible or flammable solid, liquid or 

gaseous waste; or for metal salvage or burning of motor vehicles. 

• The APCO will allocate burning based on the predicted meteorological conditions 

and whether it would cause nuisance, impact smoke sensitive areas, or create or 

contribute to an exceedance of the ambient air quality standard. 

• The APCO will restrict the time of day when burns are ignited and conducted. 

• No open burning will be permitted that will create nuisance as defined in the state 

Health and Safety Code. 

Agricultural Burning 

• Prohibits issuance of burn permits for specific field crops, specific prunings from 

certain crops, and certain types of weed abatement, except for prunings from 

apple crops, pear crops, fig crops and quince crops as well as weed abatement 

activities affecting waterways (including ponding and levee banks) whereby burn 

permits may be issued until June 1, 2010. 

• Requires the use of at least one best management practice specified in the rule 

(other practice approved by the APCO) for the control of certain type of weeds 

located along ditch banks or canal banks, and the disposal of pesticide sacks or 

fertilizer sacks. 

• Allows issuance of permits for burning of rice stubble until June 1, 2015, but the 

amount of rice stubble that could be burned will be limited and will be 

incrementally reduced annually based on the percent of the total annual acreage 

of rice planted. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-9 

• Agricultural burn permits may be issued until June 1, 2010 for orchard removals 

of citrus, apple, pear, quince, and fig crops; or orchard removals of up to 20 

acres per location per calendar year from other crops. 

• Prohibits burning of agricultural waste unless it is arranged or loosely stacked so 

as to promote drying and insure combustion with minimum smoke. 

• Ignite agricultural waste with an approved ignition device, and not burned unless 

it is free of excessive dirt, soil, and visible surface moisture. 

• Prohibits burning of agricultural waste unless it is free of certain materials 

(plastic, rubber, ornament or landscape vegetation, shop waste, construction and 

demolition, etc.) 

• Prohibits burning of orchard or vineyard removal waste, or other material, 

generated as a result of land use conversion from agricultural to nonagricultural 

purposes. 

• Prohibits burning unless the material has been allowed to dry for a minimum 

specified time period. 

• Monitor and attend burning to prevent smoldering; burn only during daylight 

hours; not add waste to existing fire after 5:00 PM; and ignite rapidly as 

practicable within applicable fire restrictions. 

Field crop burning: 

• Prohibits burning before 10:00 AM or after 2:00 PM of any day, unless local 

conditions indicate other hours are appropriate. 

• Ignite only by strip burning into-the-wind or backfiring, except under a special 

permit and other special conditions/requirements. 

• Rice harvesting must employ mechanical straw spreader but certain exceptions 

are allowed, but rice straw must be dried and meet crackle test criteria detailed in 

the rule. 

Ditch Bank and Levee Maintenance 

• Remove trash and debris prior to burning 

• Prepare the material by stacking, drying, or other methods to promote 

combustion. 

Contraband Materials 

• Prohibits transporting contraband confiscated outside the District for disposal by 

burning within the District. Only contraband confiscated within the San Joaquin 

Valley air basin may be disposed off by burning. 

• Submit written notification to the District of the planned burn prior to burning. 

• Fires should only be set or allowed by a peace officer or public fire official in the 

performance of official duty. 

• To the extent possible, materials must be burned in areas and in conditions 

limiting the possibility of smoke impacts on nearby neighbors or other sensitive 

areas. 
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Russian Thistle 

• Maintain burn site in a fire safe condition according to local fire protection 

agency. 

• Smoke and air contaminants must not impact smoke sensitive areas or 

cause/contribute to a nuisance, or create/contribute to exceedance of air quality 

standards. 

Diseased Materials 

• Requires a conditional burn permit for fires set for the purpose diseased or pest 

prevention. 

• Requires certain specific conditions/determinations by the county agricultural 

commissioner confirming the presence of the disease and the effects of not 

allowing the burn in lieu of other disposal alternatives. 

Administrative Requirements 

• Specific procedures and conditions for burn permits, burn plans for fire 

suppression training, and contraband are detailed in the rule. 

How does District Rule 4103 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

District staff’s review of the EPA CTG list indicates that there is no CTG for open 

burning. 

B. EPA – Alternative Control Techniques (ACT) Document 

District staff’s review of the EPA ACT list indicates that there is no ACT for open 

burning. 

C. Standards of Performance for New Stationary Sources (NSPS) 

District staff’s review of 40 CFR 60 (Standards of Performance for New Sources) 

indicates that there is no NSPS for open burning. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

District staff’s review of 40 CFR 61 (NESHAP) and 40 CFR (NESHAP for Source 

Categories) indicates that there is no NESHAP or MACT for open burning. 
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How does District Rule 4103 compare to rules in other air districts?

District staff compared District Rule 4103 with the rules of other California ozone 

nonattainment air districts’ rules on open burning. The results of the analysis are 

discussed below. 

• South Coast Air Quality Management District, Rule 444 (Open Burning) amended 

December 21, 2001 

• Bay Area Air Quality Management District, Regulation 5 (Open Burning) amended 

November 2, 1994 

• Sacramento Metropolitan Air Quality Management Air District, Rule 407 (Open 

Burning) amended June 4, 1998 

• Ventura County Air Pollution Control District) Rule 56 (Open Burning) amended 

November 11, 2003 

A. South Coast AQMD Rule 444 (Open Burning) 

SCAQMD Rule 444 applies to open burning of agricultural waste, disposal of Russian 

thistle, prescribed burning, fire prevention/suppression training, open detonation or use 

of pyrotechnics, fire hazard, disposal of infectious wastes (other than hospital waste), 

research and testing materials equipment or techniques, disposal of contraband, and 

residential burning. 

SCAQMD Rule 444 prohibits open burning unless: 

• The executive officer has declared the day as a permissive burn day and such 

burning is not prohibited by a public fire protection agency. 

• A written permit and an authorization are obtained from the executive for each day 

for each open burning. 

SCAQMD Rule 444 allows open burning for: 

• Agricultural burning; 

• Prescribed burning; 

• Disposal of Russian thistle; 

• Fire hazard abatement that a fire protection agency determines cannot be abated by 

any viable option; 

• Disposal of waste infected with agricultural pest or disease and ordered by the 

county agricultural commissioner; 

• Disposal of infectious waste (other than hospital waste) ordered by the county health 

officer; 

• Use of pyrotechnics for creation of special effects in motion pictures, etc.; 

• Disposal of contraband in the possession of law enforcement personnel provided 

burning is the only available reasonable method for safe disposal; and 

• Fire prevention training; and researching and testing fire retardant properties of 

materials, etc. 

SCAQMD Rule 444 prohibits open burning for 

• Residential burning; 
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• Disposal of waste except as mentioned above; 

• Materials generated as a result of land use conversion for non-agricultural purposes; 

• Disposal of materials from the production or storage of military ordnance, etc.; and 

• Wildland suppression fires except those set by fire protection agencies to save life 

and property. 

SCAQMD Rule 444 requires open burning to comply with the following: 

• Agricultural field crop burning must commence before 10:00 AM or later than 5:00 

PM; 

• Open burning other than field crop burning must not commence earlier than one 

hour after sunrise with no new ignition, or fuels to be added to an existing fire, later 

than two hours before sunset except as authorized at a time consistent with an 

approved smoke management plan; 

• Use only approved ignition device 

• Prior to burning, agricultural waste must be allowed to dry for a specified time as 

detailed in the rule; 

• Agricultural waste must be free of dirt, soil and visible moisture; and 

• Ignite rice, barley, oat, and wheat straw only by strip-firing or backfiring into the wind 

unless fire protection agency declares such actions would constitute a fire hazard. 

SCAQMD Rule 444 specifies that the executive officer may allow the certain specified 

maximum daily burn acreage for agricultural burning and prescribed burning as follows: 

• Except for Coachella Valley, 150 acres for prescribed wildland and range burning, 

and150 acres for agricultural burning. 

• Fro Coachella Valley, 5 acres for prescribed wildland and range burning and 35 

acres for agricultural burning. 

• The above restrictions do not apply to prescribed burning when a land manger 

demonstrates that it is required to reduce fire hazard that jeopardized public health 

and safety and a satisfactory smoke management plan is submitted and approved 

by the air district. 

SCAQMD Rule 444 exempts the following; 

• Wildfire suppression ignited to save life and valuable property conducted by fire 

protection agency. 

• Fire prevention/suppression training, except for the burning of existing structure, 

conducted by fire protection agency for no more than 30 minutes. Training 

involving burning of existing structure is exempt provided each training is no 

more than 30 minutes. 

• Burning of Russian thistle is exempt from having to get authorization from the 

district. 

• Recreational fires or ceremonial fires. 

• Open burning of natural gas, propane, untreated wood, or charcoal for the 

purpose of preparation or warming of food for human consumption or generating 

warmth for social gathering. 

• Open burning located on islands 15 miles or more from the mainland coast. 
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• Fireworks displays or pyrotechnics used for the creation of special effects at 

theme parks. 

• Detonation of explosives during quarry mining operations, bomb disposal by law 

enforcement agency, or demolition of buildings or structures. 

• Pyrotechnics, detonation of explosives, or fire effects for creation of special 

effects during theatrical productions, filming of motion pictures, videotaping of 

television programs or other commercial filming or video production activities 

must not be more than 30 minutes in duration. 

SCAQMD Rule 444 applies to a variety of open burning activities which includes 

prescribed burning and hazard reduction burning which are not regulated by District 

Rule 4103, but are regulated by District 4106 (Prescribe Burning and Hazard Reduction 

Burning). 

Overall, District Rule 4103 is more stringent than SCAQMD Rule 444 for the following 

major reasons: 

• District Rule 4103 prohibits open burning of almost all agricultural wastes, except 

prunings from apples crops, pears crops, fig crops, and quince crops, as well as 

weed abatement activities affecting waterways for which open burning is allowed 

until June 1, 2010. District Rule 4103 allows open burning of orchard removal from 

citrus, apple, pear, quince, fig crops and orchard removal of up to 20 acres per 

location per calendar year until June 1, 2010, the burning of rice straw until June 1, 

2015. Rule amendment project for 2009 would implement Phase IV of the state 

Health and Safety Code will address prohibition of burning of surface harvested 

crops prunings (almond, walnut, pecan and grape vines), vineyard removal, vineyard 

materials (grape canes and raisin trays), and other materials (brooder paper, 

diseased goats, and diseased beehives). SCAQMD Rule 444 allows open burning 

of agricultural waste. 

• District Rule 4103 requires the use of at least one best management practice 

specified in the rule (other practice approved by the APCO) for the control of certain 

type of weeds located along ditch banks or canal banks, and the disposal of 

pesticide sacks or fertilizer sacks. SCAQMD Rule 444 has no similar restrictions for 

burning weeds. 

• Prohibits transporting contraband confiscated outside the District for disposal by 

burning within the District. Only contraband confiscated within the San Joaquin 

Valley air basin may be disposed off by burning. SCAQMD Rule 444 allows burning 

of contraband in the possession of law enforcement personnel regardless of where 

the contraband originated. 

• District Rule 4103 does not allow open burning that will create a nuisance as defined 

in Section 41700 of the state Health and Safety Code, but SCAQMD Rule 444 does 

not specify such restriction. 

Based on the above discussion, District staff deems that District Rule 4103 is more 

stringent than SCAQMD Rule 444. 
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B. Bay Area AQMD Regulation 5 (Open Burning) 

BAAQMD Regulation 5 applies to open burning of agricultural waste, range 

management, forest management, and wildland management. The rule prohibits a 

person from igniting, causing to ignite, permit to be ignited, or suffer, allow, or maintain 

fires within the district. No burning should take place in the district on other than a 

permissive burn day. 

BAAQMD Regulation 5 allows the following fires on permissive burn days: 

• Disease and pests prevention; 

• Crop replacement; 

• Orchard pruning and attrition; 

• Double cropping stubble; 

• Hazardous materials (prevention or reduction of fire hazard, disposal of dangerous 

materials); 

• Fire training; 

• Flood debris; 

• Control growth of vegetation from irrigation ditches and canals; 

• Disposal of material which is lying or growing within natural channels or flood control 

channels; 

• Fires set for the purpose of range management and grazing; 

• Fires set for the purpose of removing forest debris and for forest management; 

• Fires set for the purpose of improvement of lowland and marsh for wildlife and game 

habitat; 

• Fires set for the purpose of disposing contraband; 

• Prescribed burning by state or federal agency, or through cooperative agreement or 

contract involving state or federal agency. 

• Fires set as part of commercial film or video production activities for motion picture 

and television. 

• Fires set as part of a planned civic event designed to educate or otherwise benefit 

the public. 

BAAQMD Regulation 5 requires that any person conducting open burning that is 

allowed by the rules must also comply with the following: 

• No burning should take place before sunrise. 

• No additional materials or fuel should be ignited nor should any material or fuel be 

added to any fire after two hours before sunset. 

• No material or fuel should be ignited nor should any material or fuel be added to any 

fire when the wind velocity is less than 5 miles per hour except for certain conditions 

specified in the rule. 

• The material should be dried for a minimum of 60 days prior to ignition. 

• All material to be burned should be reasonably free from dirt or soil. 

• Piled material should be limited to 25 square yards base area and the height should 

be at least 2/3 of the average width of the pile. 

• Ignition material should be limited to those listed by the state director of forestry. 
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• Ignition should be started at or near the top of the piled material. 

• Tonnage, volume or acreage of material burned on any given day at any given site is 

subject to limitations set by the APCO, but may not exceed any limits set by ARB. 

BAAQMD Regulation 5 requires the submission of burn plan and the APCO’s approval 

prior to burning. The rule specify the requirements that must be met when burning of 

propellants, explosives, pyrotechnics, disease and pests, fire training, flood control, 

irrigation ditches, range management, hazardous materials, and contraband as wells 

prescribed burning, filmmaking petition. The rule also includes recordkeeping and 

monitoring requirements. 

BAAQMD Regulation 5 exempts fires set for cooking food for human consumption; fires 

set for recreational purposes using only clean dried wood or charcoal, and small amount 

of fire starter; fires burning as safety flares or for combustion of waste gases; use of 

flame cultivation using only LPG or natural gas fired burners designed and used to kill 

seedling grass and weeds in orchards, vineyards and field crops and the growth is such 

that the combustion will continue without the burner; and fires set for training purposes 

using one gallon or less of flammable liquid per fire.. 

BAAQMD Regulation 5 applies to a variety of open burning activities which includes 

prescribed burning and hazard reduction burning which are not regulated by District 

Rule 4103, but are regulated by District 4106 (Prescribe Burning and Hazard Reduction 

Burning). 

Overall, District Rule 4103 is more stringent than BAAQMD Regulation 5 for the 

following major reasons: 

• District Rule 4103 prohibits open burning of almost all agricultural wastes, except 

prunings from apples crops, pears crops, fig crops, and quince crops, as well as 

weed abatement activities affecting waterways for which open burning is allowed 

until June 1, 2010. District Rule 4103 allows open burning of orchard removal from 

citrus, apple, pear, quince, fig crops and orchard removal of up to 20 acres per 

location per calendar year until June 1, 2010, the burning of rice straw until June 1, 

2015. Rule amendment project for 2009 would implement Phase IV of the state 

Health and Safety Code will address prohibition of burning of surface harvested 

crops prunings (almond, walnut, pecan and grape vines), vineyard removal, vineyard 

materials (grape canes and raisin trays), and other materials (brooder paper, 

diseased goats, and diseased beehives). BAAQMD Regulation 5 allows open 

burning of agricultural waste. 

• BAAQMD Regulation 5 exempts use of flame cultivation using only LPG or natural 

gas fired burners designed and used to kill seedling grass and weeds in orchards, 

vineyards and field crops and the growth is such that the combustion will continue 

without the burner, but District Rule has no similar exemption. 

• District Rule 4103 requires the use of at least one best management practice 

specified in the rule (other practice approved by the APCO) for the control of certain 

type of weeds located along ditch banks or canal banks, and the disposal of 
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pesticide sacks or fertilizer sacks. BAAQMD Regulation 5 has no similar restrictions 

for burning weeds. 

• District Rule 4103 prohibits transporting contraband confiscated outside the District 

for disposal by burning within the District. Only contraband confiscated within the 

San Joaquin Valley air basin may be disposed off by burning. BAAQMD Regulation 

5 allows burning of contraband in the possession of law enforcement personnel 

regardless of where the contraband originated. 

• BAAQMD Regulation 5 regulates range management, forest management, and 

wildland management which are not regulated by District Rule 4103 but are 

regulated by District 4106 (Prescribe Burning and Hazard Reduction Burning). 

Based on the above discussion, District staff deems that District Rule 4103 is more 

stringent than BAAQMD Regulation 5. 

C. Sac Metro AQMD Rule 407 (Open Burning) 

SMAQMD) Rule 407 applies to non-agricultural open outdoor fires. Agricultural burning 

is regulated under SMAQMD Rule 501 (Agricultural Burning). 

SMAQMD) Rule 407 prohibits the following: 

• Burning of petroleum waste, demolition waste, tires, trees, wood waste, or other 

combustible or flammable solid or liquid waste, motor vehicle bodies, materials for 

the purpose of metal salvage, putrescible materials, bedding, asphaltic products, or 

rubber products. 

• Burning or allowing to be burned, or maintaining any open outdoor fire for the 

purpose of burning refuse or organic waste on an agricultural no-burn day. 

• Burning or allowing to be burned, or maintaining any open outdoor fire for the 

purpose of burning refuse or organic waste at any time at certain locations specific in 

the rule. 

Overall, District Rule 4103 is more stringent than SMAQMD Rule 407 for the following 

major reasons: 

• Unlike District Rule 4103, SMAQMD Rule 407 does not require submission of burn 

plans or obtaining burn permits prior to burning the materials. 

• Unlike District Rule 4103, SMAQMD Rule 407 does not allocate burning based on 

the predicted meteorological conditions and whether it would cause nuisance, 

impact smoke sensitive areas, or create or contribute to an exceedance of the 

ambient air quality standard. 

• Unlike District Rule 4103, SMAQMD Rule 407 does not restrict the time of day when 

burns are ignited and conducted. 

• Unlike District Rule 4103, SMAQMD Rule 407 does not require the use of at least 

one best management practice for the control of certain type of weeds located along 

ditch banks or canal banks. 

Based on the above discussion, District staff deems that District Rule 4103 is more 

stringent than SMAQMD Rule 407. 
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D. Sac Metro AQMD Rule 501 (Agricultural Burning) 

SMAQMD Rule 501 regulates agricultural burning. Agricultural burning is defined in the 

rule as open outdoor fires to dispose agribusiness waste, agribusiness-related waste, 

forest management, range improvement, improvement of land for wildlife and game 

habitat, prevention of disease or pests, irrigation system management, wild land 

vegetation management, or disposal of empty paper containers of agricultural 

chemicals. 

SMAQMD Rule 501 prohibits igniting, conducting, or allowing agricultural burning on a 

no-burn day, except as when the designated agency determines that denial of burn 

permission would pose imminent and substantial economic loss and the designated 

agency approves or conditionally approves a special permit authorizing such burning on 

a no-burn day. The authorization to burn during no-burn day will limit the amount of 

acreage that may be burned in any one day and when the downwind populated areas 

are forecast by the district or designated agent to achieve the state and federal ambient 

air quality standards. 

SMAQMD Rule 501 requires obtaining a burning permit prior to igniting, conducting, or 

allowing agricultural burning. The rule prohibits the burning of material that is not clearly 

described in the authorized burn permit. An approved burn permit is not valid for any 

time when agricultural burning is prohibited by either the State Board or the APCO or 

has been restricted by the APCO. A permit holder or any other person is not exempt 

from any fire control or prevention statute or regulation, or if burning is prohibited by a 

public fire control agency. 

SMAQMD Rule 501 specifies the following standards for all agricultural burning: 

• The acreage shall not exceed should not exceed the acreage allotment determined 

pursuant to the agricultural Burning Plan. 

• The APCO may restrict agricultural burning to less than the State-allotted acreage or 

may declare a no-burn day in all or in part of the district depending on 

meteorological conditions that would cause undue emissions to be transported to a 

sensitive receptor or populated areas or cause a nuisance. 

• No agricultural burning will be conducted when the wind direction is such that smoke 

from the burn will cause or does cause a nuisance. 

• Contact the designated agency or fire protection agency having jurisdiction over the 

burn location prior to the burn, on the same day as the burn. 

• Ignite using an approved ignition device. Other ignition methods may be authorized 

by special permit when and where the fire protection agency has declared that an 

extreme fire hazard exists or where the designated agency has determined that 

crops do not lend itself to strip-firing or backfiring 

• For field crop stubble, ignite by strip-firing into the wind or backfiring. 

• Specifies the allowable ignition hours. 

• Specifies materials that are prohibited to be burned as part of any type of agricultural 

burning. 
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• Requires agricultural waste to be arranged to burn with minimum of smoke. 

• Requires a minimum drying time prior to burning agricultural waste. 

• Requires a mechanical rice straw spreader to be used in rice harvesting to ensure 

even distribution of the straw, but rice straw may be left in rows provided it meets the 

specified drying time prior to being burned. 

• Except for rice straw acreage that was harvested prior to September 10, prohibits 

burning of field crop acreage during October 1 through November 15 of each year, 

unless a special permit is approved. 

• Prohibits agricultural burning in the certain boundary in the northwest Sacramento 

area if the APCO or fire protection agency predicts that winds will be from the 

direction within 90 degrees of true north. The exception is if the burning is 

necessary to preclude hazards on public thoroughfares or at airports due to smoke 

or can be performed without causing a nuisance. 

• Burn only agribusiness waste or agribusiness-related waste that is reasonably free 

of excessive dirt, soil, and visible moisture. 

• Agricultural burning must occur where the material being burned was grown or 

raised, or in the case of agribusiness-related waste, used. 

• Specifies certain standards for forest management burning, range improvement 

burning, irrigation system management, wildland vegetation management burning, 

and burning of empty paper containers of agricultural chemicals. 

• Specify administrative requirements for permit application information, approval of 

burning permits, permit statement, advance notice request, and suspension or 

revocation of approved permit. 

Overall, District Rule 4103 is more stringent than SMAQMD Rule 501 for the following 

major reasons: 

• District Rule 4103 prohibits open burning of almost all agricultural wastes, except 

prunings from apples crops, pears crops, fig crops, and quince crops, as well as 

weed abatement activities affecting waterways for which open burning is allowed 

until June 1, 2010. District Rule 4103 allows open burning of orchard removal from 

citrus, apple, pear, quince, fig crops and orchard removal of up to 20 acres per 

location per calendar year until June 1, 2010, the burning of rice straw until June 1, 

2015. SMAQMD Rule 501 allows open burning of agricultural waste.

• SMAQMD Rule 501 regulates forest management burning, range improvement 

burning, wildlife and game habitat which are not regulated by District Rule 4103 but 

are regulated by District 4106 (Prescribe Burning and Hazard Reduction Burning). 

• Unlike District Rule 4103, SMAQMD Rule 407 does not require the use of at least 

one best management practice for the control of certain type of weeds located along 

ditch banks or canal banks. 

Based on the above discussion, District staff deems that District Rule 4103 is more 

stringent than SMAQMD Rule 501. 
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E. Ventura County APCD Rule 56 (Open Burning) 

VCAPCD Rule 56 applies to the burning of combustible materials in open outdoor fires. 

The rule allows open burning provided the following requirements are met: 

• A valid burn permit must be obtained prior to burning. 

• Open burning is allowed only on days declared to be Burn Days by the APCO. 

• Open burning is allowed for disposal of agricultural waste in the pursuit of 

agricultural operations, range improvement, wildland vegetation management, levee, 

reservoir or ditch maintenance, and disposal of Russian thistle. 

• Burn only plant material that grew on property where the burn is conducted, or on 

another property of the same grower if approved by APCO. 

• Material to be burned should be reasonably free from dirt, soil and visible moisture. 

• Material to be burned should sufficiently dry (except for prescribed burning) for the 

minimum time period specified in the rule. 

• Material to be burned should be stacked or arranged to allow maximum air 

circulation to minimize smoke during combustion. 

• Use only ignition device approved by the APCO or the fire protection agency, and 

should be ignited as rapidly as practicable within fire control restrictions. 

• Conduct open burning when wind speed and direction will not carry emissions into 

smoke sensitive areas. 

• Conduct burning during time periods specified in the rule. 

• The amount, timing, and location of all open burning will be restricted by the district 

to minimize smoke impacts on smoke sensitive areas. 

VCAPCD Rule 56 includes specific requirements for prescribed burning and range 

improvement burning. Among other things, range improvement burning requires a 

statement from the Department of Fish and Game certifying that burning is desirable 

and proper. For prescribed burning, the land manger should submit a smoke 

management plan that includes specific information detailed in the rule for review and 

approval by the district. Additionally, for prescribed burning, the land manager should 

register all planned burn projects annually or seasonally to the district. 

VCAPCD Rule 56 exempts outdoor fires for the following purposes: 

• Heating or cooking food for human consumption or for recreational purposes. 

• Burning of unserviceable American flag. 

• Fires authorized public officer to prevent fire hazard, training in the methods of 

fighting fires, etc. 

• Setting of backfires to save life or valuable property. 

• Abatement of fire hazards. 

• Disease or pest prevention. 

• Remediation of oil spill. 

Overall, District Rule 4103 is more stringent than VCAPCD Rule 56 for the following 

major reasons: 
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• District Rule 4103 prohibits open burning of almost all agricultural wastes, except 

prunings from apples crops, pears crops, fig crops, and quince crops, as well as 

weed abatement activities affecting waterways for which open burning is allowed 

until June 1, 2010. District Rule 4103 allows open burning of orchard removal from 

citrus, apple, pear, quince, fig crops and orchard removal of up to 20 acres per 

location per calendar year until June 1, 2010, the burning of rice straw until June 1, 

2015. VCAPCD Rule 56 allows open burning of any agricultural waste.

• VCAPCD Rule 56 regulates range improvement burning, wildlife and game habitat 

and prescribed burning which are not regulated by District Rule 4103 but are 

regulated by District 4106 (Prescribe Burning and Hazard Reduction Burning). 

• Unlike District Rule 4103, VCAPCD Rule 56 does not require the use of at least one 

best management practice for the control of certain type of weeds located along 

ditch banks or canal banks. 

Conclusion

There are no federal rules and regulations that apply to open burning. After careful 

evaluation the prohibitory rules in other California nonattainment areas, District staff 

concludes that District Rule 4103 satisfies RACT for open burning. 
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Rule 4104 (Reduction of Animal Matter) 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx NQ NQ NQ NQ NQ NQ NQ NQ 

VOC NQ NQ NQ NQ NQ NQ NQ NQ 

(Source: District 2007 Ozone Plan) 

District Rule 4104 Description

Rule 4104 applies to source operations used for the reduction of animal matter which 

involves any heated process, including rendering, cooking, drying, dehydration, 

digesting, evaporating, and protein concentration. The rule prohibits operation of any 

machine/equipment used in reduction of animal matter unless all gases, vapors, and 

gas-entrained effluent are incinerated at a temperature of at least 1200o

F for a period of 

not less than 0.3 seconds, or processed in a manner that is equally or more effective as 

determined by the APCO. 

How does District Rule 4407compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

District staff’s review of the EPA CTG list indicates that there is no CTG for reduction of 

animal matter. 

B. EPA – Alternative Control Techniques (ACT) Document 

District staff’s review of the EPA ACT list indicates that there is no ACT for reduction of 

animal matter. 

C. Standards of Performance for New Stationary Sources (NSPS) 

40 CFR 60 (Standards of Performance for New Sources) does not specify any NSPS for 

reduction of animal matter. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

40 CFR 61 (NESHAP) and 40 CFR (NESHAP for Source Categories) do not specify any 

NSPS for reduction of animal matter. 
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How does District Rule 4104 compare to rules in other air districts?

District staff compared District Rule 4104 with the rules of other California ozone 

nonattainment air districts’ rules. The results of the analysis are discussed below. 

• South Coast Air Quality Management District (SCAQMD) Rule 472 (Reduction of 

Animal Matter) adopted May 7, 1976 

• Bay Area Air Quality Management District (BAAQMD) Regulation 12 Rule 2 

(Rendering Plants) adoption date not available 

• Sacramento Metropolitan Air Quality Management Air District, Rule 410 (Reduction 

of Animal Matter) amended August 3, 1977 

• Ventura County Air Pollution Control District Rule 58 ((Reduction of Animal Matter) 

amended May 23, 1972 

A. South Coast Air Quality Management District (SCAQMD) Rule 472 

(Reduction of Animal Matter) 

SCAQMD Rule 472 prohibits the operation or use of any equipment for the reduction of 

animal matter unless all gases, vapors, and gas entrained effluents from such 

equipment are incinerated at temperatures of not less than 650o C (1202o F for a period 

of not less than 0.3 second, or processed in such a manner that is determined by the 

APCO to be equally or more effective than the conditions stated above. 

District Rule 4104 requires an incineration temperature of 1200 o F compared to 

SCAQMD Rule 472 temperature of 1202 o F. However, District staff’s review of the 

District Permit database indicates that permitted incineration equipment such as thermal 

oxidizer requires a temperature of 1400 o F for a period of no less than one second. 

Based on the above discussion, District staff deems that District Rule 4401 is as 

stringent as SCAQMD Rule 1108. 

B. Bay Area Air Quality Management District (BAAQMD) Regulation 12 Rule 2 

(Rendering Plants) 

BAAQMD Regulation 12 Rule 2 requires the an incineration temperature 1202 o F and 

for a period of not less than 0.3 second, or processed in a manner which is equally or 

more effective for the purpose of air pollution odor control as determined by the APCO. 

District Rule 4104 requires an incineration temperature of 1200 oF compared to 

BAAQMD Rule 472 temperature of 1202 o F. However, District staff’s review of the 

District Permit database indicates that permitted incineration equipment such as thermal 

oxidizer requires a temperature of 1400 o F for a period of no less than one second. 

Based on the above discussion, District staff deems that District Rule 4104 is as 

stringent as BAAQMD Regulation 12 Rule 2. 
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C. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 

410 (Reduction of Animal Matter) 

SMAQMD Rule 410 requires the an incineration temperature 1202 o F and for a period 

of not less than 0.3 second, or processed in a manner which is equally or more 

effective for the purpose of air pollution control as determined by the APCO. 

District Rule 4104 requires an incineration temperature of 1200 o F compared to 

SMAQMD Rule 410 temperature of 1202 oF. However, District staff’s review of the 

District Permit database indicates that permitted incineration equipment such as thermal 

oxidizer requires a temperature of 1400 oF for a period of no less than one second. 

Based on the above discussion, District staff deems that District Rule 4104 is as 

stringent as SMAQMD Rule 410.

D. Ventura County Air Pollution Control District (VCAPCD) Rule 58 (Reduction 

of Animal Matter) 

VCAPCD Rule 58 requires the an incineration temperature 1300 o F for a period of not 

less than 0.4 second, or processed in a manner which is equally or more effective for 

the purpose of air pollution control as determined by the APCO. 

District Rule 4104 requires an incineration temperature of 1200 o F for a period of 0.3 

second compared to VCAPCD Rule 58 temperature of 1300 o F for a period of not less 

than 0.4 second. However, District staff’s review of the District Permit database 

indicates that permitted incineration equipment such as thermal oxidizer requires a 

temperature of 1400 o F for a period of no less than one second. Based on the above 

discussion, District staff deems that District Rule 4104 as stringent as stringent as 

VCAPCD Rule 58.

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4104 

satisfies RACT for reduction of animal matter. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

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Rule 4106 – Prescribed Burning and Hazard Reduction Burning

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 3.41 3.40 3.39 3.38 3.38 3.36 3.34 3.32 

VOC 7.85 7.82 7.79 7.78 7.76 7.72 7.68 7.63 

(Source: District 2007 Ozone Plan) 

District Rule 4106 Description

District Rule 4106 applies to prescribed burning and hazard reduction burning 

conducted within the San Joaquin Valley Air Basin. The purpose of this rule is to 

permit, regulate, and coordinate the use of prescribed burning and hazard reduction 

burning while minimizing smoke impacts to the public. 

District Rule 4106 includes the following requirements and prohibitions 

General Requirements 

• Rule 4106 provides that regardless of the status of burn permits or burn plans, no 

prescribed or hazard reduction burning may occur at any location in the District 

unless it is within the allocation for the day for the region in which it is located and 

the burning has been authorized by the District. 

• The APCO will allocate burning based on the predicted meteorological conditions 

and whether it would cause nuisance, impact smoke sensitive areas, or create or 

contribute to an exceedance of the ambient air quality standard. 

• The APCO will restrict the time of day when burns are ignited and conducted. 

• No prescribed burning or hazard reduction burning will be permitted that will 

create nuisance as defined in the state Health and Safety Code. 

• All burning authorized pursuant to the rule shall be subject to any requirements, 

restrictions or prohibitions of the fire protection agency having jurisdiction over 

the burn site. 

Prescribed Burning 

• Ignition of a prescribed burn shall not occur on a no-burn day. 

• Rule 4106 provides that planned burn projects be submitted annually or 

seasonally for registration. The annual registration would have to include areas 

being considered for potential naturally ignited wildland fires managed for 

resource benefits. Rule 4106 also describes the information that must be 

included in the annual registration of prescribed burning projects and includes 

provisions related to plan review and approval. The District must approve or 

disapprove the plan and/or provide comments on the elements of the smoke 

management section within 30 days or it will be deemed adequate and approved 

as submitted. 
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• Requires that any person responsible for conducting a prescribed burn greater 

than ten acres in size or projected to emit more than one ton of particulate matter 

take a smoke management class approved by the APCO. 

• For a multi-day burn which may impact smoke sensitive areas, a land manager 

or his or her designee shall coordinate daily with the District or the ARB to affirm 

that the burn project remains within the conditions specified in the smoke 

management plan, or whether contingency plans must be implemented. 

Smoke Management Plans 

• Smoke Management Plans (SMPs) would be required for all prescribed burn 

projects. 

• SMPs require progressively more detail as the acreage and/or projected 

emissions get larger. 

• For projects less than 10 acres in size or projected to produce less than 1 ton of 

particulate matter a SMP must be submitted that includes: 

o A legal description of the burn, including maps, 

o A description of the type of fuels and the amount of fuels in tons or acres 

o The identity and mailing address of the responsible personnel, including 

telephone numbers for 24-hour contact. 

• For projects larger than 10 acres but less than 100 acres in size a SMP must 

also includes: 

o The distance and compass headings of smoke sensitive areas within five (5) 

miles including but not limited to schools, day care centers, hospitals, medical 

clinics, populated areas, highways. 

o A description of the wind speed and direction necessary for burning. 

o A description of the anticipated duration of project’s smoke production from 

ignition to burn down. 

• For projects larger than 100 acres but less than 250 acres in size a SMP must 

also include 

o A description of the meteorological conditions the land manager or his/her 

designee will use for making burn ignition decisions to limit smoke impacts to 

smoke sensitive areas. 

o A description of the smoke management criteria the land manager or his/her 

designee will use for making burn ignition decisions. 

o A description of the per acre fuel loading, including the fuel type, existing fuel 

loading in tons per acre, and anticipated fuel consumption. Describe the fuel 

expected to be consumed such as duff, fines, 1-, 10-, 100-, and/or 1000-hour 

fuels, live fuels, etc. 

o Identification of potential impacts to smoke sensitive areas as determined by 

mapping the daytime and nighttime smoke paths, including upslope and 

downslope and/or diurnal drainage flow, for a distance of twenty-five miles 

from the burn site. 

o Identification of the population located in the potential smoke sensitive areas. 

o A description of how the public will be informed of the possible effects of 

smoke and the duration of the effects. Include copies of public information 

planned for release. 
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o A description of the type and frequency of the surveillance and/or monitoring 

that will be conducted to determine any smoke impacts to smoke sensitive 

areas. 

o a description of the specific smoke contingency actions that will be taken in 

the event smoke impacts occur in smoke sensitive areas or meteorological 

conditions deviate from those specified in the smoke management plan. 

o a description of what post-burn Best Available Control Measures will be 

implemented to limit the duration of smoke impacts to smoke sensitive areas. 

• For projects larger than 250 acres in size a SMP must also include 

o A description of the surveillance and air monitoring methods. Monitoring may 

be visual monitoring, ambient particulate monitoring or other monitoring 

approved by the District. The type of monitoring required for a specific burn 

project shall be determined in consultation with the District and a description 

of the monitoring shall be included in the smoke management plan for that 

project. 

o A description of the surveillance and air monitoring methods. 

o A description of the smoke complaint handling procedures. 

o A description of the decision making process that will be used in 

implementing smoke mitigations procedures. 

o A description of the responsive impact mitigations up to and including a 

declaration of a wildfire and aggressive fire suppression. 

o A post-burn smoke management evaluation. 

Naturally Ignited Fires 

• Naturally ignited wildland fires occurring on a “no-burn” day shall not be allowed 

to continue as a prescribed burn unless, after consultation, the District decides, 

for smoke management purposes, that the burn can be managed for resource 

benefits. 

• If a naturally ignited wildland fire is allowed to continue for resource benefits, 

smoke management plans are required within 72 hours of the start of the fire. 

Hazard Reduction Burning 

• No person shall knowingly set or permit hazard reduction burning unless they 

have a valid Permit by the APCO or his designee. 

• No vegetation shall be burned unless it is described on a valid Permit. 

• The vegetation shall be in a condition that will facilitate combustion and minimize 

the amount of smoke emitted during combustion. 

• Vegetation to be burned shall be ignited only with an APCO approved ignition 

device. 

• Vegetation shall not be burned unless it is free of excessive dirt, soil, and 

moisture. 

• Vegetation shall not be burned unless it is arranged or loosely stacked in such a 

manner as to promote drying and insure combustion with a minimum of smoke 

production. 

• A Permit shall be valid only on those days during which burning is not prohibited 

by the ARB, by the District or by the designated agency having jurisdiction over 
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the site of the proposed burning pursuant to section 41855 of the California 

Health and Safety Code and the District has authorized the burning as being 

within the day’s burn system allocation for the region in which the burn site is 

located. 

How does District Rule 4106 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

District staff’s review of the EPA CTG list indicates that there is no CTG for prescribed 

burning or hazard reduction burning. 

B. EPA – Alternative Control Techniques (ACT) Document 

District staff’s review of the EPA ACT list indicates that there is no ACT for prescribed 

burning or hazard reduction burning. 

C. Standards of Performance for New Stationary Sources (NSPS) 

District staff’s review of 40 CFR 60 (Standards of Performance for New Sources) 

indicates that there is no NSPS for prescribed burning or hazard reduction burning. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

District staff’s review of 40 CFR 61 (NESHAP) and 40 CFR (NESHAP for Source 

Categories) indicates that there is no NESHAP or MACT for prescribed burning or 

hazard reduction burning. 

How does District Rule 4106 compare to rules in other air districts?

District staff compared District Rule 4106 with the rules of other California ozone 

nonattainment air districts’ rules on prescribed burning or hazard reduction burning. 

The results of the analysis are discussed below. 

• South Coast Air Quality Management District Rule 444 (Open Burning) amended 

December 21, 2001 

• Bay Area Air Quality Management District Regulation 5 (Open Burning) amended 

November 2, 1994 

• Sacramento Metropolitan Air Quality Management Air District Rule 501 (Agricultural 

Burning) amended April 3, 1997 

• Ventura County Air Pollution Control District) Rule 56 (Open Burning) amended 

November 11, 2003
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Chapter 4: Rule Analysis 

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A. South Coast AQMD Rule 444 (Open Burning) 

SCAQMD Rule 444 applies to open burning, burning of agricultural waste, disposal of 

Russian thistle, prescribed burning, fire prevention/suppression training, open 

detonation or use of pyrotechnics, fire hazard, disposal of infectious wastes (other than 

hospital waste), research and testing materials equipment or techniques, disposal of 

contraband, and residential burning. 

SCAQMD Rule 444 prohibits open burning unless: 

• The executive officer has declared the day as a permissive burn day and such 

burning is not prohibited by a public fire protection agency. 

• A written permit and an authorization are obtained from the executive for each day of 

prescribed burning or hazard reduction burning. 

SCAQMD Rule 444 allows open burning for: 

• Agricultural burning; 

• Prescribed burning; 

• Disposal of Russian thistle; 

• Fire hazard abatement that a fire protection agency determines cannot be abated by 

any viable option; 

• Disposal of waste infected with agricultural pest or disease and ordered by the 

county agricultural commissioner; 

• Disposal of infectious waste (other than hospital waste) ordered by the county health 

officer; 

• Use of pyrotechnics for creation of special effects in motion pictures, etc.; 

• Disposal of contraband in the possession of law enforcement personnel provided 

burning is the only available reasonable method for safe disposal; and 

• Fire prevention training; and researching and testing fire retardant properties of 

materials, etc. 

SCAQMD Rule 444 prohibits open burning for 

• Residential burning; 

• Disposal of waste except as mentioned above; 

• Materials generated as a result of land use conversion for non-agricultural purposes; 

• Disposal of materials from the production or storage of military ordnance, etc.; and 

• Wildland suppression fires except those set by fire protection agencies to save life 

and property. 

SCAQMD Rule 444 requires prescribed burning or hazard reduction burning to comply 

with the following: 

• Prescribed burning shall not be conducted until a burn implementation plan is 

approved in writing by the Executive Officer. 

• A person shall conduct or allow prescribed burning only when the fires are set by, 

under the jurisdiction of, or pursuant to the orders or requirements of a fire protection 

agency. 
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• Prior to conducting or allowing prescribed burning for any project greater than 10 

acres or that produces more than one ton of particulate matter emissions, as 

determined using EPA AP-42 or equivalent emissions factors approved by the 

Executive Officer, CARB, and EPA, a person shall have a Smoke Management Plan 

approved in writing by the Executive Officer. At a minimum, the Smoke Management 

Plan shall contain the following information: 

o location, types, and amounts of material to be burned; 

o expected duration of the fire from ignition to extinction; 

o identification of responsible personnel, including telephone contacts; 

o identification and location of all smoke sensitive areas; and 

o where the particulate emissions tonnage is selected as the criteria for 

determining the project size, calculation of the particulate emissions tonnage. 

• Prior to conducting or allowing prescribed burning for any project greater than 100 

acres or that produces more than 10 tons of particulate matter emissions, as 

determined using EPA AP-42 or equivalent emissions factors approved by the 

Executive Officer, CARB, and EPA, a person shall have a Smoke Management Plan 

approved in writing by the Executive Officer. At a minimum, the Smoke Management 

Plan shall contain the information required for 10-100 acre burns and the following 

information: 

o Identification of meteorological conditions necessary for burning 

o The smoke management criteria the land manager will use for making burn 

ignition decisions 

o Projections, including a map, of where the smoke from burns are expected to 

travel both day and night 

o Specific contingency actions (such as fire suppression or containment) that 

will be taken if smoke impacts occur or meteorological conditions deviate from 

those specified in the smoke management plan 

o An evaluation of and consideration of economically, and logistically viable 

alternatives to burning 

o Discussion of public notification procedures. 

• The Executive Officer shall prioritize burn authorization requests based upon: 

o the burner’s demonstrated level of training identified in the burn 

implementation and smoke management plans 

o the measures identified in the smoke management plan proposed to reduce 

emissions. 

• The Executive Officer may allow prescribed burning on marginal burn days provided 

a smoke management plan has been approved and the predicted daily maximum 

hourly average ozone concentration in the source receptor area of the prescribed 

burn meets the California 1-hour ozone standard. 

SCAQMD Rule 444 specifies that the executive officer may allow the certain specified 

maximum daily burn acreage for agricultural burning and prescribed burning as follows: 

• Except for Coachella Valley, 150 acres for prescribed wildland and range burning, 

and 150 acres for agricultural burning. 

• For Coachella Valley, 5 acres for prescribed wildland and range burning and 35 

acres for agricultural burning. 
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• The above restrictions do not apply to prescribed burning when a land manger 

demonstrates that it is required to reduce fire hazard that jeopardized public health 

and safety and a satisfactory smoke management plan is submitted and approved 

by the air district. 

SCAQMD Rule 444 exempts the following; 

• Wildfire suppression ignited to save life and valuable property conducted by fire 

protection agency. 

• Fire prevention/suppression training, except for the burning of existing structure, 

conducted by fire protection agency for no more than 30 minutes. Training 

involving burning of existing structure is exempt provided each training is no 

more than 30 minutes. 

• Burning of Russian thistle is exempt from having to get authorization from the 

district. 

• Recreational fires or ceremonial fires. 

• Open burning of natural gas, propane, untreated wood, or charcoal for the 

purpose of preparation or warming of food for human consumption or generating 

warmth for social gathering. 

• Open burning located on islands 15 miles or more from the mainland coast. 

• Fireworks displays or pyrotechnics used for the creation of special effects at 

theme parks. 

• Detonation of explosives during quarry mining operations, bomb disposal by law 

enforcement agency, or demolition of buildings or structures. 

• Pyrotechnics, detonation of explosives, or fire effects for creation of special 

effects during theatrical productions, filming of motion pictures, videotaping of 

television programs or other commercial filming or video production activities 

must not be more than 30 minutes in duration. 

SCAQMD Rule 444 applies to a variety of open burning activities which includes 

prescribed burning and hazard reduction burning which are not regulated by District 

Rule 4106, but are regulated by District 4103 (Open Burning). 

Overall, District Rule 4106 is more stringent than SCAQMD Rule 444 for the following 

major reasons: 

• District Rule 4106 requires SMPs for prescribed fires less than 10 acres. SCAQMD 

Rule 444 has no similar restrictions. 

• District Rule 4106 has SMP requirements for prescribed fires larger than 100 acres 

that SCAQMD Rule 444 does not, including: 

o A description of the per acre fuel loading 

o Identification of potential impacts to smoke sensitive areas for a distance of 

twenty-five miles from the burn site. 

o Identification of the population located in the potential smoke sensitive areas. 

o A description of how the public will be informed of the possible effects of smoke 

and the duration of the effects. Include copies of public information planned for 

release. 
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o A description of the type and frequency of the surveillance and/or monitoring that 

will be conducted to determine any smoke impacts to smoke sensitive areas. 

o a description of the specific smoke contingency actions that will be taken in the 

event smoke impacts occur in smoke sensitive areas or meteorological 

conditions deviate from those specified in the smoke management plan. 

o a description of what post-burn Best Available Control Measures will be 

implemented to limit the duration of smoke impacts to smoke sensitive areas 

• Rule 4106 provides that planned burn projects be submitted annually or seasonally 

for registration. The annual registration would have to include areas being 

considered for potential naturally ignited wildland fires managed for resource 

benefits. Rule 4106 also describes the information that must be included in the 

annual registration of prescribed burning projects and includes provisions related to 

plan review and approval. The District must approve or disapprove the plan and/or 

provide comments on the elements of the smoke management section within 30 

days or it will be deemed adequate and approved as submitted. SCAQMD Rule 444 

has no similar restrictions. 

• District Rule 4106 requires that any person responsible for conducting a prescribed 

burn greater than ten acres in size or projected to emit more than one ton of 

particulate matter take a smoke management class approved by the APCO. 

SCAQMD Rule 444 has no similar restrictions. 

• SCAQMD is more stringent than District Rule 4106 because it establishes maximum 

daily burn acreage for agricultural burning and prescribed burning. However, these 

limits can be if a land manger demonstrates that it is required to reduce fire hazard 

that jeopardized public health and safety and a satisfactory smoke management 

plan is submitted and approved by the air district. 

Based on the above discussion, District staff deems that additional SMP, planning, and 

training requirements in District Rule 4106 make it more stringent than SCAQMD Rule 

444. 

B. Bay Area AQMD Regulation 5 (Open Burning) 

BAAQMD Regulation 5 applies to open burning of agricultural waste, range 

management, forest management, and wildland management. The rule prohibits a 

person from igniting, causing to ignite, permit to be ignited, or suffer, allow, or maintain 

fires within the district. No burning should take place in the district on other than a 

permissive burn day. 

BAAQMD Regulation 5 allows the following fires on permissive burn days: 

• Disease and pests prevention; 

• Crop replacement; 

• Orchard pruning and attrition; 

• Double cropping stubble; 

• Hazardous materials (prevention or reduction of fire hazard, disposal of dangerous 

materials); 

• Fire training; 
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• Flood debris; 

• Control growth of vegetation from irrigation ditches and canals; 

• Disposal of material which is lying or growing within natural channels or flood control 

channels; 

• Fires set for the purpose of range management and grazing; 

• Fires set for the purpose of removing forest debris and for forest management; 

• Fires set for the purpose of improvement of lowland and marsh for wildlife and game 

habitat; 

• Fires set for the purpose of disposing contraband; 

• Prescribed burning by state or federal agency, or through cooperative agreement or 

contract involving state or federal agency. 

• Fires set as part of commercial film or video production activities for motion picture 

and television. 

• Fires set as part of a planned civic event designed to educate or otherwise benefit 

the public. 

BAAQMD Regulation 5 requires that any person conducting prescribed burning that is 

allowed by the rules must also comply with the following: 

o Effective June 1, 2002, fires may not be conducted on other than a permissive burn 

day. 

o A smoke management plan must be submitted to the APCO for review at least 30 

calendar days prior to the proposed burning that is consistent with the most current 

USEPA guidance on wildland and prescribed fires (Interim Air Quality Policy on 

Wildland and Prescribed Fires, USEPA 1998, or any subsequent document that 

supersedes this document), and provides the following information: 

o Location and specific objectives of each proposed burn 

o Acreage, tonnage, type, and arrangement of vegetation to be burned 

o Directions and distances to nearby sensitive receptor areas 

o Fuel condition, combustion and meteorological prescription elements for the 

project 

o projected burn schedule and expected duration of project ignition, combustion, 

and burn down (hours or days) 

o specifications for monitoring and of verifying critical parameters 

o including meteorological conditions and smoke behavior before and during the 

burn 

o specifications for disseminating project information to public 

o contingency actions that will be taken during the burn to reduce exposure if 

smoke intrusions impact any sensitive receptor area 

o certification by a qualified professional resource ecologist, biologist, or forester 

that the proposed burning is necessary to achieve the specific management 

objective(s) of the plan 

o a copy of the environmental impact analysis prepared for the plan that includes 

an evaluation of alternatives to burning, if such an analysis was required by state 

or federal law or statute 

o project fuel loading estimate (tons vegetation/acre) by vegetation 

o type(s) and a description of the calculation method 
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o particulate matter emissions estimate including referenced emission factor(s) and 

a description of the calculation method used 

o Permission to burn shall be governed by the acreage burning allocation issued by 

the APCO. 

o For each day on which burning occurs, report the total acreage and tonnage of 

vegetation actually burned to the APCO by telephone no later than 12:00 p.m. local 

time the following day. 

o Within 30 calendar days following completion of the burn project, provide a written 

post-burn evaluation to the APCO that addresses whether the project objectives 

were met and describes actual smoke behavior. 

o Any fire official seeking to conduct prescribed burning in a geographical area 

considered for a potential naturally-ignited wildland fire managed for resource 

benefits that is expected to exceed 10 acres in size shall annually register each burn 

project in writing with the APCO by December 31 each year, with updates as they 

occur. Once a decision is made to manage the fire for resource benefits, the fire 

official shall provide a smoke management plan for the burn project to the APCO, 

upon request. 

BAAQMD Regulation 5 requires that any person conducting hazard reduction burning 

that is allowed by the rules must also comply with the following: 

• The person setting the fire shall provide electronic, typewritten, legibly handwritten, 

or computer printed notification to the District prior to the burn on a District-approved 

form or facsimile thereof. 

• The fire must be set or allowed by any public fire official having jurisdiction, in the 

performance of official duty. 

• The fire must, in the opinion of such officer, be necessary, and the fire hazard not 

able to be abated by any other means. 

• No fires involving piled material shall be ignited or take place before 9:30 a.m. local 

time on any day. 

BAAQMD Regulation 5 applies to a variety of open burning activities which includes 

activities which are not regulated by District Rule 4106, but are regulated by District 

Rule 4103 (Open Burning). 

Overall, District Rule 4106 is more stringent than BAAQMD Regulation 5 for the 

following major reasons: 

• District Rule 4106 requires that no person shall knowingly set or permit hazard 

reduction burning unless they have a valid Permit by the APCO or his designee. 

BAAQMD Regulation 5 requires that the person setting the fire notify the District of a 

pending burn and keep a personal record of burning activities. 

• Ignition of a prescribed burn shall not occur on a no-burn day under District Rule 

4106. BAAQMD Regulation 5 contains no such restrictions. 

• District Rule 4106 requires that any person responsible for conducting a prescribed 

burn greater than ten acres in size or projected to emit more than one ton of 

particulate matter take a smoke management class approved by the APCO. 

BAAQMD Regulation 5 has no similar requirement. 
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4-34 

• BAAQMD Regulation 5 has the same requirements for all Smoke Management 

Plans, regardless of fire size. For smaller fires (less than 100 acres) Regulation 5’s 

SMP requirements are stricter than District Rule 4106. However, for larger fires 

(over 100 acres) District Rule 4106 has more stringent requirements for SMPs. 

Based on the above discussion, District staff deems that District Rule 4106 is overall 

more stringent than BAAQMD Regulation 5. 

C. Sac Metro AQMD Rule 501 (Agricultural Burning) 

SMAQMD Rule 501 applies agricultural open outdoor fires. Non-agricultural burning is 

regulated under SMAQMD Rule 407 (Open Burning). 

SMAQMD Rule 501 prohibits the following: 

• Burning of petroleum waste, demolition waste, tires, trees, wood waste, or other 

combustible or flammable solid or liquid waste, motor vehicle bodies, materials for 

the purpose of metal salvage, putrescible materials, bedding, asphaltic products, or 

rubber products. 

• Burning or allowing to be burned, or maintaining any open outdoor fire for the 

purpose of burning refuse or organic waste on an agricultural no-burn day. 

• Burning or allowing to be burned, or maintaining any open outdoor fire for the 

purpose of burning refuse or organic waste at any time at certain locations specific in 

the rule. 

SMAQMD Rule 501 contains the following specific standards for prescribed burning: 

o Vegetation to be burned shall be in a condition that will facilitate combustion and 

minimize the amount of smoke emitted during combustion. 

o For wild land vegetation management burning projects exceeding 10 acres in size, 

the following information—in addition to the information set forth in the burning 

permit application —shall be provided to the designated agency for review and 

approval 30 days in advance of the proposed burning: 

o The location and specific objectives of the burn project 

o The acreage or tonnage, type and arrangement of wild land vegetation to be 

burned 

o The directions and distances to nearby sensitive receptor areas 

o The fuel condition, combustion, and meteorological prescription elements 

developed for the burn 

o The projected schedule and duration of project ignition, combustion, and burn 

down 

o The specifications for monitoring and verifying critical project parameters 

o The specifications for disseminating project information—i.e., notification of the 

public, the designated agency, the fire protection agency having jurisdiction, and 

other affected agencies of the time, date, location, and acreage of the proposed 

burn. 
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Overall, District Rule 4106 is more stringent than SMAQMD Rule 501 for the following 

major reasons: 

• District Rule 4106 prohibits prescribed burning or hazard reduction burning of almost 

all agricultural wastes, except prunings from apples crops, pears crops, fig crops, 

and quince crops, as well as weed abatement activities affecting waterways for 

which prescribed burning or hazard reduction burning is allowed until June 1, 2010. 

District Rule 4106 allows prescribed burning or hazard reduction burning of orchard 

removal from citrus, apple, pear, quince, fig crops and orchard removal of up to 20 

acres per location per calendar year until June 1, 2010, the burning of rice straw until 

June 1, 2015. SMAQMD Rule 501 allows prescribed burning or hazard reduction 

burning of agricultural waste.

• Unlike District Rule 4106, SMAQMD Rule 501 does not require submission of burn 

plans or obtaining burn permits prior to igniting a hazard reduction burn. 

• Unlike District Rule 4106, SMAQMD Rule 501 does not allocate burning based on 

the predicted meteorological conditions and whether it would cause nuisance, 

impact smoke sensitive areas, or create or contribute to an exceedance of the 

ambient air quality standard. 

• Unlike District Rule 4106, SMAQMD Rule 501 does not restrict the time of day when 

burns are ignited and conducted. 

• Unlike District Rule 4106, SMAQMD Rule 501 does not require Smoke Management 

Plans for burns less than 10 acres. 

• Unlike District Rule 4106, SMAQMD Rule 501 does not have more stringent Smoke 

Management Plan requirements for burns over 100 acres. 

Based on the above discussion, District staff deems that District Rule 4106 is more 

stringent than SMAQMD Rule 501. 

D. Ventura County APCD Rule 56 (Open Burning) 

VCAPCD Rule 56 applies to the burning of combustible materials in open outdoor fires. 

The rule allows open burning provided the following requirements are met: 

• A valid burn permit must be obtained prior to burning. 

• Open burning is allowed only on days declared to be Burn Days by the APCO. 

• Open burning is allowed for disposal of agricultural waste in the pursuit of 

agricultural operations, range improvement, wildland vegetation management, levee, 

reservoir or ditch maintenance, and disposal of Russian thistle. 

• Burn only plant material that grew on property where the burn is conducted, or on 

another property of the same grower if approved by APCO. 

• Material to be burned should be reasonably free from dirt, soil and visible moisture. 

• Material to be burned should sufficiently dry (except for prescribed burning) for the 

minimum time period specified in the rule. 

• Material to be burned should be stacked or arranged to allow maximum air 

circulation to minimize smoke during combustion. 

• Use only ignition device approved by the APCO or the fire protection agency, and 

should be ignited as rapidly as practicable within fire control restrictions. 
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• Conduct open burning when wind speed and direction will not carry emissions into 

smoke sensitive areas. 

• Conduct burning during time periods specified in the rule. 

• The amount, timing, and location of all open burning will be restricted by the district 

to minimize smoke impacts on smoke sensitive areas. 

VCAPCD Rule 56 includes specific requirements for prescribed burning and range 

improvement burning, including: 

• The vegetation to be burned shall be in a condition that will facilitate combustion and 

minimize the amount of smoke emitted during combustion. 

• Burning at night and multi-day burns shall be minimized whenever practicable. 

• For range improvement burning conducted primarily for improvement of land for 

wildlife and game habitat, the applicant shall file with the APCD a statement from the 

Department of Fish and Game certifying that burning is desirable and proper. The 

Department of Fish and Game may specify the amount of brush treatment required, 

along with any other conditions it deems appropriate. 

• The land manager or his/her designee shall register all planned burn projects 

annually or seasonally with the APCD, including areas considered for potential 

naturally-ignited wildland fires managed for resource benefits, with updates as they 

occur. 

• The land manager or his/her designee must receive authorization to burn from the 

APCD the business day prior to burning. 

• Prior to ignition on the day of the burn, the land manager or his/her designee shall 

confirm with the APCD that all conditions and all requirements stated in the smoke 

management plan are met. 

• When a natural ignition occurs on a No Burn Day, the initial "go/no-go" decision by 

the land manager to manage the fire for resource benefit will be "no-go" unless, after 

consultation with the APCD or ARB, the APCD or ARB concurs, for smoke 

management purposes, that the burn can be managed for resource benefit. A "nogo" decision does not necessarily mean that the fire must be extinguished, but that 

the fire cannot be considered prescribed burning. 

• For naturally-ignited wildland fires managed for resource benefits that are expected 

to exceed 10 acres in size, the land manager or his/her designee shall submit a 

smoke management plan no later than 72 hours after the start of the fire. 

• For fires greater than 250 acres, the land manager or his/her designee, shall submit 

a post-burn smoke management evaluation to the APCD no later than 30 days after 

completion of the burn. 

• Smoke Management Plans are required for burns over 10 acres and must include: 

o The location and the specific objectives of the burn. 

o The acreage or tonnage, type and arrangement of the vegetation to be 

burned. 

o The distances and directions to all potentially affected smoke sensitive areas. 

o The fuel condition, combustion and meteorological prescription elements 

developed for the project. 

o The project schedule and duration of project ignition, combustion and 

burndown. 
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o Specifications for monitoring and verifying critical parameters such as air 

quality or weather. 

o A discussion of how the requirements of Section B of this Rule that apply to 

prescribed burning will be satisfied. 

o A discussion of what specific contingency actions (such as fire suppression or 

containment) will be taken if unanticipated conditions cause smoke to create 

or contribute to an exceedance of a state or federal ambient air quality 

standard or cause a public nuisance. 

o A discussion of the procedure that the land manager or his/her designee will 

use to coordinate daily with the APCD on multi-day burns, which may impact 

smoke sensitive areas, to affirm that the burn project remains within the 

conditions specified in the Plan, or whether contingency actions are 

necessary. 

o Specifications and procedures for disseminating project information to the 

public. 

o Procedures for public notification and education, including appropriate 

signage at burn sites, and for reporting any public smoke complaints to the 

APCD. 

o Identification of responsible personnel, including 24-hour telephone contacts 

for on-site personnel responsible for the burn. 

o The smoke management criteria the land manager or his/her designee will 

use for making burn ignition decisions. 

o Projections, including a map, of where the smoke is expected to travel, both 

day and night. 

o An evaluation of alternatives to burning considered. If an analysis of 

alternatives has been prepared as part of the environmental documentation 

required for the burn project pursuant to the National Environmental Policy 

Act or the California Environmental Quality Act, as applicable, the analysis 

shall be attached to the smoke management plan to satisfy this requirement. 

Overall, District Rule 4106 is more stringent than VCAPCD Rule 56 because District 

Rule 4106 prohibits open burning of almost all agricultural wastes, except prunings from 

apples crops, pears crops, fig crops, and quince crops, as well as weed abatement 

activities affecting waterways for which open burning is allowed until June 1, 2010. 

District Rule 4106 allows open burning of orchard removal from citrus, apple, pear, 

quince, fig crops and orchard removal of up to 20 acres per location per calendar year 

until June 1, 2010, the burning of rice straw until June 1, 2015. VCAPCD Rule 56

allows open burning of any agricultural waste.

VCAPCD Rule 56 and District Rule 4106 have comparable requirements for naturally 

ignited fires and prescribed fires. 

Based on the above discussion, District staff deems that District Rule 4106 is more 

stringent than VCAPCD Rule 56. 
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Conclusion

There are no federal rules and regulations that apply to prescribed burning or hazard 

reduction burning. After careful evaluation the prohibitory rules in other California 

nonattainment areas, District staff concludes that District Rule 4106 satisfies RACT for 

prescribed or hazard reduction burning. 
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Rule 4301 – Fuel Burning Equipment 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2002 2004 2006 2008 2012 2016 2020 2024 

NOx 89.157 90.311 83.046 79.302 79.944 80.452 80.574 79.188 

(Source: District 2007 Ozone Plan) 

District Rule 4301 Description

This rule was originally enacted by California Air Resources Board (CARB) in the early 

1970s. The rule was delegated to all air districts in California soon thereafter. 

This rule limits the concentration of combustion contaminants to 0.1 grain per standard 

cubic feet of gas and limits maximum emissions rates of sulfur dioxide to 200 pounds 

per hour, nitrogen oxide to 140 pounds per hour, and combustion contaminants to 10 

pounds per hour from fuel burning equipment. 

How does District Rule 4301 compare with federal rules and regulations?

A. EPA - Control Techniques Guidelines

There is no CTG for this source category. 

B. EPA - Alternative Control Techniques Guidelines 

NOx Emissions from Process Heaters - EPA-453/R-93-034 

NOx Emissions from Utility Boilers - EPA-453/R-94-023 

NOx Emissions from Industrial/Commercial/Institutional Boilers - EPA-453/R-94-022 

These documents outline the NOx control techniques used in controlling emissions from 

boilers and process heaters; such as low-NOx burners (LNB's), ultra-low NOx burners 

(ULNBs), selective non-catalytic reduction (SNCR), selective catalytic reduction (SCR) 

and flue gas recirculation (FGR). 

The reduction efficiency of each control technique varies depending on the application 

and design. The control efficiencies for LNB, ULNB, and SCR are considered to be 

representative averages based on operating experience, range from 27% for LNB to 

92% for LNB plus SCR. 

This rule was the very first rule to limit NOx from process heaters and boilers or similar 

equipment used in process of burning fuel for primary purpose of producing heat or 

power by indirect heat transfer before many of the above technologies were developed. 
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Rule limits NOx emissions to 140 lb/hr regardless of control technique or technology, 

equipment design, application, size or rating. Much lower emissions can reasonably be 

achieved using control techniques described above. 

However, District’s permits database search determined that all permit units to which 

NOx requirements of rule 4301 apply, have been subject to the following SIP approved 

rules that supersede the NOx requirements of this rule. 

The following District rules have been determined by EPA to fulfill Best Available 

Control Measures (BACM) required for serious nonattainment areas per Section 189(b) 

of Clean Air Act as well RACT required for moderate nonattainment areas per Section 

189(a) of Clean Air Act. 

Rule 4306 - BOILERS, STEAM GENERATORS AND PROCESS HEATERS

Rule 4307 - BOILERS, STEAM GENERATORS, AND PROCESS HEATERS - 2.0 

MMBTU/HR TO 5.0 MMBTU/HR

Rule 4308 - BOILERS, STEAM GENERATORS, AND PROCESS HEATERS (0.075 

MMBTU/HR TO 2.0 MMBTU/HR)

Rule 4309 - DRYERS, DEHYDRATORS AND OVENS

Rule 4352 - SOLID FUEL FIRED BOILERS, STEAM GENERATORS, AND PROCESS 

HEATERS

How does Rule 4301 compare to rules in other air districts

District staff compared NOx limits, optional control requirements, and work practice 

standards in District Rule 4301 to comparable requirements in rules from the following 

California nonattainment areas: 

• .South Coast Air Quality Management District Rule 474 (Fuel Burning Equipment - 

Oxides of Nitrogen) 

• Bay Area Air Quality Management District Regulation 9 Rule 6 (Nitrogen Oxides 

Emissions from Natural Gas-Fired Boilers and Water Heater) and Regulation 9 Rule 

7 (Nitrogen Oxides and Carbon Monoxide from Industrial, Institutional, and 

Commercial Boilers, Steam Generators, and Process Heaters) 

• Sacramento Metropolitan Air Pollution Control District Rule 411 

• Ventura County Air Pollution Control District Rule 60 

A. South Coast AQMD Rule 474 

South Coast AQMD Rule 474 allows NOx emissions that range from 125 ppmv to 400 

ppmv @ 3% O2. 
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B. Bay Area AQMD 

Bay Area Air Quality Management District does not have any rule that is similar to 

District Rule 4301. However it has following rules that were determined by EPA to fulfill 

Best Available Control Measures (BACM) required for serious nonattainment areas per 

Section 189(b) of Clean Air Act as well RACT required for moderate nonattainment 

areas per Section 189(a) of Clean Air Act. 

Rule 9-6 Nitrogen Oxides Emissions from Natural Gas-Fired Boilers and Water Heaters 

This rule applies to equipment with heat input rating between 0.75 MMBtu/hr and 2.0 

MMBtu/hr. Allowable NOx emissions range from 20 ppmv to 55 ppmv @ 3% O2. 

Rule 9-7 Nitrogen Oxides and Carbon Monoxide from Industrial, Institutional, and 

Commercial Boilers, Steam Generators, and Process Heaters 

This rule applies to equipment with heat input rating greater than 2.0 MMBtu/hr. 

Allowable NOx emissions range from 5 ppmv to 30 ppmv @ 3% O2. 

C. Sac Metro AQMD Rule 411 

Sacramento Metropolitan Air Quality Management District does not have any rule that is 

similar to District Rule 4301. However it has following rule that was determined by EPA 

to fulfill Best Available Control Measures (BACM) required for serious nonattainment 

areas per Section 189(b) of Clean Air Act as well RACT required for moderate 

nonattainment areas per Section 189(a) of Clean Air Act. 

Rule 411 NOx from Boilers, Process Heaters and Steam Generators 

This rule applies to equipment with heat input rating greater than 1.0 MMBtu/hr. 

Allowable NOx emissions range from 9 ppmv to 30 ppmv @ 3% O2. 

D. Ventura County APCD Rule 60 

Ventura County Air Pollution Control District Rule 60 (New Non-Mobile Equipment - 

Sulfur Dioxide, Nitrogen Oxides, and Particulate Matter) limits maximum emissions 

rates of nitrogen oxide to 140 pounds per hour from fuel burning equipment. 

Conclusion

District staff has determined that Rule 4301 itself can not be considered to fulfill the 

Reasonably Available Control Technology. However District staff concludes that NOx 

requirements of District Rule 4301 have been superseded by requirements of other 

District Rule that satisfy RACT for fuel burning equipment, since all units subject to 

Rule 4301 are subject to a more specific NOx rule, discussed elsewhere. 
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Rule 4306 – Boilers, Steam Generators, and Process Heaters, >5 

MMBtu/hr 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 7.5 4.7 4.6 4.6 4.7 4.7 5.2 5.4 

VOC 0.7 0.7 0.7 0.71 0.71 0.73 0.75 0.77 

(Source: District 2007 Ozone Plan) 

The emissions inventory for large boilers (> 5.0 MMBtu/hr) is assumed to be included as 

part of the inventory for District Rule 4306 (large boilers - from units rated at 5 MMBtu/hr 

or less); above are the baseline emissions from boilers as a whole. 

(Note: All Rule 4306 units are also subject to Rule 4320, which is more stringent) 

District Rule 4306 Description

District Rule 4306, was adopted September 18, 2003, and was most recently amended 

October 16, 2008. The purpose of Rule 4306 is to limit NOx and CO emissions from 

boilers, steam generators, and process heaters. The rule applies to any gaseous fuel or 

liquid fuel fired boiler, steam generator, and process heater with a rated heat input of 

5.0 million Btu/hr or greater. This source category includes a wide range of industries 

including but not limited to medical facilities, educational institutions, office buildings, 

prisons, military facilities, hotels and industrial industries. 

Units subject to Rule 4306 are to be certified that they comply with the following NOx 

and CO emission limits: 

Rule 4306 NOx and CO Limits 

Operated on Gaseous Fuel Operated on Liquid Fuel 

NOx Limit 

Category 

Standard Option Enhanced Option 

CO 

Limit 

(ppmv) 

NOx Limit CO Limit 

(ppmv) 

A. Units with a rated heat input 

equal to or less than 20.0 

MMBtu/hour, except for 

Categories C, D, E, F, G, H, 

and I units 

15 ppmv or 

0.018 lb/MMBtu 

9 ppmv or 

0.011 lb/MMBtu 

400 40 ppmv or 

0.052 

lb/MMBtu 

400 

B. Units with a rated heat input 

greater than 20.0 

MMBtu/hour, except for 

Categories C, D, E, F, G, H, 

and I units 

9 ppmv or 

0.011 lb/MMBtu 

6 ppmv or 

0.007 lb/MMBtu 

400 40 ppmv or 

0.052 

lb/MMBtu 

400 
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C. Oilfield Steam 

Generators 

15 ppmv or 

0.018 lb/MMBtu No option 

400 40 ppmv or 

0.052 

lb/MMBtu 

400 

D. Refinery units with a rated 

heat input greater than 5 

MMBtu/hr up to 65 

MMBtu/hr 

30 ppmv or 0.036 

lb/MMBtu No option 

400 40 ppmv or 

0.052 

lb/MMBtu 

400 

E. Refinery units with a rated 

heat input greater than 65 

MMBtu/hr up to 110 

MMBtu/hr 

25 ppmv or 

0.031 lb/MMBtu No option 

400 40 ppmv or 

0.052 

lb/MMBtu 

400 

F. Refinery units with a rated 

heat input greater than 110 

MMBtu/hr 

5 ppmv or 

0.0062 lb/MMBtu No option 

400 

40 ppmv or 

0.052 

lb/MMBtu 

400 

G. Load-following units 15 ppmv or 0.018 

lb/MMBtu 

9 ppmv or 

0.011 lb/MMBtu 

400 

40 ppmv or 

0.052 

lb/MMBtu 

400 

H. Units limited by a Permit to 

Operate to an annual heat 

input of 9 billion Btu/year to 

30 billion Btu/year 

30 ppmv or 0.036 

lb/MMBtu No option 400 

40 ppmv or 

0.052 

lb/MMBtu 

400 

How does District Rule 4306 compare with federal rules and regulations?

District staff conducted a rule consistency analysis as part of the recent amendments to 

Rule 4306. This analysis was included with the SIP submittal as Appendix E of the staff 

report. The purpose of this document was to compare the amended rule to federal 

rules, regulations and policies. 

This analysis determined that Rule 4306 met or exceeded the following federal 

requirements: 

• 40 CFR 60 Subpart D (Standards of Performance for Fossil-Fuel Fired 

Steam Generators for Which Construction Commenced After August 17, 

1971) 

• 40 CFR 60 Subpart Db (Standards of Performance for IndustrialCommercial-Institutional Steam Generating Units) 

• 40 CFR 60 Subpart Dc (Standards of Performance for Small IndustrialCommercial-Institutional Steam Generating Units) 

• 40 CFR 63 Subpart DDDDD (NESHAP for Industrial, Commercial, and 

Institutional Boilers and Process Heaters) 

• EPA –453/R-94-022 “Alternative Control Techniques (ACT) Document – 

NOx Emissions from Industrial/Commercial/Institutional Boilers”, dated 

March 1994 

• EPA “Control Techniques Guideline (CTG) Document 

• EPA Policy on Start-up or Shutdown 
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• EPA Policy on Recordkeeping 

• EPA Policy on Representative Unit Testing 

• EPA Policy on Alternate Emission Control Plan (AECP) 

How does District Rule 4306 compare to rules in other air districts?

The recent amendments to Rule 4306 strengthened emission limits and removed any 

exemptions which may have prevented the rule from satisfying RACT. Due to the 

overall stringency of recently amended Rule 4306, the District did not conduct a detailed 

comparison to rules in other air districts. 

Conclusion

District staff concludes that District Rule 4306 satisfies RACT for Boilers, Steam 

Generators, and Process Heaters – 5.0 MMBtu/hr or greater. 
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Rule 4307 – Boilers, Steam Generators, and Process Heaters – 2.0 

MMBtu/hr to 5.0 MMBtu/hr 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 7.5 4.7 4.6 4.6 4.7 4.7 5.2 5.4 

VOC 0.7 0.7 0.7 0.71 0.71 0.73 0.75 0.77 

(Source: District 2007 Ozone Plan) 

The emissions inventory for medium size boilers (2.0 to 5.0 MMBtu/hr) is assumed to be 

included as part of the inventory for District Rule 4306 (large boilers - from units rated at 

5 MMBtu/hr or greater); above are the baseline emissions from boilers as a whole. 

District Rule 4307 Description

Rule 4307 was adopted by the District’s Governing Board on December 15, 2005, and 

was most recently amended October 16, 2008. The purpose of Rule 4307 is to limit 

NOx and CO emissions from boilers, steam generators, and process heaters. The rule 

applies to any gaseous fuel or liquid fuel fired boiler, steam generator, and process 

heater with a rated heat input of 2.0 million Btu/hr up to and including 5.0 million Btu/hr. 

This source category includes a wide range of industries including but not limited to 

medical facilities, educational institutions, office buildings, prisons, military facilities, 

hotels and industrial industries. 

Units subject to Rule 4307 are to be certified that they comply with the NOx and CO 

emission limits specified in the rule. For gaseous fuel-fired units the NOx limit is 30 

ppmv or 0.036 lb/MMBtu and 400 ppmv for CO. For liquid fuel-fired units the NOx limit is 

40 ppmv or 0.052 lb/MMBtu and 400 ppmv for CO. The most recent amendments to 

Rule 4307 removed established lower NOx limits for new and replacement units (12 

ppmv or 0.014 lb/MMBtu) and eliminated the exemption associated with units that are 

used at schools. The rule also limits emissions SO2, and PM10 from boilers, steam 

generators, and process heaters. 

How does District Rule 4307 compare with federal rules and regulations?

District staff conducted a rule consistency analysis as part of the recent amendments to 

Rule 4307. This analysis was included with the SIP submittal as Appendix E of the staff 

report. The purpose of this document was to compare the amended rule to federal 

rules, regulations and policies. 

This analysis determined that Rule 4307 met or exceeded the following federal 

requirements: 
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• 40 CFR 60 Subpart D (Standards of Performance for Fossil-Fuel Fired 

Steam Generators for Which Construction Commenced After August 17, 

1971) 

• 40 CFR 60 Subpart Db (Standards of Performance for IndustrialCommercial-Institutional Steam Generating Units) 

• 40 CFR 60 Subpart Dc (Standards of Performance for Small IndustrialCommercial-Institutional Steam Generating Units) 

• 40 CFR 63 Subpart DDDDD (NESHAP for Industrial, Commercial, and 

Institutional Boilers and Process Heaters) 

• EPA –453/R-94-022 “Alternative Control Techniques (ACT) Document – 

NOx Emissions from Industrial/Commercial/Institutional Boilers”, dated 

March 1994 

• EPA “Control Techniques Guideline (CTG) Document 

• EPA Policy on Start-up or Shutdown 

• EPA Policy on Recordkeeping 

• EPA Policy on Representative Unit Testing 

• EPA Policy on Alternate Emission Control Plan (AECP) 

How does District Rule 4307 compare to rules in other air districts?

The recent amendments to Rule 4307 strengthened emission limits and removed any 

exemptions which may have prevented the rule from satisfying RACT. Due to the 

overall stringency of recently amended Rule 4307, the District did not conduct a detailed 

comparison to rules in other air districts. 

Conclusion

District staff concludes that District Rule 4307 satisfies RACT for Boilers, Steam 

Generators, and Process Heaters – 2.0 MMBtu/hr to 5.0 MMBtu/hr. 
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Rule 4308 – Boilers, Steam Generators, and Process Heaters – 0.075 

MMBtu/hr to 2.0 MMBtu/hr 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 7.5 4.7 4.6 4.6 4.7 4.7 5.2 5.4 

VOC 0.7 0.7 0.7 0.71 0.71 0.73 0.75 0.77 

(Source: District 2007 Ozone Plan) 

The emissions inventory for small size boilers (0.75 to 2.0 MMBtu/hr) is assumed to be 

included as part of the inventory for District Rule 4306 (large boilers - from units rated at 

5 MMBtu/hr or greater); above are the baseline emissions from boilers as a whole. 

District Rule 4308 Description

Rule 4308 was adopted by the District’s Governing Board on October 20, 2005, and 

limits NOx and CO emissions from boilers, steam generators, and process heaters. This 

rule applies to any person who supplies, sells, offers for sale, installs, or solicits the 

installation of any new small boiler, steam generator, process heater or water heater 

with a rated heat input capacity greater than or equal to 0.075 Million Btu/hr and up to 

but not including 2.0 Million Btu/hr. Facilities with boilers in this size range may include 

electrical utilities, crude oil production facilities, manufacturing facilities, and food 

processing facilities. Exemptions include units installed in manufactured homes and 

humidifiers, where the products of combustion come into direct contact with the material 

to be heated. 

District Rule 4308 limits NOx emissions at 3% O2 to the following: 

Between 0.075-0.4 MMBtu/hr 0.093 lb NOx/MMBtu 

Between 0.4 and 2.0 MMBtu/hr 0.036 lb NOx/MMBtu 

Rule 4308 also includes emissions certification protocol, establishes a District 

certification program, and outlines compliance reports requirements. 

On May 30, 2007 EPA took direct final action to approve revisions to the San Joaquin 

Valley Unified Air Pollution Control District portion of the California State Implementation 

Plan. These revisions included approval of District Rule 4307. EPA, in evaluating and 

approving Rule 4308 included the following: 

“We believe these rules are consistent with the relevant policy and guidance 

regarding enforceability, RACT, BACM, and SIP relaxations.” (CFR Volume 72, 

Number 103) 
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How does District Rule 4308 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

District staff’s review of the EPA CTG list indicates that there is no CTG for boilers, 

steam generators, and process heaters – 0.075 MMBtu/hr to 2.0 MMBtu/hr. 

B. EPA – Alternative Control Techniques (ACT) Document 

NOx Emissions from Industrial/Commercial/Institutional Boilers - EPA-453/R-94-022 

The ACT discusses the different control techniques for controlling NOx emissions from 

boilers with heat input capacities from 0.4 to 1,500 MMBtu/hr. The ACT also presented 

the achievable emission levels of several control techniques based on the type of boiler 

and the type of fuel used. The ACT contains cost effectiveness estimates for different 

control techniques. However, the ACT does not prescribe the specific emission limits 

that should be used in developing a regulation to control NOx emissions from boilers. 

C. Standards of Performance for New Stationary Sources (NSPS) 

District staff’s review of 40 CFR 60 (Standards of Performance for New Sources) 

indicates that there is no NSPS for boilers, steam generators, and process heaters – 

0.075 MMBtu/hr to 2.0 MMBtu/hr. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

40 CFR 63 Subpart DDDDD (NESHAP for Industrial, Commercial, and Institutional 

Boilers and Process Heaters) 

40 CFR 63 Subpart DDDDD establishes emission limits and work practice standards for 

boilers and process heaters to regulate hazardous air pollutants such as arsenic, 

cadmium, chromium, hydrogen chloride, hydrogen fluoride, lead, manganese, mercury, 

and nickel. NESHAP applies to any boiler process or heaters located at a major source. 

Existing units are units that commenced construction before January 13, 2003; new 

units are units built on or after January 13, 2003. Emissions from new units are limited 

to 0.03 lb/MMBtu for PM, and 400 ppm at 3%O2 for CO. In general, the applicability, 

emission limits, and monitoring requirements of Rule 4308 are more stringent than 

those specified for units that are subject to 40 CFR 60 Subpart DDDDD. 

How does District Rule 4308 compare to rules in other air districts?

District staff compared NOx limits, optional control requirements, and work practice 

standards in District Rule 4308 to comparable requirements in rules from the following 

California nonattainment areas: 
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• South Coast AQMD Rule 1146.2 (Emissions of Oxides of Nitrogen from Large Water 

Heaters and Small Boilers and Process Heaters) amended May 5, 2006 

• Bay Area AQMD Regulation 9 Rule 7 (Nitrogen Oxides and Carbon Monoxide from 

Industrial, Institutional, and Commercial Boilers, Steam Generators, and Process 

Heaters) adopted November 7, 2007 

• Bay Area AQMD Regulation 9 Rule 6 (Nitrogen Oxides Emissions from Natural Gas 

Fired Boilers and Water Heaters) amended July 20, 2008 

• Sacramento Metropolitan AQMD Rule 411 (NOx from Boilers, Process Heaters, and 

Steam Generators) amended August 23, 2007 

• Ventura County APCD Rule 74.11.1 (Large Water Heaters and Small Boilers) 

adopted September 14, 1999 

A. South Coast AQMD Rule 1146.2 (Emissions of Oxides of Nitrogen from 

Large Water Heaters and Small Boilers and Process Heaters)

SCAQMD Rule 1146.2 applies to natural gas-fired water heaters, boilers, and process 

heaters. This rule applies to units that have a rated heat input capacity less than or 

equal to 2,000,000 Btu per hour. Type 1 units have a rated heat input capacity less 

than or equal to 400,000 Btu/hr. per hour excluding. Type 2 units have a rated heat 

input capacity greater than 400,000 Btu/hr, but less than 2,000,000 Btu/hr. 

Exemptions include: 

• Units used in recreational vehicles. 

• Any residential unit 

• Units with a rated heat input capacity greater than 400,000 Btu per hour, but less 

than or equal to 2,000,000 Btu per hour that are demonstrated to use less than 

9,000 therms during every calendar year. 

Key requirements of the Rule 1146.2 include: 

• No person shall manufacture for use, or offer for sale for use, in the District any 

new Type 2 Unit, unless the NOx emissions level is less than or equal to 30 ppm 

of NOx emissions and no more than 400 ppm of carbon monoxide (at 3% O2, 

dry) 

• No person shall manufacture for use, or offer for sale for use, in the District any 

new Type 1 Unit, unless the NOx emissions level is less than or equal to 40 

nanograms of NOx (calculated as NO2) per joule of heat output or 55 ppm NOx 

emissions (at 3% O2, dry) 

• On or after January 1, 2006, no person shall operate in the District any unit more 

than 15 years old, based on the original date of manufacture with a rated heat 

input capacity greater than 1,000,000 Btu per hour but less than or equal to 

2,000,000 Btu per hour and manufactured on or after January 1, 1992, which 

does not meet emission limits of 30 ppm NOx and 400 ppm of carbon monoxide 

(at 3% O2, dry) 

• On or after January 1, 2006, no person shall operate in the District any unit more 

than 15 years old, based on the original date of manufacture as specified in 
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paragraph (c)(6), with a rated heat input capacity greater than 400,000 Btu per 

hour but less than or equal to 1,000,000 Btu per hour manufactured prior to 

January 1, 2000, which does not meet emission limits of 30 ppm NOx and 400 

ppm of carbon monoxide (at 3% O2, dry) 

• On or after January 1, 2010, no person shall manufacture for use or offer for sale 

for use within the District any Type 2 unit unless the unit is certified pursuant to 

subdivision (d) to a NOx emission level of less than 14 nanograms of NOx 

(calculated as NO2) per joule of heat output or less than or equal to 20 ppm of 

NOx emissions (at 3% O2, dry). 

• On or after January 1, 2012, no person shall manufacture for use or offer for sale 

for use within the District any Type 1 unit (excluding pool heaters), unless the unit 

is certified to a NOx emission level of less than 14 nanograms of NOx (calculated 

as NO2) per joule of heat output or less than or equal to 20 ppm of NOx 

emissions (at 3% O2, dry). 

• On or after May 5, 2006, the owner or operator of any Type 2 unit shall perform 

maintenance in accordance with the manufacturer's schedule and specifications 

as identified in a manual and other written materials supplied by the 

manufacturer or distributor. The owner or operator shall maintain on site a copy 

of the manufacturer’s and/or distributor's written instructions and retain a record 

of the maintenance activity for a period of not less than three years. 

• The owner or operator shall maintain on site a copy of all documents identifying 

the unit’s rated heat input capacity. The rated heat input capacity shall be 

identified by a manufacturer’s or distributor’s manual or invoice. 

 SCAQMD Rule 11.46.2 and District Rule 4308 apply to similar source categories, and 

have identical emission limits 

Differences between the rules include 

• District Rule 4308 applies to all gaseous and liquid fuels while SCAQMD Rule 

1146.2 applies only to units fueled by natural gas 

• District Rule 4308 does not have exemptions for low-use units 

• Rule 1146.2 has an emission limit for older in-use units, Rule 4308 does not 

Based on the above discussion, District staff deems that the rules are comparable. The 

minor differences that the rules have do not make either rule significantly more stringent 

than the other. 

B. Bay Area AAQMD Regulation 9 Rule 7 (Nitrogen Oxides and Carbon 

Monoxide from Industrial, Institutional, and Commercial Boilers, Steam 

Generators, and Process Heaters) 

BAAQMD Regulation 9 Rule 7 applies to industrial, institutional, and commercial boilers, 

steam generators, and process heaters. Exemptions include: 

• Boilers, steam generators, and process heaters with a rated heat input of 2 

MMBtu/hour or less, if fired exclusively with natural gas, liquefied petroleum gas, or 

any combination thereof 
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• Boilers, steam generators and process heaters with a rated heat input less than 1 

million Btu/hour fired with any fuel 

• Boilers, steam generators, and process heaters that are used in petroleum refineries 

• Boilers used by public electric utilities or qualifying small power production facilities, 

as defined in Section 228.5 of the Public Utilities Code, to generate electricity; 

Establishes emission limits of 40 ppm for NOx and 400 ppm for CO when boilers 

1MMBtu/hour or greater are fired with non-gaseous fuel 

BAAQMD Regulation 9 Rule 7 only applies to small boilers that are not fired by gaseous 

fuels. For this subset of the overall source category, District Rule 4308 has more 

stringent NOx emission limits and is more stringent overall. 

C. Bay Area AQMD Regulation 9 Rule 6 (Nitrogen Oxides Emissions from 

Natural Gas Fired Boilers and Water Heaters) 

BAAQMD Regulation 9 Rule 6 applies to natural gas fired water heaters and boilers with 

a heat input capacity less than or equal to 2,000,000 Btu/hr. Exemptions include: 

• Units used in recreational vehicles 

• Units using a fuel other than natural gas 

• Pool/spa heaters with less than 400,000 Btu/hr rated heat input capacity 

Emissions limits: 

• No person shall sell, install, or offer for sale within the District any large natural 

gas-fired boiler, storage tank water heater, or instantaneous water heater with a 

rated heat input capacity from 400,001 to 2,000,000 Btu/Hour, inclusive, 

manufactured after January 1, 2008, that emits more than 20 nanograms of 

nitrogen oxides (calculated as NO2) per joule of heat output, or more than 30 

ppm NOx at 3% O2, dry. 

• No person shall sell, install, or offer for sale within the District any large natural 

gas-fired boiler, storage tank water heater, or instantaneous water heater with a 

rated heat input capacity from 400,001 to 2,000,000 Btu/Hour, inclusive, 

manufactured after January 1, 2013, that emits more than 14 nanograms of 

nitrogen oxides (calculated as NO2) per joule of heat output, or more than 20 

ppm NOx at 3% O2, dry. 

• Natural Gas-Fired Pool/Spa Heaters: No person shall sell, install, or offer for 

sale within the District any natural gas-fired pool/spa heater with an input rating 

from 400,001 to 2,000,000 Btu/Hour, inclusive, manufactured after January 1, 

2008, that emits more than 40 nanograms of nitrogen oxides (calculated as NO2) 

per joule of heat output, or more than 55 ppm NOx at 3% O2, dry. 

• No person shall sell, install, or offer for sale within the District any natural gasfired pool/spa heater with an input rating from 400,001 to 2,000,000 Btu/Hour, 

inclusive, manufactured after January 1, 2013, that emits more than 14 

nanograms of nitrogen oxides (calculated as NO2) per joule of heat output, or 

more than 20 ppm NOx at 3% O2, dry. 
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BAAQMD Regulation 9 Rule 6 also has comparable administrative requirements to 

District Rule 4308. 

District Rule 4308 is currently more stringent than BAAQMD Regulation 9 Rule 6. The 

District rule has comparable emission limits for water heaters and boilers, but has more 

stringent limits for pool/spa heaters. However, BAAQMD Regulation 9 Rule contains 

requirements that lower emission limits starting in 2013. It should be noted that the 

District has a commitment to adopt an amended Rule 4308 in the 4th Quarter 2009 

which will have emission limits similar to or more stringent than BAAQMD Regulation 9 

limits. 

D. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 

411 (NOx from Boilers, Process Heaters, and Steam Generators)

SMAQMD Rule 411 applies to units (i.e., boilers, steam generators and process 

heaters) fired on gaseous or nongaseous fuels with a rated heat input capacity equal to 

or greater than 1 MMBtu/hr. 

Exemptions include: 

• Any unit that is exclusively used by an electric utility to generate electricity 

• Process heaters, kilns, and furnaces where the products of combustion come into 

direct contact with the material to be heated 

• Waste heat recovery boilers 

Units 1.0-2.5 MMBtu/hr that use less than 40,000 therms per year are subject to a 

limited exemption from emission limits. 

Applicable Emission Limits: 

Boiler Type NOx limit CO limit 

Gaseous Fuel Fired 1-5MMBtu/hr 30 ppm 400 ppm 

Non-Gaseous Fuel Fired 1-5MMBtu/hr 40 ppm 400 ppm 

Biomass Fuel Firing 70 ppm 400 ppm 

Emergency Standby Non-Gaseous Fuel Firing 150 ppm N/A 

SMAQMD Rule 411 has additional monitoring and administrative requirements, 

although this are primarily directed at larger units that would not be subject to District 

Rule 4308. 

District Rule 4308 is has more stringent NOx emission limits for non-gaseous fired units 

and units fired by biomass. Rule 4308 also does not have allowances for emergency 

standby non-gaseous fuel firing. SMAQMD Rule 411 has CO emission limits that are 

absent in Rule 4308. 

Overall Rule 4308 is more stringent because it applies to a broader range of units. 

SMAQMD Rule 411 only applies to units with a rated heat input capacity equal to or 

greater than 1 MMBtu/hr. SMAQMD also has Rule 413 while applies to residential 
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water heaters, but there is not a rule that establishes emission limits for boilers, steam 

generators and process heaters with a rated heat input capacity greater than 75,000 

btu/hr and less than 1,000,000 btu/hr. 

E. Ventura County Air Pollution Control District (VCAPCD) Rule 74.11.1 (Large 

Water Heaters and Small Boilers) 

VCAPCD Rule 74.11.1 applies to any person selling, offering for sale, or installing a 

new water heater, boiler, steam generator or process heater with a rated heat input 

capacity greater than 75,000 BTU/hr and less than or equal to 2,000,000 Btu/hr in 

Ventura County. 

VCAPCD Rule 74.11.1 includes specific requirements for small new water heaters, 

boilers, steam generators or process heaters, including: 

o Beginning in 2001, NOx emissions from units with a rated heat input capacity of 

greater than 75,000 Btu/hr and less than 400,000 Btu/hr shall not exceed 55 parts 

per million. 

o Beginning in 2000, NOx emissions from units with a rated heat input capacity of 

greater than 400,000 Btu/hr and less than 2,000,000 Btu/hr shall not exceed 30 

parts per million. CO emissions shall not exceed 400 parts per million. 

o Every subject unit offered for sale in Ventura County shall be certified by the Air 

Pollution Control Officer. 

o The manufacturer shall submit a compliance report for each applicable new or 

modified unit by model, including a report on a unit source test. 

District staff deems that the rules are comparable. They have identical emissions limits, 

and similar certification and compliance requirements. 

Conclusion

District Rule 4308 meets all federal requirements and at least as stringent as 

comparable rules in California. Therefore District Staff conclude that Rule 4308 

satisfies RACT for Boilers, Steam Generators, and Process Heaters 0.75 to 2.0 

MMBtu/hr. 
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Rule 4309 – Dryers, Dehydrators, and Ovens 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 2.512 2.631 2.794 2.836 2.965 3.082 3.244 3.390 

NOx adj 2.51 2.63 1.85 1.88 1.97 2.05 2.14 2.25 

VOC 0.389 0.417 0.440 0.446 0.469 0.486 0.512 0.539 

(Source: District 2007 Ozone Plan) 

District Rule 4309 Description

Rule 4309, recently adopted on December 15, 2005, limits NOX and CO emissions from 

dryers, dehydrators and ovens. The main rule requirement is the limitation of NOX and 

CO emissions from dryers, dehydrators, and ovens. These limitation and listed below. 

Asphalt/Concrete Plant (ppm @ 19% O2): 

Gaseous fuel: NOX: 4.3 ppm; CO: 42 ppm 

Liquid fuel: NOX: 12.0 ppm; CO: 64 ppm 

Milk, Cheese, and Dairy Processing < 20 MMBtu/hr (ppm @ 19% O2): 

Gaseous fuel: NOX: 3.5 ppm; CO: 42 ppm 

Liquid fuel: NOX: 3.5 ppm; CO: 42 ppm 

Milk, Cheese, and Dairy Processing ≥ 20 MMBtu/hr (ppm @ 19% O2): 

Gaseous fuel: NOX: 5.3 ppm; CO: 42 ppm 

Liquid fuel: NOX: 5.3 ppm; CO: 42 ppm 

Other Processes Not Described (ppm @ 19% O2): 

Gaseous fuel: NOX: 4.3 ppm; CO: 42 ppm 

Liquid fuel: NOX: 4.3 ppm; CO: 42 ppm 

On May 30, 2007 EPA took direct final action to approve revisions to the San Joaquin 

Valley Unified Air Pollution Control District portion of the California State Implementation 

Plan. These revisions included approval of District Rule 4309. EPA, in evaluating and 

approving Rule 4309 included the following: 

“We believe these rules are consistent with the relevant policy and guidance 

regarding enforceability, RACT, BACM, and SIP relaxations.” (CFR Volume 72, 

Number 103) 

Since Rule 4309 was recently approved by EPA as meeting RACT requirements, the 

District did not pursue a detailed RACT analysis. 
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How does District Rule 4309 compare with federal rules and regulations?

The District did not conduct a detailed analysis of federal rules and regulations for Rule 

4309. 

How does District Rule 4309 compare to rules in other air districts?

The District did not conduct a detailed comparison to rules in other air districts for Rule 

4309. 

Conclusion

District staff concludes that District Rule 4309 satisfies RACT for dryers, dehydrators, 

and ovens. 
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Rule 4311 – Flares 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 0.070 0.082 0.083 0.083 0.084 0.091 0.093 0.090

VOC 0.045 0.049 0.050 0.050 0.051 0.053 0.054 0.055

(Source: District 2007 Ozone Plan) 

District Rule 4311 Description

District Rule 4311, recently amended on June 15, 2006, controls emissions from any 

operation involving the use of flares. This source category currently includes flares 

associated with oil and gas production, combustion, sewage treatment, incinerators, 

petroleum refining, and VOC control. Flaring is a high temperature oxidation process 

used to burn combustible components, mostly hydrocarbons, of waste gases from 

industrial operations. 95 percent of the waste gases flared are natural gas, propane, 

ethylene, propylene, butadiene and butane. 

Rule 4311 requires ground level enclosed flares to meet the following emissions limits: 

Type of Flare and Heat 

Release Rate in MMBtu/hr

VOC (lb/MMBtu) NOx (lb/MMBtu) 

Without Steam-assist 

 <10 MMBtu 0.0051 0.0952 

 10-100 MMBtu 0.0027 0.1330 

 >100 MMBtu 0.0013 0.5240 

With Steam-assist 

All 0.14 as TOG 0.068 

How does District Rule 4311 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

There is no EPA CTG for flares. 

B. EPA - Alternative Control Technology (ACT) 

There is no EPA ACT for flares. 
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C. Standards of Performance for New Stationary Sources (NSPS) 

40 CFR 60.18 (General Control Device Requirements) and 40 CFR 65.147 (Flares) 

40 CFR 60.18 specifies certain minimum equipment performance standards for 

equipment used as control devices. In the case of flares, the CFR specifies no visible 

emission as well a certain equipment standards. Since NOx and VOC are invisible 

gasses, this portion of the CFR does not identify RACT for flares. 40 CFR 65.147 is 

part of the federal consolidated air rule. It essentially echoes 40 CFR 60.18 and as 

such does not identify RACT for flares. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There is no NESHAP or MACT for flares. 

How does District Rule 4311 compare to rules in other air districts?

District staff compared emission limits, optional control requirements, and work practice 

standards in District Rule 4311 to comparable requirements in rules from the following 

California nonattainment areas: 

• South Coast AQMD Rule 1118 (Emissions from Refinery Flares) amended February 

1998 

• Bay Area AQMD Regulation 12 Rule 11(Flare Monitoring at Petroleum Refineries) 

adopted June 4, 2003 

• Bay Area AQMD Regulation 12 Rule 12 )Flares at Petroleum Refineries) adopted 

July 20, 2005 

• Sacramento Metro AQMD has no specific prohibitory rule for flares 

• Ventura County APCD has no specific prohibitory rule for flares. 

A. SCAQMD Rule 1118 (Emissions from Refinery Flares) 

The emissions data collected as a result of Rule 1118, between 1999 and 2003, was 

analyzed and resulted in recommendations being made for further strengthening 

emissions monitoring and reporting procedures, leading to the adoption of amendments 

on November 4, 2005. The 2005 amendments prohibit the flaring of vent gases except 

in emergency situations, or during specific operational needs such as startups, 

shutdowns, and turnarounds. Operational requirements were established and practices 

to minimize flaring events, set specific annual SO2 performance targets, require flares to 

operate in a smokeless manner, and require annual inspections of pressure relief 

devices directly connected to flares. The rule also contains provisions for refineries to 

give 24-hour advance notice for each large planned flaring activity, as well as to notify 

SCAQMD within 1-hour of unexpected flaring events. Also required is the submittal of 

quarterly reports detailing flow, emissions, and cause of each flaring event. SCAQMD 
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also requires refineries to set up a 24-hour public telephone number for inquiries on 

flaring events.

B. BAAQMD Regulation 12 Rule 11 and Regulation 12 Rule 12 

BAAQMD Rule 12-11 requires that operators monitor and record emissions data for 

flares at petroleum refineries. This rule enabled BAAQMD to collect emissions data from 

refineries. With emissions data BAAQMD was able to determine causes of specific 

flaring events, as well as estimate the quantity of emissions released during those 

events. As a result of findings obtained under Rule 12-11, Rule 12-12 was adopted. 

Rule 12-12 reduces emissions from flares by minimizing the frequency and magnitude 

of flaring. Rule 12-12 also prohibits the use of refinery flares without the refinery first 

creating, following, and annually updating an FMP for each flare. Facilities are required 

to submit flaring reports when a flare, at that facility, releases more than 500,000 

standard cubic feet of gas per calendar day (scf/day). The flaring report must identify 

the cause and to avoid flaring from that cause in the future, if possible. The rule also 

requires continuous monitoring of the flare system’s knock-out drum water seal for 

leaks, and the submittal of annual reports to BAAQMD that evaluate flaring events that 

released less than 500,000 scf/day, but SO2 emitted was more than 500 lbs. 

Conclusion

District staff concludes that District Rule 4311 satisfies RACT for flaring operations in 

terms of emission limits and equipment standards. However, EPA recommends the 

District reconsider the utility of incorporating provisions such as those in South Coast Air 

Quality Management District Rule 1118 and Bay Area Air Quality Management District 

Rule 12-12 within Rule 4311 to air their enforcing of the rule, developing an accurate 

emissions inventory for theses sources, and minimizing excess emissions from flare 

activity to the maximum extent practicable.” The experience of the Bay Area AQMD and 

South Coast AQMD in incorporating flare minimization plans (FMPs) have resulted in 

data being gathered, which can be used to evaluate the effectiveness of FMPs in 

reducing flaring events. To this end, District staff is in the process of amending this rule 

to incorporate the use of FMPs. As outlined Table 4-3, it is expected that the rule will go 

before the District’s Governing Board for approval during the second quarter of 2009. 
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Rule 4313 – Lime Kiln 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOX 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

VOC 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

(Source: District 2007 Ozone Plan) 

District Rule 4313 Description

This rule applies to lime kilns. The purpose of this rule is to limit NOX emissions from 

the operation of lime kilns. 

How does District Rule 4313 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

There is no CTG for this source category. 

B EPA – Alternative Control Technology (ACT) 

There is no ACT for this source category. 

C. Standards of Performance for New Stationary Sources (NSPS) 

40 CFR Part 60 Subpart HH – Standards for Performance for Lime Manufacturing 

Plants 

The provisions of this subpart are applicable to each rotary lime kiln used in the 

manufacturing of lime. However, this subpart only has requirements for the particulate 

matter emissions from the rotary lime kilns. District Rule 4313 only has requirements 

for NOX and VOC emissions from lime kilns. Since 40 CFR Part 60 Subpart HH and 

District Rule 4313 do not have requirements for the same pollutants, they cannot be 

compared to determine if District Rule 4313 satisfies RACT. In addition, the RACT 

analysis is only evaluating VOC and NOx emissions. Since this subpart only has 

provisions for PM emissions, it will not have any impact in the District’s RACT analysis 

conclusion. 
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D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

Subpart AAAAA—National Emission Standards for Hazardous Air Pollutants for Lime 

Manufacturing Plants 

The provisions of this NESHAP are applicable to each rotary lime kiln used in the 

manufacturing of lime. However, this NESHAP only has requirements for the particulate 

matter emissions from the rotary lime kilns. District Rule 4313 only has requirements 

for NOX and VOC emissions from lime kilns. Since 40 CFR Part 63 Subpart AAAAA 

and District Rule 4313 do not have requirements for the same pollutants, they cannot be 

compared to determine if District Rule 4313 satisfies RACT. In addition, the RACT 

analysis is only evaluating VOC and NOx emissions. Since this subpart only has 

provisions for PM emissions, it will not have any impact in the Districts RACT analysis 

conclusion. 

How does District Rule 4313 compare to rules in other air districts?

District staff looked at the rules and regulations for air districts located in other California 

nonattainment areas. None of the following air districts have a rule that is applicable to 

lime kilns: South Coast AQMD, Bay Area AQMD, Sacramento Metro AQMD, Ventura 

County APCD 

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4313 

satisfies RACT for lime kilns. 
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Rule 4352 – Solid Fuel Boilers, Steam Generators and Process 

Heaters 

Emissions Inventory:

 Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 4.0 4.0 4.1 4.1 4.1 4.1 4.2 4.2 

VOC 0.406 0.408 0.409 0.409 0.409 0.411 0.413 0.413 

(Source: District 2007 Ozone Plan) 

District Rule 4352 Description

Rule 4352 applies to solid fuel fired boilers, steam generators, and process heaters. 

Units subject to Rule 4352 are not subject to Rules 4351, 4305, 4306, 4307, and 4308 

because these rules apply to boilers, steam generators, and process heaters fired on 

gaseous or liquid fuel. 

District Rule 4352 requires municipal solid waste units to meet a NOx limit of 200 ppmv 

@ 12% CO2. For all other units the NOx limit is 115 ppmv @ 3% O2. 

How does District Rule 4352 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

There is no EPA CTG for boilers, steam generators, and process heaters. 

B EPA – Alternative Control Technology (ACT) 

EPA –453/R-94-022 “Alternative Control Techniques (ACT) Document – NOx Emissions 

from Industrial/Commercial/Institutional Boilers”, dated March 1994 

The ACT discusses the different control techniques for controlling NOx emissions from 

boilers with heat input capacities from 0.4 to 1,500 MMBtu/hr. The ACT also presented 

the achievable emission levels of several control techniques based on the type of boiler 

and the type of fuel used. The ACT contains cost effectiveness estimates for different 

control techniques. However, the ACT does not prescribe the specific emission limits 

that should be used in developing a regulation to control NOx emissions from boilers. 

C. Standards of Performance for New Stationary Sources (NSPS) 

1. 40 CFR 60 Subpart D (Standards of Performance for Fossil-Fuel Fired Steam 

Generators for Which Construction Commenced After August 17, 1971) 

40 CFR 60 Subpart D applies to fossil fuel-fired, and fossil fuel and wood residue-fired 

steam generating units of more than 250 MMBtu/hr that commenced construction or 
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modification after August 17, 1971. Subpart D establishes the emission standards for 

NOx, SOx, and PM. Since Rule 4352 applies to units that are fired on solid fuel, this 

analysis focuses only on the NOx standards established in 40 CFR 60 Subpart D for 

similar type of fuel. 

NOx limits: 

• Wood residue, or gaseous fossil fuel and wood residue – 0.30 lb/MMBtu 

• Solid fossil fuel or solid fossil fuel and wood residue (except lignite or a solid 

fossil fuel containing 25 percent, by weight, or more of coal refuse) – 0.70 

lb/MMBtu 

• Lignite or lignite and wood residue – 0.60 lb/MMBtu 

• Lignite which is mined in North Dakota, South Dakota, or Montana and which is 

burned in a cyclone-fired unit – 0.80 lb/MMBtu 

In general, the applicability, emission limits, and monitoring requirements of Rule 4352 

are more stringent than those specified for units that are subject to 40 CFR 60 Subpart 

D. The relevant standards used for comparing the draft rule with 40 CFR 60 Subpart D 

are shown in the Rule Consistency Table. 

 

2. 40 CFR 60 Subpart Db (Standards of Performance for Industrial-CommercialInstitutional Steam Generating Units) 

40 CFR 60 Subpart Db applies to steam generating units with a heat input capacity of 

greater than 100 MMBtu/hr that commence construction, modification, or reconstruction 

after June 19, 1984. Steam generating units, as defined in 40 CFR 60 Subpart Db, do 

not include process heaters. Rule 4352 applies to solid fuel fired units so this analysis 

focuses only on the NOx standards established in 40 CFR 60 Subpart Db for similar 

type of fuel. 

NOx limits: 

• Mass-feed stoker – 0.50 lb/MMBtu. 

• Spreader stoker and fluidized bed combustion – 0.60 lb/MMBtu. 

• Pulverized coal – 0.70 lb/MMBtu 

• Lignite – 0.60 lb/MMBtu 

• Lignite mined in ND, SD, MT, and combusted in a slag tap furnace – 0.80 

lb/MMBtu. 

• Coal-derived synthetic fuels – 0.50 lb/MMBtu 

In general, the applicability, emission limits, and monitoring requirements of Rule 4352 

are more stringent than those specified for units that are subject to 40 CFR 60 Subpart 

Db. 

3. 40 CFR 60 Subpart Cb (Emissions Guidelines and Compliance Times for Large 

Municipal Waste Combustors That are Constructed on or Before September 20, 

1994) 
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40 CFR 60 Subpart Cb applies to each municipal waste combustor unit with a 

combustion capacity greater than 250 tons per day of municipal solid waste for which 

construction was commenced on or before September 20, 1994. Rule 4352 applies to 

solid fuel fired units so this analysis focuses only on the NOx standards established in 

40 CFR 60 Subpart Cb for similar type of fuel. 

NOx limits: 

• Mass burn waterwall – 205 ppm at 7% O2 

• Mass burn rotary waterwall – 250 ppm at 7% O2 

• Refuse-derived fuel combustor – 250 ppm at 7% O2 

• Fluidized bed combustor – 240 ppm at 7% O2 

• Mass burn refractory combustors - no limit 

• Fluidized bed combustor – 180 ppm at 7% O2 

4. 40 CFR 63 Subpart DDDDD (NESHAP for Industrial, Commercial, and 

Institutional Boilers and Process Heaters)

40 CFR 63 Subpart DDDDD establishes emission limits and work practice standards for 

boilers and process heaters to regulate hazardous air pollutants such as arsenic, 

cadmium, chromium, hydrogen chloride, hydrogen fluoride, lead, manganese, mercury, 

and nickel. NESHAP applies to any boiler process or heaters located at a major source. 

Existing units are units that commenced construction before January 13, 2003; new 

units are units built on or after January 13, 2003. 

5. EPA Policy on Start-up or Shutdown 

Section 5.3 of Rule 4352 establishes certain operational standards that must be met 

during start-up or shutdown of boilers, steam generators, and process heaters. District 

staff believes that the proposed start-up or shutdown provisions are consistent with the 

EPA policy as discussed in an EPA memorandum, dated February 15, 1983, “Policy on 

Excess Emissions During Start-up, Shutdown, Maintenance and Malfunctions” which 

prohibits automatic exemption during periods of start-up or shutdown of a unit. 

6. EPA Policy on Recordkeeping 

The recordkeeping requirement in Section 6.2 of Rule 4352 is consistent with EPA’s 

policy to keep and maintain records for at least five years. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There is no NESHAP or MACT for this category. 
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How does District Rule 4352 compare to rules in other air districts?

District staff compared NOx limits, exemptions, and control requirements in District Rule 

4352 to comparable requirements in rules from the following California nonattainment 

areas: 

• South Coast Air Quality Management District 

• Bay Area Air Quality Management District 

• Sacramento Metro Air Quality Management District 

• Ventura County Air Pollution Control District 

1. South Coast Air Quality Management District Rule (SCAQMD) 1146 (Emissions 

of oxides of Nitrogen from Industrial, Institutional, and Commercial Boilers, 

Steam Generators, and Process Heaters) last amended September 5, 2008 

SCAQMD Rule 1146 applies to boilers, steam generators, and process heaters of equal 

to or greater than 5 million Btu per hour rated heat input capacity used in all industrial, 

institutional, and commercial operations with the exception of: 

• boilers used by electric utilities to generate electricity; and 

• boilers and process heaters with a rated heat input capacity greater than 40 

million Btu per hour that are used in petroleum refineries; and 

• sulfur plant reaction boilers. 

SCAQMD Rule 1146 establishes a 40ppm NOx emission limit for all units fired on nongaseous fuel. 

Comparison of SCAQMD Rule 1146 and District Rule 4352 

SCAQMD Rule 1146 applies to all large boilers, steam generators and process heaters, 

regardless of fuel type. NOx emission limits in SCAQMD Rule 1146 are more stringent 

than emission limits for solid fuel fired units in District Rule 4352. 

Overall SCAQMD Rule 1146 is more stringent than District Rule 4352 when it is applied 

to solid fuel fired units. The District believes that that a 40ppm NOx emission limit is 

technologically infeasible for solid fuel fired units, and is not aware of any solid fuel fired 

boiler, steam generator or process heater that has operated at this level. 

2. South Coast Air Quality Management District (SCAQMD)Rule 1146.1 (Emissions 

of oxides of Nitrogen from Small Industrial, Institutional, and Commercial Boilers, 

Steam Generators, and Process Heaters) last amended September 5, 2008 

SCAQMD Rule 1146 applies to boilers, steam generators, and process heaters that are 

greater than 2 million BTU per hour and less than 5 million Btu per hour rated heat input 

capacity used in any industrial, institutional, or commercial operation. 
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SCAQMD Rule 1146.1 establishes a 30ppm NOx emission limit for all units fired on 

non-gaseous fuel. 

Comparison of SCAQMD Rule 1146.1 and District Rule 4352 

SCAQMD Rule 1146.1 applies to all small boilers, steam generators and process 

heaters, regardless of fuel type. NOx emission limits in SCAQMD Rule 1146.1 are 

more stringent than emission limits for solid fuel fired units in District Rule 4352. 

 

Overall SCAQMD Rule 1146.1 is more stringent than District Rule 4352 when it is 

applied to solid fuel fired units. The District believes that that a 30ppm NOx emission 

limit is technologically infeasible for solid fuel fired units, and is not aware of any solid 

fuel fired boiler, steam generator or process heater that has operated at this level. 

3. Bay Area Air Quality Management District (BAAQMD) Regulation 9 Rule 7 

(Nitrogen Oxides and Carbon Monoxide from Industrial, Institutional, and 

Commercial Boilers, Steam Generators, and Process Heaters) adopted 

November 7, 2007 

BAAQMD Regulation 9 Rule 7 applies to industrial, institutional, and commercial boilers, 

steam generators, and process heaters. Exemptions include: 

• Boilers, steam generators, and process heaters with a rated heat input of 2 

MMBtu/hour or less, if fired exclusively with natural gas, liquefied petroleum gas, or 

any combination thereof 

• Boilers, steam generators and process heaters with a rated heat input less than 1 

million BTU/hour fired with any fuel 

• Boilers, steam generators, and process heaters that are used in petroleum refineries 

• Boilers used by public electric utilities or qualifying small power production facilities, 

as defined in Section 228.5 of the Public Utilities Code, to generate electricity; 

BAAQMD Regulation 9 Rule 7 establishes emission limits of 40ppm for NOx and 

400ppm for CO when boilers 1MMBtu/hour or greater are fired with non-gaseous fuel. 

Comparison of BAAQMD Regulation 9 Rule 7 and District Rule 4352 

BAAQMD Regulation 9 Rule 7 applies to all small boilers, steam generators and 

process heaters, regardless of fuel type. NOx emission limits in BAAQMD Regulation 9 

Rule 7 are more stringent than emission limits for solid fuel fired units in District Rule 

4352. 

 

Overall BAAQMD Regulation 9 Rule 7 is more stringent than District Rule 4352 when it 

is applied to solid fuel fired units. The District believes that that a 40ppm NOx emission 

limit is technologically infeasible for solid fuel fired units, and is not aware of any solid 

fuel fired boiler, steam generator or process heater that has operated at this level. 
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4. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 411 

(NOx from Boilers, Process Heaters, and Steam Generators) last amended 

August 23, 2007 

SMAQMD Rule 411 applies to units (i.e., boilers, steam generators and process 

heaters) fired on gaseous or nongaseous fuels with a rated heat input capacity equal to 

or greater than 1 MMBtu/hr. Exemptions include: 

• Any unit that is exclusively used by an electric utility to generate electricity 

• Process heaters, kilns, and furnaces where the products of combustion come into 

direct contact with the material to be heated 

• Waste heat recovery boilers 

Units 1.0-2.5 MMBtu/hr that use less than 40,000 therms per year are subject to a 

limited exemption from emission limits. 

Applicable Emission Limits: 

Boiler Type NOx limit CO limit 

Gaseous Fuel Fired 1-5MMBtu/hr 30ppm 400ppm 

Non-Gaseous Fuel Fired 1-5MMBtu/hr 40ppm 400ppm 

Biomass Fuel Firing 70ppm 400ppm 

Emergency Standby Non-Gaseous Fuel Firing 150ppm N/A 

Comparison of SMAQMD Rule 411 and District Rule 4352 

SMAQMD Rule 411 applies to units fired on gaseous or non-gaseous fired fuels. NOx 

emission limits for non-gaseous fuel fired units in SMAQMD Rule 411 are more 

stringent than emission limits for solid fuel fired units in District Rule 4352. 

 

Overall SMAQMD Rule 411 is more stringent than District Rule 4352 when it is applied 

to solid fuel fired units. The District believes that that a 40ppm NOx emission limit is 

technologically infeasible for solid fuel fired units, and is not aware of any solid fuel fired 

boiler, steam generator or process heater that has operated at this level. 

5. Ventura County Air Pollution Control District (VCAPCD) Rule 74.15 (Boilers, 

Steam Generators, and Process Heaters) last amended November 8, 1994 

VCAPCD Rule 74.15 applies to boilers, steam generators and process heaters used in 

all industrial, institutional and commercial operations with a rated heat input capacity of 

equal to or greater than, 5 million BTUs per hour. Exemptions include: 

• Utility electric power generating units 

• Auxiliary boilers used with a utility electric power generating unit 

• Water heaters 

VCAPCD Rule 74.15 establishes a 40ppm NOx emission limit for units subject to the 

rule. 
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Comparison of VCAPCD Rule 74.11.1 and District Rule 4352 

VCAPCD Rule 74.15 applies to all large boilers, steam generators and process heaters, 

regardless of fuel type. NOx emission limits in SMAQMD Rule 411 are more stringent 

than emission limits for solid fuel fired units in District Rule 4352. 

 

Overall VCAPCD Rule 74.15 is more stringent than District Rule 4352 when it is applied 

to solid fuel fired units. The District believes that that a 40ppm NOx emission limit is 

technologically infeasible for solid fuel fired units, and is not aware of any solid fuel fired 

boiler, steam generator or process heater that has operated at this level. 

6. Ventura County Air Pollution Control District (VCAPCD) Rule 74.15.1 (Boilers, 

Steam Generators, and Process Heaters) last amended June 13, 2000 

VCAPCD Rule 74.15.1 applies to boilers, steam generators and process heaters with a 

rated heat input capacity equal to or greater than 1 million BTU per hour and less than 5 

million BTU per hour. 

VCAPCD Rule 74.15.1 establishes a 30ppm NOx emission limit for units subject to the 

rule. 

Comparison of VCAPCD Rule 74.15.1 and District Rule 4352 

VCAPCD Rule 74.15.1 applies to all small boilers, steam generators and process 

heaters, regardless of fuel type. NOx emission limits in SMAQMD Rule 411 are more 

stringent than emission limits for solid fuel fired units in District Rule 4352. 

 

Overall VCAPCD Rule 74.15.1is more stringent than District Rule 4352 when it is 

applied to solid fuel fired units. The District believes that that a 30ppm NOx emission 

limit is technologically infeasible for solid fuel fired units, and is not aware of any solid 

fuel fired boiler, steam generator or process heater that has operated at this level. 

Conclusion

The District maintains that the ARB RACT/BARCT guidelines for non-gaseous fired 

units were not meant to apply to solid fuel fired boilers based on the description of 

control technology options. The District applies the 40ppm emission limit to liquid fired 

units. 

Permitted units subject to Rule 4352 are all equipped with non-catalytic selective reduction 

systems which the District considers to be BARCT for this application. 
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Further, the District does not believe that a 40ppm NOx emission limit is technologically 

infeasible for solid fuel fired units, and is not aware of any solid fuel fired boiler, steam 

generator or process heater that has operated at this level. 

After careful evaluation of federal rules or regulations covering emissions from this 

source category as well as prohibitory rules in other California nonattainment areas, 

District staff concludes that District Rule 4352 satisfies RACT for solid fuel boilers, 

steam generators, and process heaters. 
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Rule 4354 – Glass Melting Furnaces 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 9.38 8.02 8.56 8.73 9.08 9.64 10.12 10.65 

VOC 0.337 0.39 0.415 0.423 0.440 0.469 0.49 0.515 

(Source: District 2007 Ozone Plan) 

District Rule 4354 Description

This rule controls NOx, SOx, VOC, and CO emissions from any glass-melting furnace 

located at facilities that have the total potential to emit of at least ten tons per year of 

NOx or at least ten tons per year of VOC. The emission limits depend on type of glass 

produced, furnace firing technology and emission averaging period. NOx emission 

limits range from 4.0 to 9.2 pounds NOx per ton of glass pulled (lb/ton glass); CO limits 

are 300 ppmv or 0.9 to 1.0 lbs/ton glass; and VOC emission limits are 20 ppmv or range 

from 0.1 to 0.25 lbs/ton glass. 

Operators of multiple furnaces have the option to average emissions across the 

furnaces in order to comply with the emission limits. Operators who select this option 

are required to meet emission limits that are 10% lower than if they had controlled each 

furnace individually. 

Operators meet current emission limits through a selection of furnace firing technology 

and glass raw materials. There are a range of NOx control strategies to achieve the 

current emission limits. These strategies go beyond low-NOx or ultra-low-NOx burners 

and electric boost to advanced controls like oxygen-enriched air staging (OEAS), 

replacement of combustion air with pure oxygen (oxy-fuel firing), and fuel re-burn 

technology (the proprietary 3-R process). One source is in the process of converting to 

selective catalytic reduction (SCR) for NOx control. This SCR system will be the first in 

the US on a glass furnace. 

How does District Rule 4354 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

There is no CTG for this source category. 

B. EPA – Alternative Control Technology (ACT) 

EPA-453/R-94-037 Alternative Control Techniques Document – NOx Emissions from 

Glass Manufacturing 
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This document outlines the available control techniques for three types of glass melting 

furnaces – container glass, flat glass and pressed-and-blown glass. The document lists 

no specific NOx emission limit, although it does suggest estimated percent NOx 

reduction from uncontrolled levels. In not having a specific NOx limit for any of the 

subject furnaces, the document does not define RACT for the three types of glass. 

There is no ACT for glass melting furnaces at either wool fiberglass or strand fiberglass 

manufacturing facilities. 

C. Standards of Performance for New Stationary Sources (NSPS) 

40 CFR 60 Subpart CC – Standards of Performance for Glass Manufacturing Plants; 

and 40 CFR Subpart PPP – Standards of Performance for Wool Fiberglass 

Insulation Plants 

These NSPSs target the control of particulate matter from the specified glass 

manufacturing processes. As such, neither NSPS defines applicable RACT for these 

sources. There is no NSPS for fiberglass strand furnaces. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There is one NESHAP that could apply to glass melting furnaces – 40 CFR 61 Subpart 

N (National Emission Standard for Inorganic Arsenic Emissions from Glass 

Manufacturing Plants). An arsenic-containing compound could be used in the glass 

recipe to improve glass quality, although no glass manufacturer subject to the District 

rule uses the arsenic compound in their operations. The NESHAP specifically targets 

inorganic arsenic emissions, and therefore, does not apply to NOx or VOC emission 

limits. The NESHAP does not define applicable RACT for this source category. 

There are two MACT standards that apply to glass melting furnaces – 40 CFR 63 

Subpart NNN (National Emission Standards for Hazardous Air Pollutants for Wool 

Fiberglass Manufacturing Plants) and 40 CFR 63 Subpart SSSSSS (National Emission 

Standards for Hazardous Air Pollutants for Glass Manufacturing Area Sources). The 

portions of both MACTs that apply to the glass melting furnaces are particulate emission 

limits and subsequent recordkeeping. As such, they do not regulate NOx or VOC for 

this source category; therefore the MACT standard does not define applicable RACT for 

this source category. 

How does District Rule 4354 compare to rules in other air districts?

District staff compared NOx limits, optional control requirements, and work practice 

standards in District Rule 4354 to comparable requirements in rules from the following 

California nonattainment areas: 
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• South Coast AQMD Rule 1117, as amended January 1984 

• Bay Area AQMD Regulation 9 Rule 12, as adopted January 1994 

• Ventura County APCD and Sacramento Metro AQMD do not have a specific 

prohibitory rule for this source category. 

A. South Coast AQMD Rule 1117 (Emissions of Oxides of Nitrogen from Glass 

Melting Furnaces) 

South Coast AQMD Rule 1117 has a single NOx limit of 4.0 pounds per ton glass 

pulled, however the limit does not apply to tableware glass, flat glass, or fiberglass 

furnaces – these are specifically exempt under Rule 1117. This means that Rule 1117 

applies only to container glass furnaces. Alternative emission control plans are allowed 

which let emissions to be averaged over more than one furnace as long as the total 

emissions are no greater than if each furnace was individually meeting the emission 

limit. Recent amendments to District Rule 4354 have reduced NOx limits for container 

glass which are lower than South Coast Rule 1117. The District rule also goes beyond 

the South Coast AQMD rule to limit NOx emissions from flat glass and fiberglass 

furnaces. Additionally, the alternative emission control plan in District Rule 4354 

requires a 10% reduction in total emissions for the averaged group of furnaces over 

controlling the furnaces individually. 

B. Bay Area AQMD Regulation 9 Rule 12 (Nitrogen Oxide Emissions from Glass 

Melting Furnaces) 

Bay Area AQMD Regulation 9 Rule 12 has a single NOx emission limit of 5.5 pounds 

NOx per ton glass pulled, which is lower than current District Rule 4354 NOx emission 

limits for flat glass. However, there are no flat glass furnaces within Bay Area AQMD, 

meaning the emission limit has not been achieved in practice in the Bay Area AQMD for 

flat glass furnaces. On April 3, 2009, Mr. Weyman Lee of BAAQMD has verified that 

there are no flat glass furnaces within the BAAQMD. With the most recent amendments 

to District Rule 4354, the NOx emission limit for every category of glass is more 

stringent than the NOx limit in Bay Area AQMD Regulation 9 Rule 12. 

Are additional cost-effective controls available?

As noted above, the current furnaces are already utilizing advanced control 

technologies for NOx. Table 2 below details the NOx control technologies being used 

within the District. All 14 glass melting furnaces in the District are using low-NOx or 

ultralow NOx burners in conjunction with the advanced NOx controls. The estimated 

emission reductions are taken from EPA’s ACT fro glass furnaces. Cost effectiveness 

was taken from the recent rule amendment project where only SCR and oxy-fuel firing 

were considered sufficient to meet the new NOx limits. While SCR is new to US glass 

furnaces, it has been in use in Europe for several years. 
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Table 2 – NOx Control Strategies, Cost Effectiveness, and Actual Technology Utilization 

NOx Control 

Technology 

Estimated Emission 

Reduction over 

Uncontrolled 

Furnaces 

Estimated Cost 

Effectiveness 

($/ton reduced) 

Number District 

Furnaces Currently 

Using This 

Technology 

Low-NOx or Ultra-low 

NOx burners 30% to 40% --- 14 

Electric Boost 10% to 30% --- Unable to tell from 

individual permits 

Oxygen Enriched Air 

Staging (OEAS) 30% to 75% --- 3 

Oxygen Fuel (oxyfuel) Firing 75% to 85% $51,700 6 

Fuel Re-burn (3-R) 50% to 65% --- 1 

Selective Catalytic 

Reduction (SCR) 75% to 90% $2,180 – $10,800 1 

Were relevant public comments received recently about Rule 4354?

Relevant public comments received during the public process for adopting the District’s 

2008 Ozone Plan have been addressed in Appendix L of the plan. 

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4354 

satisfies RACT for glass melting furnaces. 
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Rule 4401 – Steam Enhanced Crude Oil Production Well Vents 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

VOC 13.5 13.2 12.6 12.5 11.7 11.3 11.0 12.1 

(Source: District 2007 Ozone Plan) 

District Rule 4401 Description 

This rule controls VOC emissions from steam-enhanced crude oil production well vents. 

The primary source of VOC emissions from the wells is the casing vent. The emissions 

from a casing vent are usually controlled through the operation of a VOC collection and 

control device. 

This rule prohibits the operation of a steam-enhanced crude oil production well, except 

cyclic wells meeting certain requirements, unless the uncontrolled VOC emissions from 

any well vent are reduced by at least 99 percent by weight, or, if several steamenhanced crude oil production well vents are connected to a vapor collection and 

control system, this rule requires that total uncontrolled VOC emissions be reduced by 

at least 99 percent. 

Fugitive VOC emissions can also occur from oil and gas flowing through the various 

components (such as valves and flanges) that are part of the piping from the wells to 

the emission control system. Rule 4401 contains a schedule that specifies the number 

of allowable component leaks based on the number of wells connected to a vapor 

collection and control system. Rule 4401 requires an operator, upon detection of a leak, 

to affix a readily visible tag bearing the date on which the leak is detected. Rule 4401 

further requires an operator to repair a leak within fifteen (15) calendar days; failure to 

repair the leak would constitute a violation of the rule. 

How does District Rule 4401 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

There is no CTG for this source category. 

B. EPA – Alternative Control Technology (ACT) 

There is no ACT for this source category. 
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C. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS for this source category. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There is no NESHAP or MACT for this source category. 

How does District Rule 4401 compare to rules in other air districts?

District staff compared control requirements, and work practice standards in District 

Rule 4401 to comparable requirements in rules from the following California 

nonattainment areas: 

• South Coast AQMD Rule 1148, as amended November 5, 1982 

• Bay Area AQMD, Sacramento Metropolitan AQMD, and Ventura County APCD do 

not have a prohibitory rule that covers the same emission source category 

South Coast AQMD Rule 1148 

South Coast AQMD Rule 1148 (Thermally Enhanced Oil Recovery Wells) requires that 

ROG emissions from a steam drive well not to exceed 4.5 lb/day or if steamed drive 

wells are connected to vapor control system ROG emissions from the control system 

shall average no more than 4.5 lb/day/connected well. 

Using CARB emissions factor for uncontrolled steam drive well of 220 lb-VOC/day, Rule 

4401’s 99% control requirement equates to 2.2 lb/day/well, which is more stringent than 

4.5 lb/day/well (heavy oil production results in no methane or ethane, meaning 100% of 

ROGs are considered VOCs). 

South Coast AQMD Rule 1148 does not specify any fugitive VOC leak detection and 

repair provisions where as Rule 4401 specifies the number of allowable component 

leaks based on the number of wells connected to a vapor collection and control system. 

Rule 4401 requires an operator, upon detection of a leak, to affix a readily visible tag 

bearing the date on which the leak is detected. Rule 4401 further requires an operator 

to repair a leak within fifteen (15) calendar days; failure to repair the leak would 

constitute a violation of the rule. 

South Coast AQMD Rule 1148 contains a six month exemption for steam drive wells if 

steam is injected more frequently than 45 days and amount of steam injection 

expressed as water is more than 2,000 barrels. Rule 4401 provides exemptions for up 

to 40 cyclic wells owned by a company that are undergoing pilot testing and well 

stimulation. Rule 4401 also exempts for up to 5 cyclic wells (20 cyclic wells for small 

producer) if wells are located more than 1000 feet from an existing well control system 
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operated by the company and operation is under District permit. South Coast AQMD 

Rule 1148 does not limit number of wells that can be exempt and Rule 4401 does not 

limit duration of exemption, therefore exemptions in the both rules can not be compared 

directly. 

Both South Coast AQMD Rule 1148 and Rule 4401 require annual testing of vapor 

control systems. However District Rule waives this testing requirement if uncondensed 

vapors are incinerated in fuel burning equipment, internal combustion engine or in a 

smokeless flare. 

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4401 

satisfies RACT for steam-enhanced crude oil production well vents. 
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Rule 4402 – Crude Oil Production Sumps 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

VOC 0.42 0.41 0.40 0.39 0.37 0.36 0.35 0.39 

(Source: District 2007 Ozone Plan) 

On April 1, 2009, the United State Environmental Protection Agency (EPA) Region IX 

sent a comment recommending the RACT analysis clarify how the 3 to 60 tons/day 

emissions inventory cited in the District’s 2007 Ozone Plan was in error. The District 

consultant’s emissions inventory methodology which estimated 60 tons/day VOC from 

sumps was based on Department of Oil, Gas, and Geothermal Energy (DOGGR) 

database of sumps compiled in early 1990s including surface area of sumps and 

characteristic of fluids, data on sump closures from Central Valley Regional Water 

Quality Control Board (RWQCB) and District survey in 1997. It is important to note that 

DOGGR and RWQCB data on number of sumps and surface areas are not as accurate 

as the recent data submitted by oil producers in the San Joaquin valley (Valley) to the 

District during the emissions inventory survey in late 2007. The 60 tons/day VOC 

estimated by the consultant in November 2003 was based on an estimated total 660 

sumps with a total surface area of 9,590,945 square feet1

. In contrast, the 2007 District 

sump emissions inventory2

 of oil producers in the Valley showed that there are only a 

total of 95 sumps with a total surface area of 308,763 square feet. Furthermore, the 

consultant used the California Air Resources Board’s default emission factors for sumps 

while the recent District inventory used the emission factors developed by the District 

based on data from source testing of sumps in Kern County. The updated emission 

factors were published in the District’s corrected “Technical Guidance for Emissions 

Inventory Criteria and Guidelines Regulation for AB 2588 (Air Toxics “Hot Spots” 

Information and Assessment Act of 1987). The 2007 District emissions inventory 

estimated VOC emission from sumps is about 2.6 tons/day. The District expects to 

finalize the area source emissions inventory methodology report by end of April 2009 

and thereafter submit an updated sumps inventory to the California Air Resources 

Board. 

District Rule 4402 Description

District Rule 4402 controls VOC emissions from crude oil production sumps located at 

facilities that produce heavy crude oil. Rule 4402 requires sumps to have a flexible 

floating cover, rigid floating cover, or fixed roof cover. The flexible floating cover has to 

be equipped between the sump wall and the cover edge, and the gap between the wall 

 

1

 “Emission Inventory Methodology- Oil and Gas Sumps (Methods Document STI-903340-242f-MD)”, Sonoma 

Technology, Inc., November 7, 2003. 

2

 Draft 2007 Area Source Emissions Inventory Methodology, 310 – Oil Production Sumps and Well Cellars posted in 

www.valleyair.org/busind/draft-policies/sumpscellars 2007.pdf.
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and at every point around the perimeter must not exceed 1 inch. The fixed-roof cover 

must have a PV and meet certain specific requirements. If sumps are replaced with 

above-ground fixed roof tanks, the tanks must comply with the provisions of Rule 4623. 

How does District Rule 4402 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

District staff’s review of the EPA CTG list indicates that there is no CTG for crude oil 

production sumps. 

B. EPA – Alternative Control Techniques (ACT) Document 

District staff’s review of the EPA ACT list indicates that there is no ACT for crude oil 

production sumps. 

C. Standards of Performance for New Stationary Sources (NSPS) 

District staff’s review of 40 CFR 60 (Standards of Performance for New Sources) 

indicates that there is no NSPS for crude oil production sumps. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

District staff’s review of 40 CFR 61 (NESHAP) and 40 CFR (NESHAP for Source 

Categories) indicates that there is no NESHAP or MACT for crude oil production sumps. 

How does District Rule 4402 compare to rules in other air districts?

District staff compared District Rule 4402 with the rules of other California ozone 

nonattainment air districts’ rules (South Coast Air Quality Management District, Bay 

Area Air Quality Management District, Sacramento Metropolitan Air Quality 

Management Air District, and Ventura County Air Pollution Control District on crude oil 

production sumps. The results of the analysis are discussed below. 

The control requirements of Rule 4402 are essentially the same as Ventura County Air 

Pollution Control District (VCAPCD) Rule 71.4. South Coast AQMD, Bay Area AQMD, 

Sacramento AQMD do not have any rule on crude oil production sumps. 

Although VCAPCD Rule 71.4 prohibits the use of first stage sumps, District staff 

believes that other VCAPCD either do not have first stage sumps or such sumps have 

been replaced with tanks. Although use of first stage sumps is allowed by District Rule 

4402, it does not necessarily mean that the rule is less stringent than other air districts’ 

rules, for the following reason. If first stage sumps are replaced with tanks, the tanks 
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would be subject to another rule that control emissions from the storage of organic 

liquids. District Rule 4623 (Storage of Organic Liquids) applies to tanks that have a 

capacity of at least 1,100 gallons that store organic liquids with a true vapor pressure 

(TVP) of 0.5 psia or greater. The tank VOC control requirements are based on the tank 

size and true vapor pressure (TVP) of the stored organic liquid. Organic liquids with a 

TVP less than 0.5 psia would not be subject to the VOC control requirements of Rule 

4623. Replacing first stage sump with a tank could result in an unintended 

consequence that the tank would either be totally uncontrolled or less effectively 

controlled compared to Rule 4402 because the TVP might be lower than the control 

trigger level specified in Rule 4623. 

Based on the District’s Permit database, staff has determined that there are only very 

few permitted small-size first-stage sumps for processing heavy crude oil that were 

issued to very small producers (less than 150 barrels of oil/day production) and they are 

not major sources (less than 10 tons per year of VOC or NOx)3

. The source testing 

required by Rule 4623, shows the TVP of the heavy crude oil is less than 0.5 psia. As 

discussed above, prohibiting the use of first stage sumps would essentially force 

operators to replace the sumps with tanks, which could result in the tanks being exempt 

from Rule 4623 because the TVP is less than 0.5 psia. Although Rule 4402 allows the 

use of first stage sumps, the controls are equal to or better than that which would be 

required for such materials stored in tanks. Furthermore, it is important to mention that 

the District’s 2007 survey of crude oil sumps4 revealed that there are no active first 

stage sumps operating in the San Joaquin Valley. Therefore, staff believes that existing 

control requirements of the rule satisfy RACT for this operation. 

District staff reviewed other air districts’ rules for this source category and found that, 

except for SBCAPCD Rule 344, other air districts rules that control VOC emissions from 

sumps have no exemption for small producer sumps; no minimal emissions exemption; 

and have a lower limit (based on a lower VOC content) for the clean produced water 

exemption. SBCAPCD Rule 344 exempts sumps of oil producer producing 150 barrels 

of oil/day regardless of the type of oil (light or heavy crude oil). 

Rule 4402 exempts small producers’ second and third stage sumps less than 1,000 

square feet surface area used exclusively for heavy crude oil. Another exemption is 

provided for very small producer second and third stage sumps less than 5,000 square 

feet used exclusively for heavy crude oil. Small producer is defined in the rule as a 

producer whose oil production does not exceed 6,000 barrels/day. Very small oil 

producer is defined in Rule 4402 as a producer whose oil production does not exceed 

150 barrels/day, similar to SBCAPCD Rule 344. 

 

3

 Smilodon Oil Company (Facility ID S-2771); Woodward Oil Company (Facility ID S-780); Arthur McAdams (Facility 

ID S-2288); Gotland Oil (Facility ID S-2803 and S-2804). The total controlled VOC emissions from these five heavy 

oil first stage sumps are estimated at 0.04 tons per day. Recent District’s survey indicated no first stage sumps 

operating in the District. 

4

 Draft 2007 Area Source Emissions Inventory Methodology, 310 – Oil Production Sumps and Well Cellars posted in 

http://www.valleyair.org/busind/draft-policies/sumpscellars2007.pdf.
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-79 

Rule 4402 exemption for small/very small producers’ second stage and third stage 

sumps are exclusively for heavy crude oil and only for small size sumps. As discussed 

above, the TVP of heavy crude oil is less than 0.5 psia. Low-TVP heavy crude oil emits 

less VOC than higher TVP light crude oil. The VOC emissions from small size second 

and third stage sumps are relatively low. Requiring small/very small producers to install 

and operate a fixed or floating cover would not be economically feasible because they 

have much less revenue than large oil producers. The estimated cost effectiveness of 

a rigid floating cover for a 5,000 square feet second stage sump containing heavy crude 

oil is about $64,800 per ton of VOC reduced5

. The cost effectiveness value for heavy 

crude oil third stage sump cover would be much higher than for a second stage sump. 

Due to economic infeasibility, District staff believes the exemption is still appropriate. 

The exemptions for minimal VOC emissions (0.007 lb/sq.ft/day) and clean produced 

water (35 milligrams/liter) are also considered to still be appropriate. It is important to 

note that the emissions from clean produced water are significantly less than heavy 

crude. The cost of controlling VOC emissions from clean produced water sumps would 

be significantly higher than heavy crude oil sumps. Due to economic infeasibility, 

District staff believes the exemptions in Rule 4402 are appropriate. Based on the 

discussion above, District staff deems Rule 4402 to satisfy RACT for this category. 

Conclusion

District staff concludes that District Rule 4402 satisfies RACT for Crude Oil Production 

Sumps. 

 

5

 SBCAPCD Staff Report for Rule 344 (Sumps, Pits, and Well Cellars). Rigid floating cover annualized cost for 5,000 

sq.ft. sump is $78,111 (1986 dollars). Assuming 3% per year consumer price index (inflation rate) for 22 years, the 

1986 dollars would be adjusted by an additional 66% to 2008 dollars. The 2008 adjusted annualized cost is 

$129,664 [($78,111) + (78,111 x 0.66)]. Assuming a VOC emission reduction from heavy crude second stage sump 

is about 2 tons per year, the cost effectiveness would be $64,832. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-80 

Rule 4404 – Heavy Oil Test Station - Kern County

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

VOC 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

(Source: District 2007 Ozone Plan) 

District Rule 4404 Description

District Rule 4404 controls VOC emissions from operation of heavy oil test stations 

(HOTS). HOTS is a tank setting comprised of both a family tank and one or more test 

tanks. A family tank directly receives crude oil production from more than one steam 

drive well through individual production lines which discharge into the tank. A test tank 

tests the production rate from a single steam drive well. 

Rule 4404 prohibits operation of HOTS unless the VOC emissions are reduced by at 

least 99%. Except during sampling, gauging, and PV valve vent, any tank roof opening 

must be equipped with a cover, seal, or lid with no visible gap and maintained in a gastight condition. 

Requirements of this rule are applicable to heavy oil test stations (HOTS) that are 

atmospheric tanks. A review of the District’s permit database and observations of 

Compliance Division staff indicate that there are no atmospheric HOTS operating in the 

District. All HOTS operations are now employing pressure vessels which do not vent to 

atmosphere. These unvented pressure vessels are exempt from District permitting per 

section 6.13 of District Rule 2020. Therefore, the VOC emissions from this source 

category are considered to be zero. 

How does District Rule 4404 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

District staff’s review of the EPA CTG list indicates that there is no CTG for HOTS. 

B. EPA – Alternative Control Techniques (ACT) Document 

District staff’s review of the EPA ACT list indicates that there is no ACT for HOTS. 

C. Standards of Performance for New Stationary Sources (NSPS) 

District staff’s review of 40 CFR 60 (Standards of Performance for New Sources) 

indicates that there is no NSPS for HOTS. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-81 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

District staff’s review of 40 CFR 61 (NESHAP) and 40 CFR (NESHAP for Source 

Categories) indicates that there is no NESHAP or MACT for HOTS. 

How does District Rule 4404 compare to rules in other air districts?

District staff reviewed other nonattainment California air districts’ rules (SCAQMD, 

BAAQMD, SCMAQMD, and VCAPCD) and found that they do not have rules for this 

source category. 

Conclusion

Since there are no HOTS currently operating in the District that are subject to 

requirements of this rule and the VOC emissions from this source category are 

considered to be zero. Therefore District staff concludes that District Rule 4404 satisfies 

RACT. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-82 

Rule 4407 – In-Situ Combustion Well Vents 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 0 0 0 0 0 0 0 0 

VOC 0 0 0 0 0 0 0 0 

(Source: District 2007 Ozone Plan) 

District Rule 4407 Description

District Rule 4407 controls VOC emissions from in situ-combustion well vents. The rule 

applies to all crude oil production wells where production has been enhanced by in-situ 

combustion. In situ-combustion is defined in the rule as a thermal crude oil recovery 

process in which air is injected into an oil reservoir and in-place petroleum oxidizes at 

an accelerated rate. The heat of combustion and combustion products enhance oil 

production by decreasing oil viscosity and pressurizing the reservoir. In situ combustion 

well is defined in the rule as any crude oil production well which produces from the 

same zone in which an air injection well is completed and lies within 1,000 feet from an 

injection well. 

District Rule 4407 prohibits operation of any in-situ combustion well unless the well vent 

is connected to an emission control device which abates 85% by weight of entering 

VOC gases or is connected to a fuel burning equipment (furnace, boiler, etc.) or a 

smokeless flare. All components (piping, valves, fittings, pumps, compressors, etc.) 

should be maintained in good repair and must be inspected for leaks on a quarterly 

basis. If no more than 2% of all components of the collection system are found to be 

leaking during each three consecutive quarterly inspections, the inspection frequency 

may be changed from quarterly to annual. The total number of leaks in a collection 

system should not exceed 2% of all the components in the collection system. Upon 

detection of a leak, the operator should affix a visible tag indicating the date of detection 

of the leak and the tag must remain in place until the leak is repaired. A leaking 

component must be repaired within 15 days of leak detection, but a 10 day extension to 

repair a leak may be granted provided the operator demonstrates that necessary and 

sufficient actions have been taken to correct the leak. Failure to repair a leak after the 

10 day extension constitutes a violation of the rule. 

District Rule 4407 requires annual testing of the VOC control efficiency of the control 

and collection system (testing should be conducted during June, July, August, or 

September each year if the system’s control efficiency is dependent upon ambient 

temperature). The APCO may waive the test requirement if all uncondensed VOC 

emissions is collected by a collection and control system are burned in fuel burning 

equipment or a smokeless flare. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-83 

Currently, there are no in-situ combustion crude oil wells operating in the San Joaquin 

Valley Air Basin. A review of the California Division of Oil, Gas, and Geothermal 

Resources’ oil and gas wells database showed that there are only 16 in-situ combustion 

wells in SJVAB, but all these wells were shut-in (i.e., not producing). Wells that are 

shut-in do not emit air pollutants; therefore, there are no emissions from this source 

category. 

How does District Rule 4407 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

District staff’s review of the EPA CTG list indicates that there is no CTG for in-situ 

combustion crude oil wells. 

B. EPA – Alternative Control Techniques (ACT) Document 

District staff’s review of the EPA ACT list indicates that there is no ACT for in-situ 

combustion crude oil wells. 

C. Standards of Performance for New Stationary Sources (NSPS) 

40 CFR 60 (Standards of Performance for New Sources) does not specify any NSPS for 

in-situ combustion crude oil wells. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

40 CFR 61 (NESHAP) and 40 CFR (NESHAP for Source Categories) does not specify 

any NESHAP or MACT for in-situ combustion crude oil wells. 

How does District Rule 4407 compare to rules in other air districts?

District staff reviewed other California ozone nonattainment air districts’ rules (South 

Coat Air Quality Management District, Bay Area Air Quality Management District, 

Sacramento Metropolitan Air Quality Management Air District, and Ventura County Air 

Pollution Control District) and found that other air districts do not have any rules on insitu combustions crude oil wells. 

Conclusion

Since there are no federal rules and regulations as well as prohibitory rules in other 

California nonattainment areas for in-situ-combustion crude oil wells, District staff 

concludes that District Rule 4407 satisfies RACT. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-84 

Rule 4408 – Glycol Dehydration Systems 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

VOC NQ NQ NQ NQ NQ NQ NQ NQ 

The emission inventory for this source category is not available. 

District Rule 4408 Description

Rule 4408, adopted on December 19, 2002, reduces emissions of volatile organic 

compounds (VOCs) from glycol dehydration systems used on natural gas streams. This 

rule provides the following three control options. 

• Condenser/Vapor Disposal - all uncondensed VOC emissions are directed to a 

vapor recovery system, a fuel gas system, or a sales gas system. 

• Flare/Incinerator - all VOC emissions are combusted by a flare, an incinerator, a 

reboiler, or a thermal oxidizer. 

• Any other system to control VOC emissions by at least 95% or to no higher than 

1.7 pounds of VOC emitted per million dry standard cubic feet of gas. 

How does District Rule 4408 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

There is no CTG for this source category. 

B. EPA – Alternative Control Techniques (ACT) Document 

There is no ACT for this source category. 

C. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS for this source category. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

40 CFR 63 Subpart HH: National Emission Standards for Hazardous Air Pollutants for 

Oil and Natural Gas Production 

For major oil and natural gas production facilities, this subpart requires controls at 

process vents if actual flowrate of natural gas to the glycol dehydration unit is greater 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-85 

than 85 thousand m3

/day, on an annual average basis; or the actual average benzene 

emissions from the glycol dehydration unit are greater than 0.90 Mg/ yr. 

The control system must reduce emissions: (1) by 95.0 percent or more of HAP, or (2) 

by connecting the process vent to a process natural gas line, or (3) Pollution prevention 

measures, such as process modifications or combinations of process modifications and 

one or more control devices that reduce the amount of HAP emissions generated, are 

allowed as an alternative provided they achieve the required emission reductions. (CFR 

Volume 64, Number 116, page 32633) 

The control requirements as described above are the same as required by Rule 4408. 

For this subpart controls are required if more than 85 thousand m3

/day is processed 

which is equal to 1,095 million standard cubic feet. While Rule 4408 controls required if 

more than 5 million standard cubic feet of gas processed. Therefore Rule 4408 

requirements are more stringent than requirements of 40 CFR 63, subpart HH. 

How does District Rule 4408 compare to rules in other air districts?

District staff compared control requirements in District Rule 4408 to comparable 

requirements in rules from the following California nonattainment areas: 

• Ventura County APCD Rule 71.5, as amended December 13, 1994 

1. Ventura County APCD Rule 71.5 

Ventura County APCD Rule 71.5 requirements are same as requirements of Rule 4408. 

Conclusion

District staff concludes that District Rule 4408 satisfies RACT for Glycol Dehydration 

Systems. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-86 

Rule 4409 – Components Serving Light Crude Oil or Gases at Light 

Crude Oil and Gas Production Facilities and Components at Natural 

Gas Processing Facilities 

Emissions Inventory:

 Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

VOC 5.0 4.9 4.8 4.7 4.5 4.3 4.3 11.6 

VOC* adj 9.943 3.94 3.80 3.76 3.68 3.57 3.47 3.40 

* Emissions inventory does not reflect reductions resulting from recently adopted Rule 4409. This 

adjustment to the baseline inventory accounts for the 60% reduction from previously controlled emissions 

level resulting from Rule 4409 implementation effective April 2006. 

District Rule 4409 Description

Rule 4409, adopted on April 20, 2005, concerns fugitive emissions from various 

components at Light Crude Oil and Gas Production Facilities and Components at 

Natural Gas Processing Facilities. The main requirement of this rule is to reduce the 

number and severity of leaking components by regular inspection, repair, and 

replacement requirements, as well as mandating violations and penalties above certain 

leak thresholds. 

On March 23, 2006, EPA took direct final action to approve revisions to the San Joaquin 

Valley Unified Air Pollution Control District portion of the California State Implementation 

Plan. These revisions included approval of District Rule 4409. EPA, in evaluating and 

approving Rule 4409 included the following: 

“We believe these rules are consistent with the relevant policy and guidance 

regarding enforceability, RACT, and SIP relaxations.” (CFR Volume 71, Number 

56) 

Since Rule 4409 was approved by EPA as meeting RACT requirements, the District did 

not pursue a detailed RACT analysis. 

How does District Rule 4409 compare with federal rules and regulations?

The District did not conduct a detailed analysis of federal rules and regulations for Rule 

4409. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-87 

How does District Rule 4409 compare to rules in other air districts?

The District did not conduct a detailed comparison to rules in other air districts for Rule 

4409. 

Conclusion

District staff concludes that District Rule 4409 satisfies RACT for Components Serving 

Light Crude Oil or Gases at Light Crude Oil and Gas Production Facilities and 

Components at Natural Gas Processing Facilities. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-88 

Rule 4453 – Refinery Vacuum Producing Devices or Systems 

Emissions Inventory:

 Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

VOC NQ NQ NQ NQ NQ NQ NQ NQ 

(Source: District 2007 Ozone Plan) 

District Rule 4453 Description

Rule 4453, amended on December 17, 1992, applies to any vacuum producing device 

or system, including hot wells and accumulators in a refinery. The rule requires hot wells 

and accumulators to be covered. In addition, the rule requires the vapors from vacuum 

producing devices or systems, hot wells, and accumulators to be compressed and 

added to refinery gas, controlled and combusted to a firebox or incinerator with at least 

90% VOC control efficiency, or controlled by other methods approved by the APCO. 

How does District Rule 4453 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

EPA-450/2-77-025 (Control of Refinery Vacuum Producing Systems, Water Separators 

and Process Unit Turnarounds), October 1977, indicates that RACT requires noncondensable vapors from vacuum producing systems be combusted in a firebox. Also, 

process units should be depressurized to a flare, fuel gas system, or other combustion 

device before being opened for inspection or maintenance. The District Rule 4453 

requirements are as stringent as the CTG. 

B. EPA – Alternative Control Techniques (ACT) Document 

District staff’s review of the EPA ACT list indicates that there is no ACT for refinery 

vacuum producing device or system. 

C. Standards of Performance for New Stationary Sources (NSPS) 

District staff’s review of 40 CFR 60 (Standards of Performance for New Sources) 

indicates that there is no NSPS for refinery vacuum producing device or system. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-89 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

40 CFR 63 Subpart CC (NESHAP from Petroleum Refineries) does not have specific 

control requirements for refinery vacuum producing devices or systems. 

How does District Rule 4453 compare to rules in other air districts?

District staff compared District Rule 4402 with the rules of other California ozone 

nonattainment air districts’ rules (South Coast Air Quality Management District, Bay 

Area Air Quality Management District, Sacramento Metropolitan Air Quality 

Management Air District, and Ventura County Air Pollution Control District) on open 

burning. The results of the analysis are discussed below. 

A. SCAQMD Rule 465 (Refinery Vacuum-Producing Devices or Systems) 

amended August 13, 1999 

SCAQMD Rule 465 requires hot wells and accumulators to be equipped with covers. 

Rule 465 also requires the exhaust gases from vacuum-producing devices or systems, 

including hot wells and accumulators to be continuously collected and added to a fuel 

system or a combustion device. In comparison, Rule 4453 requires hot wells and 

accumulators to be covered, and the vapors from vacuum producing devices or 

systems, hot wells, and accumulators have to be compressed and added to refinery 

gas, controlled and combusted to a firebox or incinerator with at least 90% VOC control 

efficiency. Based on this evaluation District staff deems Rule 4453 is as stringent as 

SCAQMD Rule 465. 

B. BAAQMD Regulation 8, Rule 9 (Vacuum Producing Systems) amended 

July,20,1983 

BAAQMD Regulation 8, Rule 9 requires hot wells and accumulators to be covered and 

the organic vapors must be incinerated or treated so as to prevent their emission into 

the atmosphere. The rule also requires the non-condensable organic emissions from 

vacuum producing systems to be controlled and piped to an appropriate firebox or 

incinerator for combustion, or collected, compressed, and added to the fuel gas system, 

or be contained and treated so as to prevent their emission into the atmosphere. In 

comparison, Rule 4453 requires hot wells and accumulators to be covered, and the 

vapors from vacuum producing devices or systems, hot wells, and accumulators have to 

be compressed and added to refinery gas, controlled and combusted to a firebox or 

incinerator with at least 90% VOC control efficiency. Based on this evaluation District 

staff deems Rule 4453 is as stringent as BAAQMD Regulation 8, Rule 9. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-90 

C. VCAPCD Rule 74.8 (Refinery Vacuum Producing Systems, Wastewater 

Separators and Process Turnarounds) amended July 5, 1983 

VCAPCD Rule 74.8 requires all uncondensed organic vapors emitted from vacuum 

producing systems to be contained and piped the vapors to a firebox, a flare, or added 

to refinery fuel gas or feedbacks. In comparison, Rule 4453 requires hot wells and 

accumulators to be covered, and the vapors from vacuum producing devices or 

systems, hot wells, and accumulators have to be compressed and added to refinery 

gas, controlled and combusted to a firebox or incinerator with at least 90% VOC control 

efficiency. Based on this evaluation District staff deems Rule 4453 is as stringent as 

VCAPCD Rule 74.8. 

D. Sacramento AQMD has no rule for this source category. 

Conclusion

District staff concludes that District Rule 4453 satisfies RACT for Refinery Vacuum 

Producing Devices or Systems. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-91 

Rule 4454 – Refinery Process Unit Turnaround 

Emissions Inventory:

 Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

VOC NQ NQ NQ NQ NQ NQ NQ NQ 

(Source: District 2007 Ozone Plan) 

District Rule 4454 Description

Rule 4454 applies to any refinery vessel containing VOC. The rule exempts any process 

vessel that has been depressurized to less than five psig (1020 mm Hg). The rule 

requires VOC-containing vessels to be depressurized to less than 5 psig or as close to 

atmospheric pressure as possible, and the recovered vapors must be directed to a fuel 

gas system, incinerator, or a flare for combustion before venting/opening to the 

atmosphere. 

How does District Rule 4454 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

EPA-450/2-77-025 (Control of Refinery Vacuum Producing Systems, Water Separators 

and Process Unit Turnarounds), October 1977, indicates that RACT requires process 

units to be as close to atmospheric pressure as practicable as possible. The CTG 

indicated that most refineries should easily depressurize processing units to 5 psig or 

below before venting to the atmosphere. Atmospheric emissions will be greatly reduced 

if vapors are combusted as fuel gas or flared until the pressure in the vessel is as close 

to atmospheric. The District Rule 4454 requirements are as stringent as the CTG. 

B. EPA – Alternative Control Techniques (ACT) Document 

District staff’s review of the EPA ACT list indicates that there is no ACT for refinery 

process unit turnarounds. 

C. Standards of Performance for New Stationary Sources (NSPS) 

District staff’s review of 40 CFR 60 (Standards of Performance for New Sources) 

indicates that there is no NSPS for refinery process unit turnarounds. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

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4-92 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

40 CFR 63 Subpart CC (NESHAP from Petroleum Refineries) does not have specific 

control requirements for refinery process unit turnarounds. 

How does District Rule 4454 compare to rules in other air districts?

District staff reviewed other nonattainment California air districts’ rules (South Coast Air 

Quality Management District (SCAQMD), Bay Area Air Quality Management District 

(BAAQMD), Sacramento Air Quality Management District (SMAQMD) and Ventura 

County Air Pollution Control District (VCAPCD) that control the VOC emissions from 

depressurizing process vessels as discussed below. 

A. SCAQMD Rule 1123 (Refinery Process Turnarounds), amended December 12, 

1990 

SCAQMD Rule 1123 prohibits depressurizing any vessel containing organic materials 

unless the vapors released from the vessel are collected and contained for use as fuel 

or sent to a gas disposal system until the pressure in the vessel is below 5 psig, or is 

within 10 percent above minimum gauge pressure at which the vapors can be collected, 

whichever is lower. If inert gas displacement or vacuum eduction is used for process 

turnaround, an operator has to submit a plan to the executive officer for approval which 

describes at a least the following: the procedure used for gas displacement or eduction; 

the disposition of the displaced or educed organic gases, the stage in the displacement 

or eduction procedure at which disposition is changed from control facility to 

atmospheric venting; and the criteria by which said stage is identifiable. 

B. BAAQMD Regulation 8, Rule 10 (Organic Compounds - Process Vessel 

Depressurization), amended January 21, 2004 

BAAQMD Regulation 8, Rule 10 requires organic compounds emissions from 

depressurizing any process vessel to be controlled by venting them to a fuel gas 

system, firebox, incinerator, thermal oxidizer, flare or containing and treating them so as 

to prevent their emissions into the atmosphere. The depressurizing procedure should 

continue until the pressure within a process vessel is as close to atmospheric pressure 

as practically possible, in no case should a process vessel be vented to the atmosphere 

until the partial pressure of the organic compounds in the vessel is less than 1,000 mm 

Hg (4.6 psig). The rule prohibits opening a process vessel to the atmosphere unless 

the internal concentration of total organic compounds has been reduced to less than 

10,000 ppm expressed as methane. However, a process vessels may be opened to the 

atmosphere when the internal pressure is 10,000 ppm or greater if the total number of 

vessels opened with such concentration during any five consecutive years does not 

exceed 10% of the total vessel population and the organic compound emissions do not 

exceed 15 pounds/day. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-93 

Although Rule 4454 does not have a requirement like BAAQMD Regulation 8, Rule 10 

that prohibits opening a process vessel to the atmosphere unless the internal 

concentration of total organic compounds has been reduced to less than 10,000 ppmv, 

based on District’s staff field inspection experience and observations, operators would 

not start opening a process vessel for inspection or maintenance unless the internal 

vapor concentration is less than 5,000 ppmv or less than 10% of the lower explosive 

limit (LEL) for safety reasons in order to comply with applicable OSHA regulations. 

Additionally, such vessel is also considered a tank as defined in Rule 4623 (Storage of 

Organic Liquid) and is subject to the more stringent degassing provisions which require 

the vessel to be degassed to less than 5,000 ppmv or less than 10% of the LEL, 

whichever is lower. As such, the process vessel depressurization requirements of Rule 

4454 in conjunction with the degassing control requirements of Rule 4623 are more 

effective than other air districts’ rules. 

C. VCAPCD Rule 74.8 (Refinery Vacuum Producing Systems, Wastewater 

Separators and Process Turnarounds), amended July 5, 1983 

VCAPCD Rule 74.8 prohibits venting organic compounds to the atmosphere during 

depressurization or the vessel purging steps of a refinery process turnaround. All 

uncondensed organic gases should be vented to a fuel gas system or to a flare, or other 

methods which district has determined will prevent said gases from being emitted into 

the atmosphere. 

D. Sacramento AQMD has no rule for this source category. 

Conclusion

District staff concludes that District Rule 4454 satisfies RACT for Refinery Process Unit 

Turnaround. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-94 

Rule 4455 – Components at Petroleum Refineries, Gas Liquids 

Processing Facilities, and Chemical Plants 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

VOC 0.120 0.120 0.120 0.120 0.120 0.120 0.120 0.190 

VOC* adj 0.233 0.026 0.026 0.026 0.026 0.026 0.026 0.026 

* Emissions inventory does not reflect reductions resulting from recently adopted Rule 4455. The 

adjusted inventory accounts for the 89% reduction from previously controlled emissions level resulting 

from Rule 4455 implementation effective April 2006.

District Rule 4455 Description

Rule 4455, adopted on April 20, 2005, concerns fugitive emissions from various 

components at petroleum refineries and chemical plants. The main requirement of this 

rule is to reduce the number and severity of leaking components by regular inspection, 

repair, and replacement requirements, as well as mandating violations and penalties 

above certain leak thresholds. 

On March 23, 2006 EPA took direct final action to approve revisions to the San Joaquin 

Valley Unified Air Pollution Control District portion of the California State Implementation 

Plan. These revisions included approval of District Rule 4455. EPA, in evaluating and 

approving Rule 4455 included the following: 

“We believe these rules are consistent with the relevant policy and guidance 

regarding enforceability, RACT, and SIP relaxations.” (CFR Volume 71, Number 

56) 

Since Rule 4455 was approved by EPA as meeting RACT requirements, the District did 

not pursue a detailed RACT analysis. 

How does District Rule 4455 compare with federal rules and regulations?

The District did not conduct a detailed analysis of federal rules and regulations for Rule 

4455. 

How does District Rule 4455 compare to rules in other air districts?

The District did not conduct a detailed comparison to rules in other air districts for Rule 

4455. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-95 

Conclusion

District staff concludes that District Rule 4455 satisfies RACT for Components at 

Petroleum Refineries, Gas Liquids Processing Facilities, and Chemical Plants. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-96 

Rule 4565 - Biosolids, Animal Manure, and Poultry Litter Operations 

Emissions Inventory: 

Tons per day - summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 0 0 0 0 0 0 0 0 

VOC 9.7 9.8 9.9 10.0 10.1 10.2 10.3 10.4 

(Source: District 2007 Ozone Plan) 

District Rule 4565 Description

District Rule 4565, recently adopted on March 15, 2007, to limit VOC emissions from 

facilities whose throughput consists entirely or part of biosolids, animal manure, or 

poultry litter and the operator who landfills, land applies, composts, or co-composts 

these materials. Sewage treatment plants or other wastewater treatment facilities are 

not subject to this rule unless the operator landfills, land applies, composts, or cocomposts the treated material (biosolids) on site. 

How does District Rule 4565 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

There is no EPA CTG guidance document for biosolids, animal manure, and/or poultry 

litter operations. 

B. EPA - Alternative Control Technology (ACT) 

There is no EPA ACT guidance document for biosolids, animal manure, and/or poultry 

litter operations. 

C. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS guidance document for biosolids, animal manure, and/or poultry litter 

operations. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There is no NSPS guidance document for biosolids, animal manure, and/or poultry litter 

operations. 

How does District Rule 4565 compare to rules in other air districts?

District staff compared VOC limits, optional control requirements, and work practice 
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standards in District Rule 4565 to comparable requirements in rules from the following 

California nonattainment areas: 

• South Coast AQMD Rule 1133.2 - Emission Reductions from Co-Composting 

Operations (Adopted January 10, 2003 

• Bay Area AQMD, Sacramento Metropolitan AQMD and Ventura County APCD do not 

have rules that apply to composting or co-composting operations. 

South Coast Air Quality Management District (SCAQMD) Rule 1133.2 (Emission Reductions from 

Co-Composting Operations) 

SCAQMD Rule 1133.2 applies to all new and existing co-composting operations. 

Staff notes that there are some significant differences between District Rule 4565 and 

SCAQMD Rule 1133.2. This should not be interpreted to mean that one rule is more 

stringent than the other, but due instead to the following factors: 

1. Technology has changed significantly since SCAQMD Rule 1133.2 was 

adopted; 

2. Additional research projects regarding mitigation measures have been 

completed since SCAQMD Rule 1133.2 was adopted; and 

3. The socioeconomic climate of the SCAQMD is significantly different from that of 

the District. 

The table below summarizes the significant differences between SCAQMD Rule 1133.2 

and SJVUAPCD Rule 4565. Below are the important differences between the two rules. 

Category SCAQMD Rule 

1133.2 

SJVUAPCD Rule 4565 Reason 

Rule does not 

apply to these 

operations 

Management practice 

requirements 

Knowledge of VOC control options has 

increased since Rule 1133.2 adoption 

and staff believes that cost-effective 

methods of controlling VOC emissions 

from these facilities exist. 

Co-Composting 

Threshold for 

Applicability 

Facilities with at 

least 1,000 tpy 

throughput 

Facilities that handle 100 

tpy or more of biosolids, 

animal manure, or 

poultry litter 

Staff believes that there are reasonable, 

cost effective options for facilities with 

throughputs of ≥100 tpy that would not 

impose an undue burden on operators. 

Composting Control 

Requirements 

In-vessel 

composting with 

70 – 80% VOC 

control 

efficiency 

VOC control efficiency 

10% - 80% depending on 

type of operation and 

facility throughput 

Management practices (mitigation 

measures) are effective, reasonable, 

and have been achieved in practice for 

smaller facilities. 

In-vessel composting is not costeffective for smaller or medium facilities 

and there are no known, unsubsidized 

facilities in the SCAQMD that would 

comply with such rule requirements. 
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Furthermore, in order to acknowledge that some VOC mitigation measures are only 

cost-effective for larger facilities, SJVAPCD staff developed the concept of Class One 

and Class Two mitigation measures. Class One mitigation measures are considered 

BARCT and cost-effective options for all facilities, regardless of size. These measures 

are management practices found to be best practices for all composting operations. 

Class Two mitigation measures are the technology options and achieve reductions 

greater than Class One mitigation measures, however they are not cost effective for 

facilities with throughputs of less than 100,000 wet tons per year (see Appendix C of the 

Final Rule 4565 Draft Staff Report details the costs and cost effectiveness analysis). 

SJVAPCD Rule 4565 requires reductions from two addition categories (landfilling and 

land applying) when compared to SCAQMD Rule 1133.2. For the third category, 

composting, SJVAPCD staff determined it is not cost effective to require in-vessel 

(enclosed) composting. 

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4565 

satisfies RACT for biosolids, animal manure, and poultry litter operations. 
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Rule 4570 – Confined Animal Facilities 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

VOC 

without 4570 65.4 68.7 72.5 74.0 76.9 81.4 85.9 90.4 

VOC 

*adjusted 65 68 53 55 57 60 64 67 

*Baseline adjusted to reflect recently adopted Rule 4570 reductions & current estimated control 

efficiencies. 

Note: The RACT analysis for Rule 4570 follows a different format due to the innovative nature 

of the rule. 

1. BACKGROUND – CONFINED ANIMAL FACILITIES IN THE SAN JOAQUIN 

VALLEY 

Confined Animal Facilities are used for the raising of animals including, but not limited 

to, cattle, calves, chickens, ducks, goats, horses, sheep, swine, rabbits, and turkeys, 

which are corralled, penned, or otherwise caused to remain in restricted areas for 

commercial agricultural purposes and fed by a means other than grazing. (CH&SC 

39011.5 (a)(1)) 

1.1. TYPES OF CONFINED ANIMAL FACILITIES 

1.1.1 INDUSTRIES THAT USE CAFs 

Confined animal facilities are used in the raising of livestock for the purpose of providing 

dairy products, meat, and eggs. The raising of livestock (livestock agriculture) has gone 

through significant changes since the 1990s. Today, meat and dairy products typically 

originate on farms whose herds of cattle or hogs, or flocks of chickens are much larger 

than in the past. These farms usually house a single species in buildings or open-air 

pens, and provide them with feed that has been purchased rather than grown onsite. 

While most such farms are still family-owned and operated, they rely heavily on hired 

labor and are tightly linked to other stages of production and processing through formal 

contracts, alliances, and joint financing or common ownership of assets.1 

The growth of all types of livestock agriculture farms continues to increase. A big driver 

in the structural change in livestock agriculture is increased productivity and, through 

that, lower production costs to the farmer. The largest dairy farms (1,000+ head) have 

production costs that are 15% lower than the next largest size class (500-999 head). 

This kind of production cost-saving is also true of layers (chickens raised to lay eggs), 

broilers (chickens raised for meat), hog, and beef producers. For livestock agriculture, 

evidence to-date suggests that production costs fall as the farm size increases up to 

some threshold level. Production costs then level out, meaning that there is no unique 

optimal size. Dairies with 2,000 cows have average costs similar to dairies with 1,000 
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cows, for example. Therefore, these livestock operations can get quite large without 

experiencing increased production costs from being “overly” large. 

One example of the shift to large-scale production is the dairy industry. Nationally, only 

about 10% of all dairy cows were housed on farms with more than 1,000 head in 1992. 

By 2007, that ratio rose to 36% of all dairy cows. The shift to very-large dairies (1,000+ 

head) had its origin in California and other western states. Looking at California 

specifically, the state has become the largest producer of milk in the nation. The eight 

counties of the San Joaquin Valley are all in the top-ten California counties for milk 

production, with Tulare County heading the list. Tulare County alone produced almost 

as much milk as the entire state of Pennsylvania, the state ranked number five on the 

2007 list of top milk-producing states and Tulare County was well ahead of Minnesota, 

the sixth largest milk producing state. 

The State of California tracks the number of dairies and the number of dairy cows by 

county. By dividing the number of cows by the number of dairies, the average number 

of cows per dairy for each county is determined. The simple math done by the state 

does not reveal the extent to which larger dairies have appeared in the District. The 

SCAQMD Staff Report for the adoption of Rule 223 points out the relative contribution of 

all CAFs to the South Coast emissions inventory in the near future is expected to be 

significantly lower than what the current figures indicate.6

 Consistent with the 

assumptions made by SCAQMD, many dairies have already moved to the San Joaquin 

Valley (SJV). Much of this is due to the encroachment of residential areas close to 

South Coast CAF operations. That, coupled with the less-expensive land in the Valley 

and proximity to the Greater Los Angeles market, makes the SJV the perfect destination 

for dairies from the South Coast air basin. Kern County is about 50 minutes away from 

the Greater Los Angeles area and has direct access via Interstate 5 and California State 

Route 99. The county with the highest head-per-dairy in 2007 was Kern County with an 

average of 3,137 head per dairy, up 50% from the 2002 level of 2,093 head per dairy. 

Although dairies are notable in their shift to large-scale production, other types of 

livestock agriculture have also increased the average farm size. Nationally, the median 

production of broilers (50% larger and 50% smaller) is 600,000 broilers per year. In 

2002, the median production was 520,000. Active District permits echo this national 

trend. 

1.1.2 MAJOR CAF CATEGORIES 

Industries employing confined animal facilities (CAFs) provide several major nutritional 

commodities, including dairy products, meat, and eggs. There are many different types of 

CAFs in the San Joaquin valley. The major categories are described below. 

 

6

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1.1.2.1 Dairy Operations 

Dairy operations are defined as those operations producing milk or animals for facilities 

that produce milk. In order to produce milk, the cows must be bred and give birth. 

Typically, the gestation period for dairy cattle is nine (9) months and dairy cows are bred 

again approximately four (4) months after calving. Milk production typically peaks 

shortly after calving and then declines. Commonly a cow will produce milk for ten (10) 

to twelve (12) months and then be dry approximately two (2) months. Thus, a dairy 

operation may have several types of animal groups present including heifers, lactating 

cows, dry cows, calves, and bulls (for breeding purposes). Approximately 25% of a 

milking herd is replaced each year, but replacement levels can be as high as 40% for 

intensively managed herds (EPA 2001). 

Feeding and watering practices vary for each animal type. In general, calves are 

nursed for four (4) to five (5) days after birth. Calves are then fed a milk replacement 

until weaning, which generally occurs at about eight (8) weeks of age. During this 

period, a feed grain based starter diet is introduced. This starter diet is fed to calves 

until they are approximately three (3) months old. At approximately three (3) months, 

calf rumen development allows a shift to a roughage-based diet. 

Older cattle and calves being raised for milk production are commonly fed a roughagebased diet. The principal constituents of these diets are corn or grain sorghum silage 

and legume or grass and legume hays with feed grains and byproduct foodstuff added 

in varying amounts to satisfy energy, protein, and other nutrient requirements. The 

manure tends to be generated in a semi-solid state. 

1.1.2.2 Poultry Operations 

Poultry facilities operate either as layer ranches for egg production or as broiler ranches 

where birds are grown for the fresh meat market. Poultry facilities, called ranches in 

reference to their specialized operation, may consist of one or more farms on properties 

that may be several miles apart. Several barn-like houses may make up a farm. A 

chicken layer house may have over 100,000 layers; a typical chicken broiler house 

contains approximately 20,000-25,000 birds; and a typical turkey broiler house contains 

approximately 10,000 birds at any one time. 

1.1.2.3 Beef Cattle Feeding Operations 

This animal sector includes adult beef cattle (heifers and steers). Beef cattle may 

spend all, part, or none of their lives on a CAF. There are three types of operations in 

the beef industry: cow-calf operations, backgrounding operations, and finishing 

operations. These operations are typically conducted at separate locations that 

specialize in each phase of production, but may occur at a single location. 

Cow-calf operations are a source of heifers and steers fed for slaughter. These animals 

are fed primarily hay with some grain and other foodstuff. Backgrounding or stocker 
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operations prepare weaned calves for finishing. The backgrounding process is highly 

dependent on feed prices. Typically the animals are fed the lowest priced feed at the 

time, which may be forages or crop residues, with the objective of building muscle and 

bone mass at a low cost. The duration of the backgrounding process may be from thirty 

(30) days to six (6) months old. Typically, high grain prices favor longer periods of 

backgrounding by reducing feed costs for finishing or fattening. After approximately 150 

to180 days, animals in finishing operations will reach slaughter weights of 1,050 to 

1,250 pounds. Although, some feedlots start with younger or older cattle and the 

finishing cycle may be less than 100 days or over 270 days. Accordingly, feedlots 

typically have between 1.5 to 3.5 cattle turnovers per year. 

In any case, animals are typically segregated by production stage in pens with feed 

truck access. The animals are typically fed two (2) to three (3) times per day using feed 

bunks located along feed alleys that separate the individual pens. 

1.1.2.4 Swine Operations 

The production cycle for hogs has three (3) phases: farrowing, nursing, and finishing. 

The first phase begins with breeding and gestation over a 114-day period followed by 

farrowing (giving birth). After farrowing, the newly born pigs or piglets normally are 

nursed for a period of three (3) to four (4) weeks until they reach a weight of 

approximately ten (10) to fifteen (15) pounds. Typically, there are from nine (9) to 

eleven (11) pigs per litter. Sows can be bred again within a week after a litter is 

weaned. Sows normally produce five (5) to six (6) litters before they are sold for 

slaughter at a weight of 400 to 460 pounds. 

Weaned pigs are fed a starter ration until they reach a weight of approximately fifty (50) 

to sixty (60) pounds. At this point, they are typically eight (8) to ten (10) weeks of age. 

Then the animals are fed a growing and finally a finishing ration until they are 

approximately 240 to 280 pounds at which point they are approximately 26 weeks of 

age and ready for slaughter. The diet varies, but it typically includes small grains such 

as wheat and barley, corn and soybean meal. 

1.1.3 VARIETY OF CAFS 

CAFs can vary significantly in size from one CAF to another (e.g., dairy to feedlots, 

poultry, etc.) and within the same category of CAFs (dairy to dairy). For example, a 

dairy can be as small as 10 acres to well over 100 acres, depending on the number and 

types of cows on the facility. The majority of the sources on a dairy or a cattle facility 

are large open areas and cannot be easily controlled, specifically by a single control 

device. Dairies cannot be compared to feedlot cattle nor can either be compared to 

poultry operations. Poultry operations, even within themselves have many different 

characteristics and practices. 

Due to the different methods of confinement and associated manure management, 

there is no typical CAF. The design and operation of a CAF varies depending on animal 
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type, regional climatic conditions, business practices, and preferences of the 

owners/operators. Not all of the mitigation measures included as an option in Rule 

4570 can be reasonably adopted by all facilities due to infrastructure, conditional use 

permits, water board permits, soil types, production contracts, and other limitations. 

A description of the different types of housing and management systems are described 

below: 

1.1.3.1 Dairy Cattle Manure Management 

1.1.3.1.1 Flush 

The vast majority of the dairy cows in the Valley are located at dairies with a flush 

manure management system, which removes the manure by using a flushing system. 

A large volume of water is introduced at the head of a paved area, and the cascading 

water removes the manure. Flush water can be introduced from storage tanks or highvolume pumps. The required volume of flush water varies with the size of the area to 

be flushed and slope of the area. In a flush system, the manure generated by the cows 

next to the freestalls (near the feed lanes) is flushed by large amounts of water a few 

times a day generally to the lagoon. The lagoon serves as the basis of holding and 

decomposing the manure. 

1.1.3.1.2 Scrape 

Scrape manure management removes the manure and bedding from the barns and 

pens by a tractor or a mechanical scraper. Scrape manure management dairies may 

also have a mechanical alley scraper that consists of one or more blades that are wide 

enough to scrape the entire alley in one pass. A timer can be set so that the scraper 

runs two to four times a day. Scrapers reduce daily labor requirements, but have a 

higher maintenance cost due to corrosion and deterioration. 

The rate of manure accumulation in drylots (open corrals) and pens for the cattle is 

highest along feed bunks and watering troughs and therefore these areas will be 

scraped more frequently than other areas. These areas are usually paved with 

concrete. 

1.1.3.1.3 Vacuum 

There is a small percentage of dairies that utilize a vacuum system to collect as 

excreted manure with a vacuum truck. Generally, the trucks collect approximately 4,000 

gallons per load. The manure can be hauled to a disposal site rather than to an 

intermediate sump. Vacuum collection is a slow and tedious process. The advantage 

is that the collected manure is undiluted and approximately equal to the as excreted 

concentration and can be applied directly to land. Generally no lagoons are needed for 

this type of system, however there may be a need to maintain slurry pits if the facility 

does not have sufficient land available. 
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1.1.3.2 Dairy Cattle Housing and Manure Management 

Majority of Milk cows in the Valley are housed in freestalls while the vast majority of 

other cows (dry cows and heifers) are housed in open corrals. However, dairies may 

have a single type of housing or consist of both types of housing. Baby calves are 

generally housed in calf hutches, but vary in type (aboveground or on-ground). A brief 

description of each of the types of housing is included below: 

1.1.3.2.1 Freestalls 

In the freestall barn cows are grouped in large pens with free access to feed bunks, 

waterers, and stalls for resting. A standard free-stall barn design has a feed alley in the 

center of the barn separating two feed bunks on each side. Animals stand on the 

concrete feed lane to eat; this is where the majority of the animal excretion occurs. A 

variety of types of bedding materials are used for animal comfort and to prevent animal 

injury. 

1.1.3.2.2 Open Corrals (drylots) 

An open corral is a large open area (fenced in) where cows are confined, with unlimited 

access to feed bunks, water, and possibly an open structure to provide shade. 

1.1.3.2.3 Special Needs Housing 

The special needs area serves the gestating cows at the dairy or any cow that may 

have a medical condition. This area acts as a veterinary area and gives the cows 

special attention as they move from dry cow (a mature cow that is gestating but not 

lactating) to maternity to milking status or until their health improves. 

1.1.3.2.4 Calf Housing 

The calves are generally housed individually until they are ready to wean (to accustom 

to take nourishment other than by suckling).

1.1.3.3 Feedlot Cattle Housing and Manure Management 

Feedlot cattle are segregated in pens designed for efficient movement of cattle, 

optimum drainage, and easy feed truck access. Pens are large open areas where cattle 

are confined, with unlimited access to feed bunks, water, and possibly an open structure 

to provide shade. A typical pen holds 150-300 head of cattle but the size can vary 

substantially. Required pen space may range from 75 to 400 square feet of pen space 

per head, depending on the climate. A dry climate requires 75 square feet of pen space 

per head whereas a wet climate may require up to 400 square feet (Thompson, O'Mary, 

1983). Space needs vary with the amount of paved space, soil type, drainage, annual 

rainfall, and freezing and thawing cycles. These types of operations may use mounds to 
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improve drainage and provide areas that dry quickly, since dry resting areas improve 

cattle comfort, health, and feed utilization. 

For these types of operations, the manure is commonly handled as a solid. Solid 

manure is typically scraped or moved by tractors to stockpiles. Manure accumulates in 

areas around feed bunks and water troughs most rapidly, thus these areas may need to 

be cleaned during the finisher cycle. However, there is significant concern and risks 

associated with entering areas where beef cattle are housed. 

1.1.3.4 Poultry Housing and Manure Management 

In the United States, approximately 61% of the chicken layer houses and a majority of 

the breeder and broiler houses use power ventilation instead of natural ventilation. The 

most common type of power ventilation is tunnel ventilation. In tunnel-ventilated 

houses, all the fans are clustered at one end of the house and the fans push the air to 

the other end of the house. Curtains on the houses may be used on a non-routine basis 

for ventilation, particularly during colder weather. 

Studies indicate that most chicken layer houses produce approximately two cubic yards 

of waste per week per five hundred chickens. Although a small amount of liquid waste 

may occur from egg washing operations located on the facility and a small amount of 

bedding may be collected as waste, poultry excretions account for a majority of the 

waste. Typically, hens are confined in a layer house that consists of many layer boxes 

positioned above the ground. On average, every seven (7) to nine (9) days workers 

remove waste from under the layer boxes, and every fourteen (14) to eighteen (18) 

weeks workers remove waste from the floor of the layer houses. However, many 

facilities list less frequent waste removal, ranging from one (1) to three (3) times per 

year (every 17-52 weeks) as a control technique used to comply with District Rule 4550 

Conservation Management Plan (CMP). Several mitigation measures in Proposed Rule 

4570 and Rule 4550 that the owners/operators could choose do not affect waste 

removal frequency. Therefore, owners/operators can comply with both Rule 4550 and 

4570. 

In broiler facilities, complete litter removal from the house occurs one (1) to four (4) 

times per year. Litter removal frequencies vary from every two (2) to seven (7) flocks 

(approximately 90-315 days); more commonly, it is removed every third flock. Before 

introducing a new flock, the house is left empty, typically for five (5) days. During this 

interlude, the operator adjusts the temperature and other ambient conditions in the 

house. In the broiler industry, the new flocks of birds are brought into the houses as 

chicks and are raised for approximately 45 days, until they reach the desired weight. 

Shortly thereafter, the grown birds are removed and the house is again left empty for 

approximately five (5) days to sanitize. This approximately 55-day cycle is the 

production period for one flock. Depending on management practices, litter production 

ranges from 0.5 to 0.7 pounds per pound of live bird weight. On average, for each 

pound of live weight gained, meat birds produced 0.52 pounds of litter during the 

production period. 
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Poultry excretions and bedding materials, such as rice hulls, are removed either by 

scraping or by flushing. In a scrape system, the litter is either swept or scraped from the 

house into a pile or piles outside the house. Typically, concerns about transmitting 

diseases among birds and flocks necessitate trucking the scraped litter offsite shortly 

after removal. The liquid handling system is similar to dairy flush systems, explained 

later in this report. However, less than 15% of the poultry operations in the San Joaquin 

Valley use liquid manure handling systems. 

1.1.3.5 Swine Housing and Manure Management 

The animals are typically housed in confinement buildings that are either totally 

enclosed or open-sided with curtains. Totally enclosed facilities are mechanically 

ventilated throughout the year. Open-sided buildings are naturally ventilated the 

majority of the year, but may be mechanically ventilated when the curtains are closed 

due to weather conditions. Manure may be flushed from the floor of the housing or fall 

through slats in the floor to a pit underneath the floor. Manure in the pit may be flushed 

or scraped. 

1.1.3.6 Miscellaneous Emission Units at CAFs 

1.1.3.6.1 Manure Stock Piles-Storage 

Almost all cattle facilities maintain uncovered storage stockpiles. Because open piles 

are subjected to rain, they exhibit emission profiles of both aerobic and anaerobic 

conditions over time. When stacked for storage, a significant increase in temperature 

may occur depending on moisture content due to microbial heat production. 

1.1.3.6.2 Storage Ponds 

Manure with a total solid content of 10% or less can be handled as a liquid. In slurry or 

liquid systems, the manure is flushed from alleys or pits to a storage facility. A flush 

manure management needs a place to flush the manure to and generally consist of 

small to very large basin(s) designed for temporary collection and storage of their 

organic waste. Storage ponds are not designed to treat waste but to simply store it or 

hold it. Storage ponds may completely be emptied when pumped, and the design 

storage periods are about 90 to 180 days. 

1.1.3.6.3 Land Application of Animal Waste 

Liquid manure from flush systems stored in lagoons or solid manure scraped from 

facilities eventually may be land applied with or without prior treatment such as 

composting or anaerobic digestion. Typically, animal waste is applied to cropland at 

rates adequate to supply crop nutrient needs. Historically the determination of 

application rates has been based on crop nitrogen requirements due to concern about 

the impact of excess nitrogen on surface and ground water. In cases where treatment 
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methods, such as aerobic digestion, increase the nitrate content in the waste stream, 

the waste may need to be applied over a greater number of acres in order to comply 

with the Regional Water Quality Board’s regulations. 

Surface application of manure waste may be done with a spreading device known as a 

box manure spreader. This is simply a rectangular box that is either tractor drawn or 

truck mounted with a spreading device at the rear end. During spreading, the manure 

moves to the rear of the box by either a belt or chain-and flight conveyor. Box type 

spreaders are typically loaded with tractor mounted front-end loaders. Manure handled 

as slurry or liquid may be spread with a tractor drawn or truck mounted tank known as a 

liquid manure spreader. The manure may be forced out of the tank under pressure 

against a distribution plate to create a spray pattern. Another option is to force the 

manure from the tank under pressure through a manifold with a series of hanging or 

trailing pipes to create parallel strips of manure on the soil surface. A second type of 

spreader for manure slurries is a flail spreader. This is a partially open tank with chains 

attached to a rotating shaft positioned parallel to the direction of travel. Manure is 

discharged perpendicular to the direction of travel by the momentum transferred from 

rotating chains. 

Manure may be land applied and land incorporated through the use of a manure 

injection device, typically attached to a tractor; tilling surface applied manure under the 

soil; applying liquid manure at such a rate that is rapidly absorbed into the soil; or 

another method in which the manure is covered with soil. 

Facilities choosing to use conservation tillage options will likely apply any liquid manure 

at a rate such that it is rapidly absorbed into the soil and apply any solid manure only 

after it has been treated with an anaerobic digestion process, treated with an aerobic 

digestion process, or dried to a moisture content of less than 50%. In any of these 

cases the animal waste land applied would not need to be tilled under the soil in order 

to comply with rule requirements. Similarly, such methods may be used when crop 

height prevents the owner/operator from tilling the land-applied waste. 

1.1.3.6.4 Windrow Composting 

Some dairies in the Valley also compost the manure generated from their facility. 

Composting is the aerobic decomposition of manure or other organic materials in the 

thermophilic temperature range (104 -149 degrees F). It is the same process that decays 

leaves and other organic debris in nature. Composting merely controls conditions so that 

materials decompose faster. Composting is generally performed through windrow 

compost piles. A windrow process involves forming long piles turned by specially 

designed machines. Typically the rows are 1 to 2 meters high and 2 to 5 meters at the 

base. The piles are turned periodically to mix and introduce and rebuild bed porosity. This 

helps to insure that all the material is uniformly composted. 

Composting improves the handling characteristics of any organic residue by reducing its 

volume and weight. Composting also kills pathogens and weed seeds. Composting 
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reduces material volume through natural biological action and produces a product that 

enhances soil structure and benefits new growth. However, windrow composting 

operations also result in significant VOC emissions. 

1.2 EMISSION FACTORS AND EMISSION INVENTORY 

1.2.1 BIOLOGICAL PROCESSES ARE COMPLEX, NOT WELL-UNDERSTOOD 

Unlike other traditional stationary sources (many of which are combustion sources for 

which there is a very good understanding of emissions), agriculture sources are 

biological sources that consist of hundreds of different VOCs among other major 

pollutants. Perhaps the most important finding of all is that CAFs are extraordinarily 

complex sources of air emissions, varying not only season to season, but from CAF to 

CAF, and from place to place within a CAF. Emissions can vary substantially 

depending on weather, types of feed, and management styles along with many other 

factors. The same methodologies and standards used to establish emissions from 

traditional stationary sources cannot be used in determining the emissions from CAFs. 

Development of strategies to reduce environmental impacts of animal agriculture 

requires a better understanding of the mechanisms involved in the production, emission, 

and consumption of ammonia, odors, and greenhouse gases. In order to understand 

and ultimately reduce the negative impacts of these gaseous emissions, it is important 

to understand the circumstances under which they form. Understanding the sources 

and mechanisms of these emissions is a first step to developing effective control 

strategies. 

However, as discussed earlier, prior to January 1, 2004, the only available emission 

factor for dairies, swine, rabbits, horses, sheep, and goats was based on a metabolism 

study conducted in 1938 by Benedict and Ritzman. No other data was available at that 

time. Since 2004, multiple studies have been performed, each subsequent study 

providing more insight into how the biology of the animals and their waste plays a large 

role in emission production. Although numerous studies have been completed in 

evaluating the emissions profile from CAFs and a significant amount has been learned 

through this process, much is still not well understood. Each new study performed 

sheds new light in regards to how the different biological factors effect emissions. 

1.2.2 STATE OF THE SCIENCE 

Due to the relatively new status of CAFs as a regulated stationary source, the body of 

scientific knowledge that is useful in understanding CAFs’ impact on air pollution is not 

as well established compared to other traditional stationary sources under the 

jurisdiction of the District. Even after the adoption of Rule 4570, the science 

significantly lags in comparison to other stationary sources. New scientific findings 

characterizing and quantifying dairy, poultry, and other animal emissions and possible 

control measures are still being developed and completed. The District developed Rule 
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4570 using relevant findings from previous and on-going research efforts as they were 

finalized, published, and peer-reviewed. These include, but are not limited to: 

• A study at UC Davis, led by Dr. Frank Mitloehner, which focused on emissions from 

cows housed in environmental chambers to evaluate the emissions produced 

directly from cows and their fresh manure. 

• A study at two operating dairies in the San Joaquin Valley, led by Dr. Chuck 

Schmidt, in which measurements were made at various locations at the dairies, 

including the corrals and turnouts, bedding areas, lagoons, feed storage areas, flush 

lanes, and bunker feed. 

• A study by Dr. Schmidt to validate the effectiveness and capture efficiency of using 

flux chambers that were used to quantify emissions in the dairy studies. 

These studies have provided many findings that provided a better understanding of the 

emissions at CAFs. 

1.2.3 EMISSION FACTORS 

Accurate Emission Factors are needed in order to calculate source emissions, 

reductions, and cost effectiveness of control measures. However, prior to January 1, 

2004 (the date the exemption was lifted from agriculture sources), the only available 

emission factor for dairies, swine, rabbits, horses, sheep, and goats was based on a 

metabolism study conducted in 1938 by Benedict and Ritzman. This study measured 

methane from animals including an elephant, a horse, seven Holsteins, four Jerseys, 

and a Hereford cow. 

To address the need for better science, the District, other regulatory agencies, industry 

and the scientific community put forward multiple research projects to close the gap on 

the emissions data. This study and the subsequent research papers were the most 

current published and reviewed source of emission factors for several species during 

the Rule development process. Although multiple studies were completed in time for 

Rule 4570 development that proved useful, a significant amount of additional questions 

were raised and even more data gaps still remain. Several most recent articles have 

reported different emissions from these operations and emission sources. However, 

those emission factors tend to be inconsistent, possibly due to variation between 

facilities, and are not complete and have yet to be vetted by District Staff. As a note, 

the District is reevaluating the emissions from dairy and cattle operations taking into 

account all the latest studies completed. This effort will be taking place over the next 

several months. 

1.2.4 EMISSION INVENTORY 

Staff utilized the 2002 USDA census, industry data, and California Air Resources Board 

documents to estimate the VOC's emitted by CAFs in the SJVAB. The methodology is 

further explained below; Table 1 summarizes the results. 
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Table 1: Total 2005 VOC Emissions from CAFs in the SJVAB 

 VOC Emission 

Factor (lb/hd/yr) 

Total VOC 

Emitted by CAFs 

(tons/day) 

Total VOC 

Emitted by Large 

CAFs (tons/day) 

Milk Cows 21.00 51.28 36.92 

Beef Cattle 11.90 2.80 2.66 

Other Cattle 8.30 15.56 14.79 

Poultry 7.20 3.54 2.16 

Swine 1.00 0.57 

Other Animals 6.60 0.00 0.00 

Total Animals 74.57 57.09 

1.2.4.1 Dairy 

Staff utilized the California Department of Food and Ag (CDFA) report entitled 

“California Agricultural Statistics 2004." The numbers are shown in Table 2. These 

numbers only include milking and dry cows, not heifers that have not calved or calves. 

Table 2: Number of Milk and Dry Cows (CDFA Data 2004) 

County 2002 2003 2004 Projected 

2005* 

Fresno 86,115 90,345 95,577 99,878 

Kern 85,830 98,478 121,147 126,599 

Kings 146,545 153,475 162,656 169,976 

Madera 49,899 57,099 63,934 66,811 

Merced 224,895 224,734 237,854 248,557 

San Joaquin 99,828 106,162 103,619 108,282 

Stanislaus 164,558 177,432 178,420 186,449 

Tulare 424,643 437,476 442,853 462,781 

Total 1,282,313 1,345,201 1,406,060 1,469,333 

*The growth from 2002 to 2003 was approximately 4.9% and the growth from 2003 to 2004 was 

4.5%. In order to be conservative, staff assumed a growth of 4.5% for 2004 to 2005. 

In order to estimate the number of support stock at a dairy, ratios were developed using 

216 dairy applications submitted to the District. Based on those applications the 

following ratios, listed in Table 3, were developed. These ratios represent the number 

of each type of animal. 

Table 3: Ratio of Each Type of Dairy Cow to Milkers

Support 

Animals to 

Milkers 

Dry 

Cows 

to 

Milkers 

Heifers (15-

24 mo) to 

Milkers 

Heifers (7-14 

mo) to 

Milkers 

Heifers (4-6 

mo) to 

Milkers 

Calf 

(<4 mo) to 

Milkers 

107% 16% 34% 29% 16% 11% 
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Total 

Animals

VOC Factor 

(lb/hd/yr) 

from Table 4

Total VOC 

Emissions 

(lb/yr)

Animal 

Included In 

Rule

VOC Factor 

(lb/hd/yr) 

Total VOC 

from Animals 

Included in 

Rule (lb/yr)

Milk Cows 1,266,666 21.00 26,599,994 912,000 21.00 19,151,996 

Dry Cows 202,667 11.90 2,411,733 145,920 11.90 1,736,448 

Heifers (15-24) 430,667 8.30 3,574,533 310,080 8.30 2,573,663 

Heifers (7-14) 367,333 7.20 2,644,799 264,480 7.20 1,904,256 

Heifers (3-6) 202,667 6.60 1,337,600 145,920 6.60 963,072 

Calves 139,333 6.20 863,866 100,320 6.20 621,984 

Total Cows 2,609,333 37,432,525 1,878,720 26,951,418 

 Table 4: Total 2005 Dairy Animals in SJVAB

Before the above ratios can be applied to the CDFA milk and dry cow numbers to 

estimate a total number of head, the number of dry cows needs to be subtracted from 

the milk and dry cow numbers. Based on the ratios above, 16% of cows are dry cows 

when compared to milk cows, therefore the calculations would be as shown in the 

example below: 

1,469,333/1.16 = 1,266,666 milk cows 

1,266,666 x 0.16= 202,667 dry cows 

1,266,666 x 0.11 = 139,333 calves 

Now we can use the ratios in Table 7 to estimate all the other types of cows at a dairy. 

Staff assumed, based on the ARB's June 23, 2005 Staff Report for Confined Animal 

Facilities page iii, that 72% of the dairy cows would be included in this regulation. 

Furthermore, since the APCO Report noted that the 19.3 lb/hd-yr factor did not consider 

all emission sources and that the majority of facilities have freestalls, in order to be 

conservative, Staff utilized the weighted emission factor of 21.0 lb/hd-yr listed on the 

District's web page for dairies. 

1.2.4.2 Beef and Other Cattle 

The following table includes other cattle facilities in the San Joaquin Valley, from a 

USDA California Agricultural Statistics 2004 Report and beef on feedlots from the 

California Farm Bureau Federation. Staff assumed, based on the ARB's June 23, 2005 

Staff Report for Confined Animal Facilities page 8, that 95% of the beef cattle and other 

cattle would be included in this regulation. This is based on the assumption that a 

similar number of beef and other cattle would be included in this rule as feedlot cattle 

listed in the ARB Staff Report. 

Furthermore, staff assumed that there were equal numbers of each type of heifers and 

calves at the other cattle facilities therefore, averaged the emission factors for heifers 

and calves in order to obtain the emission factor for other cattle. This was used to 

develop Table 9. 
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Total 

Animals

VOC Factor 

(lb/hd/yr) 

from Table 4

Total VOC 

Emissions 

(lb/yr)

Animal 

Included In 

Rule

 VOC Factor 

(lb/hd/yr) 

Total VOC 

from Animals 

Included in 

Rule (lb/yr)

Total Beef 184,050 11.10 2,042,955 174,848 11.10 1,940,807 

Total Other Cattle 1,605,000 7.08 11,355,375 1,524,750 7.08 10,795,230 

Total 1,789,050 13,398,330 1,699,598 12,736,037 

 Table 5: Total 2005 Beef and Other Cattle

Total 

Animals

VOC Factor 

(lb/hd/yr) 

from Table 4

Total VOC 

Emissions 

(lb/yr)

Animal 

Included In 

Rule

VOC Factor 

(lb/hd/yr) 

Total VOC 

from Animals 

Included in 

Rule (lb/yr)

Layers 11,717,799 0.050 585,890 7,265,035 0.050 363,252 

Broilers 47,608,059 0.025 1,190,201 29,540,054 0.025 738,501 

Turkeys 8,071,297 0.100 807,130 4,728,720 0.100 472,872 

Total 2,583,221 67,397,155 41,533,809 1,574,625 

 Table 6: Total 2005 Poultry Animals

1.2.4.3 Poultry and Other Animals 

Staff obtained an estimate of the number of layers in the SJVAB from USDA census 

data. Since the ARB Proposed Emission Methodology assumed no significant growth 

for layers, staff assumed that the layer population has been relatively constant since 

2002. Based on ARB June 23, 2005 Public Hearing to Consider the Adoption of a 

Regulation Establishing a Definition of BACT, staff assumed that 62% of the layers are 

housed in large CAFs. 

Staff obtained estimates of the number of broilers and turkeys in the SJVAB from the 

California Poultry Federation. Based on this information, staff determined the number of 

turkeys and broilers housed in large CAFs. 

Staff obtained an estimate of the number of rabbits, goats, sheet, and swine in the 

SJVAB from the USDA census data. Since ARB Proposed Emission Methodology 

assumed no significant growth for non-cattle, staff assumed that the non-cattle 

population has been relatively constant since 2002. Based on the District's permit 

database, staff found that approximately 90,000 swine are housed in large CAFs 

and no rabbits, goats, or sheep in the SJVAB are housed in large CAFs. This is 

illustrated in Table 7. 
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Total 

Animals

VOC Factor 

(lb/hd/yr) 

from Table 4

Total VOC 

Emissions 

(lb/yr)

Animal 

Included In 

Rule

VOC Factor 

(lb/hd/yr) 

Total VOC 

from Animals 

Included in 

Rule (lb/yr)

Rabbits 0.190 742 - 3,903 0.190 - 

Goats 0.960 32,794 - 34,160 0.960 - 

Sheep 0.960 262,848 - 273,800 0.960 - 

Swine 4.600 729,266 90,000 158,536 4.600 414,000 

Total 1,025,649 470,399 90,000 414,000 

 Table 11: Total 2005 Other Animals

1.3 LACK OF AIR POLLUTION CONTROLS BEFORE RULE 4570 

As discussed earlier, prior to January 1, 2004, agriculture sources were exempt from air 

permitting requirements in California. Therefore, prior to 2004 and in most cases prior 

to the passage of Rule 4570 in 2006, agriculture sources had practically no pollution 

control systems in place. Agriculture sources were primarily managed and operated 

completely at the operator’s discretion without any thought to the effects of their 

operation to air emissions. In addition, as discussed above, prior to recent studies, the 

science was completely lacking which would allow for any reasonable control to be used 

that would effectively reduce VOC emissions. 

The District’s efforts to develop Rule 4570 sparked new scientific research into 

understanding the emissions profile and potential strategies to reduce emissions. A 

great deal of research has already been conducted and research is ongoing and will 

continue far into the future. 

With the changes to the CH&SC and the resulting loss of exemption from permitting of 

agricultural sources of air pollution (CH&SC 39011.5 (b)), new or expanded CAFs are 

now required to undergo the BACT process as a requirement under New Source 

Review (NSR). District Rule 2201 (New and Modified Stationary Source Review Rule) 

implements state and federal requirements under Title I, Part D and requires BACT for 

new sources or sources undergoing modification with emission increases that are above 

the de minimis value (two (2) pounds per day of VOC). BACT provisions would apply to 

sources which are subject to District permitting requirements and that emit or may emit 

one or more affected pollutant, either as a “major” source subject to Title V permitting or 

as a source with actual emissions which are 50% or more of any major source 

thresholds. 
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2 OVERVIEW OF RULE 4570 

2.1 REASONS FOR IMPLEMENTATION 

2.1.1 FEDERAL AND STATE PLANNING REQUIREMENTS 

In mid-2003, the San Joaquin Valley Air Pollution Control District started the process of 

revising its attainment plan to meet the federal one-hour ozone standard. The July 

2003 workshops for the Extreme Ozone Attainment Demonstration Plan included a 

control measure for confined animal feeding operations. The Plan was adopted in 

October 2004 and established a CAF rule adoption deadline of 2nd Quarter 2006, and 

set a 2010 VOC emission reduction goal of 15.8 tons per day based on a 61.3 ton per 

day emission baseline. 

Since Rule 4570 was a control measure in the District’s 2004 1-Hour Ozone Plan, it is 

subject to Federal Register, Clean Air Act (CAA), and California Health and Safety Code 

(CH&SC) requirements. Additionally, despite the federal revocation of the federal 1-

hour ozone standard, anti-backsliding provisions commit the District to develop all 

control measures listed in the 2004 1-Hour Ozone Plan (Federal Register Volumes 69 

and 70). These federal and state planning requirements are summarized in the 

following table. 

Federal and State Planning Requirements 

and District 2004 1-Hour Ozone Plan Commitments 

Subject Reference Requirement 

RACT CAA 182(b)(2) 

and 182(f) 

Ozone attainment plans shall assure that reasonable 

available control technology (RACT) for volatile 

organic compounds (VOC) is in use at sources and 

on source categories at or above the RACT 

threshold. 

RACT 

Threshold 

70 Federal 

Register 

30592-30596 

The applicable RACT threshold for control measures 

shall be the threshold in effect on June 15, 2004. 

The Districts threshold on June 15, 2004 was 10 

tons per year (tpy) for VOC. Therefore, 10 tpy was 

the RACT threshold for Rule 4570. 

Timeline CAA Section 

172(c)(1) 

Ozone attainment plans shall implement control 

measures as expeditiously as practicable, and 

provide for attainment. 

Antibacksliding 69 Federal 

Register 23955 Districts shall develop all control measures listed in 

the one-hour Ozone Plan until the District is 
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Federal and State Planning Requirements 

and District 2004 1-Hour Ozone Plan Commitments 

Subject Reference Requirement 

designated as attainment for the 8-hr NAAQS. 

BARCT 

CH&SC 

40919(a)(3) 

Ozone Plan 

 Ozone attainment plans should provide for best 

available retrofit technology (BARCT) for existing 

permitted sources. 

Feasible 

Controls 

CH&SC 

40914(a)(2) 

Ozone attainment plans should include "all feasible 

control measures." 

Deadlines Ozone Plan Rule adoption by the 2nd quarter of 2006. 

Reductions Ozone Plan 

The rule shall reduce VOC emissions by at least 

25% from the baseline by 2010. Twenty-five percent 

of the baseline used for the Ozone Plan (63.1 tpd) is 

15.8 tpd. 

In addition, the California Health and Safety Code (CH&SC) Section 40914(a)(2) states 

that ozone attainment plans should include All Feasible Control Measures (AFCMs). 

The ARB interprets “every feasible control measure to mean that, at a minimum, a 

district considers regulations that have been successfully implemented elsewhere. 

They should also consider going beyond what has already been accomplished by 

evaluation of new technologies and innovative approaches that may offer potential 

emission reductions. Further, districts should consider not only technological factors, 

but also social, environmental, economic (e.g., cost effectiveness), and energy factors 

which prevail in the District, along with the resources realistically available to the district 

to adopt, implement, and enforce the measures.” 

In the context of rule development, District staff considers AFCM to mean that each 

rulemaking project seeks to obtain as much emission reduction from the rule’s source 

category as is expeditiously practicable, technologically feasible and economically 

reasonable, as determined by the District’s Governing Board. To this end, District staff 

compares the current emission limits or control technology against what limits or control 

technology has been promulgated in other districts, as well as reviewing the federal, 

state, and local BACT clearinghouses for the most recent control technology available 

for the source category. The information obtained through this research is used to craft 

the proposed emission limits or imposed control technology. 

2.1.2 STATE LAW – SB 700 

On September 22, 2003, Governor Gray Davis signed into law Senate Bill 700. The bill 

amended air pollution control requirements in the California Health and Safety Code to 

include requirements for agricultural sources of air pollution. Agricultural sources of air 
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pollution were the focus of the bill for two main reasons. First, California law had 

previously exempted these sources from requirements to obtain air permits. This 

resulted in a conflict between state and federal law, and California faced sanctions if it 

failed to correct the problem. Had the bill not been signed, new and expanding 

businesses in the state would have faced significant and costly hurdles to obtain air 

permits required under federal law, and the state would have lost billions of dollars in 

federal transportation funding. 

The bill did six main things: (1) It defines "agricultural source" in state law; (2) It 

removes the restriction from state law that prevented air districts from requiring permits 

for agricultural sources; (3) It establishes specific permitting and exemption 

requirements for agricultural sources; (4) It requires emission control regulations in 

areas that do not attain National Ambient Air Quality Standards for PM10; (5) It requires 

permits and emissions mitigation for Confined Animal Facilities (CAFs) that are defined 

by ARB as "large" (based on a review of current scientific data about emissions from 

CAFs and the impact of those emissions on attainment of ambient air standards); and 

(6) It requires CAPCOA to compile a clearinghouse of information about available 

emissions control and mitigation for agricultural activities. It is important to note that the 

bill did not remove the exemption for agricultural operations from the general odornuisance provisions of the Health and Safety Code.7

In addition to satisfying District Planning commitments, Rule 4570 was also designed to 

fulfill the following requirements created by SB 700. 

SB700/California Health and Safety Code Requirements 

Subject CH&SC 

Sections SB700 / CH&SC Requirements 

Large Confined 

Animal Facility 

Definition (large 

CAF) 

40724.6(a) 

The District shall use the "large CAF" 

definition developed by the California Air 

Resources Board (ARB). 

Deadline 40724.6(b) 

By July 1, 2006 the District shall adopt, 

implement, and submit for inclusion in the 

state implementation plan a rule requiring 

owners of "large" CAF to obtain a permit. 

Degree of 

Mitigation 

Required 

40724.6(d)(1)(B) 

Best Available Retrofit Control Technology 

(BARCT) is the degree of mitigation required 

of large CAF. 

Compliance 

Schedule 40724.6(d)(4) 

Owner/operators shall implement control 

measures within one year of the permit 

issuance date. 

Permit 

Requirements 

to be Included 

40724.6(d) 

1. The permit shall include an emission 

mitigation plan that demonstrates use of 

BARCT, 

 

7

 CAPCOA White Paper on SB700 
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SB700/California Health and Safety Code Requirements 

Subject CH&SC 

Sections SB700 / CH&SC Requirements 

in the Rule 2. The District shall provide for a 30-day public 

noticing and commenting period for 

proposed permits, 

(The District shall review and update 

permits at least once every three (3) years, 

3. The District shall act on completed permit 

applications within six (6) months of receipt, 

4. The permit shall include sufficient 

information to prepare an emission 

inventory of all regulated air pollutants 

emitted from the facility, and 

5. The owner/operators of large CAF shall 

submit a permit application within six (6) 

months of Rule 4570 adoption. 

Impact 

Assessment 40724.6(d) 

Prior to adopting a rule, the District shall 

analyze the following: 

1. Category, number, and size of facilities 

affected, 

2. Nature, quantity, and significance of 

emissions in adversely affecting public 

health, the environment, and attainment of 

air quality standards, 

3. Emission reduction potential, 

4. Costs, 

5. Impact on employment and the economy, 

6. Alternative controls, and 

7. Technical and Practical Feasibility. 

2.1.2.1 RULE DEVELOPMENT PROCESS 

As part of the rule development process, District staff conducted public scoping 

meetings in April 2005, public workshops and Socioeconomic Focus Group meeting in 

March 2006 in order to present, discuss, and solicit comments on Rule 4570. In 

addition to the workshops, staff met with representatives of the impacted industries, and 

control technology vendors to receive comments on the technical aspects and 

compliance costs of the proposed rule. The comments received from the public, 

affected sources, California Air Resources Board, and United States Environmental 

Protection Agency during the public workshop process and technical consultation 

meetings were incorporated into the rule as appropriate. Comments received and 

District responses are discussed in Appendix A of the Final Draft Staff Report. 
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Rule 4570 and the Final Draft Staff Report including the analyses mandated by CH&SC 

were published prior to a public hearing on June 15, 2006 for the District Governing 

Board to consider the adoption of the rule. The notice of the public hearing for this rule 

project was published in a general circulation newspaper in each of the eight San 

Joaquin Valley counties, and was mailed to affected sources and interested parties. The 

public notice solicited written comments to be submitted by mail, and identified the 

name and telephone numbers of the District staff that could answer questions and 

respond to comments. The June 15, 2006 adoption schedule satisfied the requirement 

of the CH&SC for the District to adopt a regulation by July 1, 2006. 

2.1.2.2 Main Issues Addressed in the Rulemaking Process 

2.1.2.2.1 Difficulty of Controlling Fugitive Emissions 

Because of the large amount of land required to sustain the growth of crops and raising 

of animals, agricultural facilities, by their nature, tend to be very expansive. Agricultural 

production areas can span over a hundred acres with air contaminants primarily 

produced as fugitive emissions from multiple sources and operations at the facility. 

Fugitive emissions are defined as “those emissions which could not reasonably pass 

through a stack, chimney, vent, or other functionally-equivalent opening.” Examples of

fugitive emission sources at agricultural facilities include enteric emissions from 

livestock and emissions from animal waste that is applied to land. 

As discussed in above, it was demonstrated that the majority of emissions from 

confined animal operations are fugitive. The fugitive nature of the emissions from 

agricultural sources and their expansive size impose challenges and limitations to the 

type of controls that can be feasibly applied to reduce emissions. Unlike other stationary 

sources, where the majority of emissions are collected and released through a chimney, 

pipe, vent, or stack, which facilitates the use of traditional emission controls (e.g. fabric 

filters, catalysts, scrubbers, etc.), emissions from agricultural sources are spread out 

over large areas and are very dilute at the point of release. These emissions cannot 

reasonably be captured since capture of these emissions would entail monumental 

changes, which have not yet been developed and are likely infeasible, to the methods 

that are currently used for agricultural production. An additional consideration is that, 

unlike traditional stationary sources, potential adverse affects to livestock must also be 

considered when changes in production methods are undertaken, such as those 

needed to capture emissions. 

As mentioned, it would be exceedingly difficult to design and construct a system 

capable of capturing the majority of emissions from these sources without even 

considering control of these emissions; however, even if it were possible to capture 

most of the fugitive emissions, the extremely dilute nature of the emissions emitted from 

animals at agricultural sources would still cause the use of traditional point source 

controls to be infeasible and exceedingly expensive. Because of these constraints, the 

District has adopted an approach in which the best management practices are utilized 

to minimize emissions from confined animal facilities prior to their release. 
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2.1.2.2.2 Considerations for Animal Health and Food Safety 

Emission control mitigation measures, especially those that will be applied to animals, 

must take into consideration the health, welfare and productivity of the animals, food 

safety, and bio-security issues. Animal deaths, expenses for treatment or disposal of 

dead animals, as well as loss of productivity due to poor animal health can all be 

devastating to a farmer. Government agencies such as the USDA are also deeply 

concerned about animal health and the related food safety and bio-security issues that 

affect not just individual farmers but also the entire farm industry and the public. 

Diseases such as foot and mouth disease, mad cow disease, or avian flu are all of 

grave concern to the government because of their ability to destroy the entire farm 

industry and/or cause enormous loss of human life. In addition, animal welfare is a 

significant public issue, as demonstrated by the recent passage of Proposition 28

 by 

voters in California. While in the past, product boycotts and bad publicity were the main 

threats linked to animal welfare issues, the passage of laws such as Proposition 2 

brings the additional possibility of litigation that can put farmers out of business. 

 

It is therefore critical for farmers to have the flexibility to decide the kind of mitigation 

measures that will work best for their specific operation by taking into consideration 

animal health and welfare, productivity, food safety and overall bio-security issues, while 

at the same time achieving the required level of emission control. For instance, some 

dairy farmers have pointed out that high moisture levels in animal pens increase cases 

of mastitis infections in their herds. In such cases, it would be unfair to compel farmers 

to implement mitigation measures that increase moisture levels in their animal pens 

because of the potential harm to animal health, cost of treatment and loss of 

productivity. Instead, an option to implement another mitigation measure that achieves 

the same level of emission control should be provided. On the other hand, if certain 

mitigation measures such as housing dairy cows in completely enclosed barns were to 

be required across the board, many farmers, depending on case-by-case factors such 

as size of operation, location or financial resources, may find themselves exposed to 

serious animal welfare issues and devastating litigation. 

 

8

 Proposition 2 was a California ballot proposition in that state's general election on November 4, 2008. 

known as the Standards for Confining Farm Animals initiative. The official title of the statute enacted by 

the proposition is the Prevention of Farm Animal Cruelty Act. The proposition adds a chapter to Division 

20 of the California Health and Safety Code to prohibit the confinement of certain farm animals in a 

manner that does not allow them to turn around freely, lie down, stand up, and fully extend their limbs. 

The measure deals with three types of confinement: veal crates, battery cages, and sow gestation crates. 
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2.1.2.2.3 Considerations for the Wide Variety of CAFs 

Due to the different methods of confinement and associated manure management, for 

any animal type there is no single design that encompasses every CAF. Consequently, 

a universal method to control emissions from all CAFs is not only not available, but not 

suitable. In fact, multiple measures are required to implement BARCT for this source 

category. The design and operation of each CAF varies depending on animal type, 

sub-regional climatic conditions, subsurface geologic structure, business practices, and 

preferences of the owners/operators. This is why the District structured the rule such 

that facilities must comply with rule requirements utilizing management practices and 

machinery that owners/operators already have access to. This also acknowledges that 

not all facilities can implement the same options due to infrastructure, conditional use 

permits, water board permits, soil types, production contracts, and other limitations. 

2.1.2.3 Rule 4570 is not arbitrary nor capricious 

CAFs are newly-regulated and the supporting science for air emissions from these 

sources is still developing. In the mitigation measure menus of District Rule 4570, 

District staff considered all of the operations within each type of CAF, the available 

information about emission reduction potential, as well as the feasibility and cost of 

implementing required mitigation measures. CAF operators control emissions in every 

phase of the CAF operation. Many of the assumptions were based on studies and data 

showing that these practices would result in some reduction, but there was insufficient 

science to know exactly what the reductions would be. The menu approach of Rule 

4570 allows flexibility as the science of air emissions from CAFs evolves. The 

mitigation measures can be further focused on the operations that are shown to have 

the highest emissions. Independently, the mitigation measures themselves can be 

revised or expanded to include those that are most efficient and cost-effective each 

CAF emission source. 

In calculating the cost effectiveness of Rule 4570, District staff determined cost 

effectiveness for those Class One mitigation measures that had the lowest cost. Class 

Two mitigation measures, although having potentially higher emission reduction 

potential, were not included in the cost effectiveness calculation because they are costly 

to implement and are considered beyond the BARCT level of control. However, the 

Class Two mitigation measures were included in the mitigation measure menus in order 

to encourage voluntary practices exceeding BARCT. It is reasonable to assume that 

CAF operators would opt not to use those measures so expensive that the cost far 

outweighs annual profits. District staff calculated the potential emission reduction of its 

rule based on the likelihood that only the cheapest options will be chosen. This is a 

prudent and reasoned approach, neither an arbitrary nor a capricious one. This opinion 

was echoed in a recent court decision by the California Fifth Appellate District in 

Association of Irritated Citizens vs. San Joaquin Valley Air Pollution Control District 

(2008). 
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2.2 REQUIREMENTS OF RULE 4570 

2.2.1 APPLICABILITY 

Rule 4570 controls VOC emissions from “Large Confined Animal Facilities,” as defined 

by the California Health & Safety Code and the Air Resources Board. According to 

CH&SC 39011.5(a) and 39011.5(a)(1) a CAF is defined as “a source of air pollution or a 

group of sources used in the...(fill in the missing text – don’t summarize) raising of fowl 

or animals located on contiguous property under common ownership or 

control...including, but not limited to, any structure, building, installation, barn, corral, 

coop, feed storage area, milking parlor, or system for the collection, storage, treatment, 

and distribution of liquid and solid manure, if domesticated animals are corralled, 

penned, or otherwise caused to remain in restricted areas for commercial purposes and 

feeding is by means other than grazing.” 

The ARB was required by CH&SC 40724.6 to review all available scientific information, 

including, but not limited to, emission factors for confined animal facilities; the effect of 

those facilities on air quality in the basin; and other relevant scientific information and to 

develop a definition for a “large” confined animal facility. ARB's board adopted the 

following thresholds for a large CAF, based on air emissions from CAFs: 

ARB Large CAF Thresholds 

Livestock Category Number of Animals 

Dairy 1,000 lactating cows 

Beef Feedlots 3,500 beef cattle 

Other Cattle Operations 7,500 calves, heifers, and other cattle 

Chickens-Broilers & Egg Layers 650,000 head 

Turkeys 100,000 head 

Swine 3,000 head 

Sheep and Goats 15,000 head 

Horses 2,500 head 

Ducks 650,000 head 

Other Livestock Not Previously Mentioned 30,000 head 

Source: http://www.arb.ca.gov/regact/lcaf05/lcaf05.htm accessed 2/24/06 

2.2.2 EMISSION CONTROL REQUIREMENTS 

Rule 4570 requires multiple mitigation measures from all large CAFs covering the 

following CAFs: Dairy, Beef Feedlots, Other Cattle, Swine, Poultry, and various other 

smaller operations. Each of these facilities consists of multiple sources of emissions 

within the facility. Since these facilities generally cover a large area and have different 

processes, a single mitigation measure or technology is generally not sufficient in 

reducing overall emissions from the facility. Rather than allow facilities to select a 

number of measures at the emission source of their choosing, Rule 4570 specifically 

requires a certain number of mitigation measures at the majority, if not all, of the 

emission sources. Mitigation measures required by Rule 4570 have been tailored for 
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each source of emission, thereby ensuring that the overall emissions from a facility are 

reduced rather than from only a part of the facility, which would be the case if that was 

left as an option in the Rule. The current methodology in Rule 4570 provides for the 

greatest overall control from the facility. 

Rule 4570 recognized the following five sources for all of the CAFs: Feed, Housing, 

Solid Waste, Liquid Waste and Land Application of Manure. Rule 4570 requires each 

CAF to implement a certain number of mitigation measures (ranging from 1 to 8 

measures) for each of these sources. Rule 4570 also distinguishes between the 

different types of housing configurations (freestall vs open corrals) for the cattle and the 

different types of feed (feed stuff vs silage) and as such requires additional mitigation 

measures for each type. In addition, dairies are also required to implement a mitigation 

measure for the milking parlor. By requiring mitigation measure(s) for each source of 

emissions at a facility, Rule 4570 ensures that reductions are achieved throughout the 

entire facility. 

Rule 4570 requires operators of a CAF to implement multiple VOC mitigation measures 

for the major emission sources at each facility. The sources covered by the Rule and 

the number of measures required are shown in the following table. This menu approach 

not only provides flexibility to facilities to select measures that are suitable to their 

particular operation, but the requirement to implement multiple mitigation measures in 

each source category results in a larger emission reduction. 

Summary of the Minimum Number of VOC Mitigation Measures Per Animal Type 

and Area Compared to Total Number of Options 

Area Dairy Beef Other 

Cattle 

Swine Poultry 

Feed 4 of 8 5 of 8 5 of 8 5 of 12 5 of 10 

Silage 1 of 6 1 of 6 1 of 6 0 of 0 0 of 0 

Milk Parlor 1of 3 0 of 0 0 of 0 0 of 0 0 of 0 

Housing 8 of 26 7 of 15 7 of 23 5 of 10 4 of 17 

Solid Manure 2 of 8 1 of 8 1 of 8 1 of 8 1 of 8 

Liquid Manure 1 of 11 1 of 11 1 of 11 1 of 11 1 of 11 

Land Application 2 of 7 2 of 7 2 of 7 2 of 7 0 of 0 

TOTAL 19 of 69 17 of 55 17 of 63 14 of 48 11 of 46 

2.3 ECONOMIC COSTS OF RULE 4570 

The socioeconomic analysis within the District’s Staff Report indicated that, although 

there are approximately 247 large CAFs subject to Rule 4570 that would need to 

implement additional mitigation measures to comply with rule requirements. The table 

below summarizes the number and type of CAFs that would need to implement 

additional mitigation measures to comply with the rule and its estimated annual 

compliance costs. 
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Summary of Estimated Total Annual Compliance Cost 

Type of CAF 

Number of 

CAFs 

Estimated Total Annual Compliance 

Costs 

Dairy 233 $18,324,074

Beef Feedlots 6 $590,112

Other Cattle Facilities 5 $7,147,266

Swine 3 $540

TOTAL 247 $26,061,922

Source: District and stakeholder comments 

The socioeconomic impact analysis also showed that the total annual compliance costs 

represented 9.6 percent of the net profits of large dairies, 13.0 percent of the net profits 

of large cattle operators (beef feedlots), 13.5 percent of the net profits of other large 

CAF cattle stakeholders, and <1 percent of the net profits for large CAF swine 

stakeholders;. Annual compliance costs associated with the District’s costs for 

impacted “other cattle industries” exceed the threshold of significance, resulting in direct 

employment impacts of approximately 17 jobs. Factoring in indirect impacts associated 

with the direct loss of 17 jobs, the rule could result in the loss of an additional 23 jobs 

across different industries, for a total job impact of 40 jobs. 

By far, the largest cost involved with Rule 4570 will be borne by dairy operators. This 

section of the report discusses the methodology employed in calculating costs borne by 

affected dairy farms. The same methodology was used for beef feedlots, other cattle 

facilities, and swine facilities. 

It is important to note that agriculture in general, and livestock products in particular, are 

“price takers”, meaning that they have little ability to set price of their goods, and little 

ability to pass on costs to the consumer. As prices of basic goods like beef increase, 

consumers may switch to other products, such as poultry. Alternatively, consumers 

might continue to buy beef, but they may switch to products from other regions or states 

that could be less expensive. 

2.3.1 EXAMPLES OF DESIGN/OPERATIONAL INCOMPATIBILITY WITH 

CONTROLS 

As discussed above, due to the different methods of confinement and associated 

manure management, there is no typical CAF. The design and operation of a CAF 

varies depending on animal type, regional climatic conditions, business practices, and 

preferences of the owners/operators. Not all of the mitigation measures included as an 

option in Rule 4570 can be reasonably adopted by all facilities due to infrastructure, 

conditional use permits, water board permits, soil types, production contracts, and other 

limitations. This is why the District structured the rule such that facilities comply with 

rule requirements utilizing management practices and machinery that owners/operators 

already have reasonably available to them. Examples of some of the mitigation 

measures that may not be adaptable to all facilities due to facility limitations are 

discussed below: 
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Mitigation Measure: “Collect leachate from the silage piles and send it to a waste 

treatment system such as a lagoon at least once every 24 hours” 

Many existing facilities were not initially designed to handle or collect the leachate from 

the silage piles. Although Rule 4570 is a retrofit rule, for many of facilities it is not 

reasonable to retrofit their entire facility to accommodate this mitigation measure. 

Obstacles in achieving this mitigation measure are listed below: 

1. The Lagoon placement is on the opposite side of the silage piles, making 

it almost impossible to transfer the small amount of leachate to the lagoon 

system 

2. Grading and transfer system are non-existent and would require a 

significant amount of construction and demolition 

3. This mitigation measure generally works well with a concrete pad and 

would require a large pad generally an acre in size to be poured 

 

Therefore, Rule 4570 consists of multiple mitigation measures and operators are 

required to choose measures that are appropriate for their method of operation, to 

ensure emission reductions. 

Mitigation Measure: “Use a dry animal waste handling system, such as scraping, instead 

of a liquid animal waste handling system, such as a flush system” 

A significant portion of dairies in the Valley are designed around a flush system and a 

considerable amount of cost goes into building such a dairy. There are also several air 

benefits in having a flush system as long as mitigation measures are implemented. 

Therefore, a dairy that has invested a significant amount of capital and has elected to 

operate their dairy as a liquid manure management will not be able to change the makeup of their entire dairy by convert it over to a scrape system. As stated earlier, Rule 

4570 was specifically structured so that facilities would comply with the rule regardless 

of the type of facility or manure management system. 

There are specific measures available for facilities that have a liquid manure 

management system, just as there are measures for scrape systems. However since 

the flush dairies generate waste at the lagoons, a mitigation measure is also required 

under the liquid manure mitigation category to ensure that the emissions associated 

from that system are also mitigated. 

Mitigation Measure: “Use non-animal waste-based bedding and non-separated solids 

based bedding for at least 90% of the bedding material, by weight, for freestalls (e.g. 

rubber mats, almond shells, sand, or waterbeds)”

This measure requires that a non-animal waste bedding material be used in lieu of 

manure or separated solids. However, not every dairy in the Valley has access to non-
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manure based material due to the limited resource of these materials (almond hulls, 

etc). 

Sand on the other hand has many disadvantages such as clogging of main drains and 

pipes including breakdowns from the considerable amount of wear and tear on pumps 

and equipment. If the infrastructure does not exist to handle this material it is 

unreasonable to implement this mitigation measure; which is why Rule 4570 consists of 

multiple mitigation measures to allow operators the flexibility to choose measures that 

are appropriate for their method of operation, while still ensuring emission reductions. 

Mitigation Measure: “Use lime or a similar absorbent material in the pens according to the 

manufacturer's recommendations to minimize moisture in the pens.” 

Lime is extremely costly and in many cases not feasible due to soil quality and water 

quality issues. Therefore, while this mitigation measure may work for one facility it may 

not work for another. 

Mitigation Measure: “Manage the facility such that there are no lagoons at the facility.” 

Considering the uniqueness from one facility to another, Section 5.13 of Rule 4570 also 

allows CAF facilities to submit an emission mitigation plan demonstrating facility wide 

reductions of at least 30% in lieu of selecting the required mitigation measures. 
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3 REVIEW OF FEDERAL RACT REQUIREMENTS 

3.1 FEDERAL APPLICABILITY OF RACT 

The Clean Air Act (CAA) Section 182(b)(2) states that ozone attainment plans shall assure 

that ract for volatile organic compounds (VOC) is applied at certain sources. 

“The State shall submit a revision to the applicable implementation plan to 

include provisions to require the implementation of reasonably available 

control technology under section 172(c)(1) of this title with respect to each 

of the following: 

(A) Each category of VOC sources in the area covered by a CTG 

document issued by the Administrator between November 15, 1990, and 

the date of attainment. 

(B) All VOC sources in the area covered by any CTG issued before 

November 15, 1990. 

(C) All other major stationary sources of VOCs that are located in the 

area.” 

Because EPA has not issued a CTG for Confined Animal Facilities, the only applicable 

provision above for the San Joaquin Valley, is the need for RACT to be applied to 

“major stationary sources.” Because the San Joaquin Valley Air Basin is classified as 

an extreme ozone area, “major sources” are those that generate more than 10 tons per 

year of NOx or VOC. 

3.2 DEFINITION AND STRINGENCY OF RACT 

Although the Clean Air Act itself does not define Reasonably Available Control 

Technology, 40 CFR 51.100(o) defines RACT as: 

”devices, systems, process modifications, or other apparatus or techniques that 

are reasonably available, taking into account (1) the necessity of imposing such 

controls in order to attain and maintain a national ambient air quality standard; (2) 

the social, environmental, and economic impact of such controls; and (3) 

alternative means of providing for attainment and maintenance of such a 

standard.” 

The foregoing definition applies to a specific federal provision regarding approval of 

extension requests for attainment plans for secondary air quality standards, but in the 

absence of a more definitive regulatory description, it is concise and useful. EPA also 

defined RACT in the Strelow memorandum9

 as: 

 

9

 The Strelow RACT Memorandum, published in BNA Environmental Reporter, December 9, 1976, pages 1210-1212 
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“the lowest emission limitation that a particular source is capable of 

meeting by the application of control technology that is reasonably 

available, considering technological and economic feasibility”. 

3.3 PURPOSE OF FEDERAL RACT 

The Clean Air Act requires RACT for certain sources in all nonattainment areas 

nationwide, regardless of the severity of the ozone problem. 

“172(c) Nonattainment plan provisions 

The plan provisions (including plan items) required to be submitted under 

this part shall comply with each of the following: 

(1) In general 

Such plan provisions shall provide for the implementation of all reasonably 

available control measures as expeditiously as practicable (including such 

reductions in emissions from existing sources in the area as may be 

obtained through the adoption, at a minimum, of reasonably available 

control technology) and shall provide for attainment of the national primary 

ambient air quality standards.” 

From this section, it is clear that RACT is intended as the minimum level of control that 

all ozone nonattainment areas must achieve for existing sources. It is also clear that 

RACT not intended as the only level of control needed for all nonattainment areas to 

attain the ozone standard. Two key conclusions are drawn from the section above: 

first, states must adopt RACT for existing sources regardless if they are needed for 

attainment, and second, states may need additional measures beyond RACT to attain 

the standard. This second conclusion leads to the understanding that RACT is not 

intended to be the most stringent level of control in an area’s attainment strategy. 

In the greater context of air pollution control levels, RACT is understood as the “floorlevel” of air pollution controls, not the “ceiling-level.” More effective levels of emissions 

control are termed Best Available Control Technology (BACT) and Lowest Achievable 

Emission Rate (LAER). BACT and LAER are required for new sources, and for existing 

sources undergoing modification. Under state and federal air pollution programs, new 

facilities face more stringent pollution control requirements than existing facilities, with 

the understanding that better controls can be more easily implemented before a facility 

is built, than after it is built. New sources must generally implement BACT10 and 

 

10 Federal regulations for permitting new facilities require Best Available Control Technology (BACT) for new sources 

in attainment areas, and Lowest Achievable Emission Rate (LAER) – a generally more stringent level –for new 

sources in nonattainment areas. LAER differs from BACT in that economic costs are not considered for candidate 

LAER controls that are considered “Achieved in Practice.” Under California state law, the District is required to apply 

“BACT” for new sources under essentially the same requirements as federal LAER. The District’s “BACT” 

determinations thus fulfill the federal LAER requirements. 
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existing sources must implement a less stringent level of control such as Reasonably 

Available Control Technology (RACT). Additionally, California law establishes an 

intermediate level of control that is the “best available” for “retrofit” to existing sources 

(entitled Best Available Retrofit Control Technology – BARCT11), recognizing that the 

state’s worst ozone problems demands more effective pollution control than what is 

usually considered “reasonably available.” 

As discussed above, the purposes of BACT, RACT, and BARCT are different. BACT is 

designed to minimize the growth in future stationary source emissions with the 

installation of best available controls; RACT is designed to reduce current stationary 

source emissions from existing sources with the application of reasonably available 

controls; and BARCT is designed to reduce current stationary source emissions even 

further with the application of best available retrofit controls. BACT is identified and 

prescribed in the permitting process on a case-by-case administrative basis. RACT and 

BARCT are developed on an industry-wide basis in the rule development process, 

which concludes with quasi-legislative action by the District Governing Board. 

3.4 RACT GUIDANCE FROM EPA REGION IX 

A letter from EPA, Region IX12 outlined documents that could be useful in establishing 

RACT. Those documents include EPA’s Control Techniques Guidelines (CTGs), 

Alternative Control Techniques (ACTs), New Source Performance Standards (NSPS), 

National Emissions Standards for Hazardous Air Pollutants (NESHAPs), EPA Best 

Available Control Technology (BACT) Clearinghouse, California Suggested Control 

Measures (SCM) and RACT/Best Available Retrofit Control Technology (BARCT) 

determinations, regulations adopted in other Districts, and guidance and rules 

developed by other state and local agencies. 

To date, EPA has not developed any federal regulations (NSPS, MACT, NESHAP) or 

guidance (CTG, ACT) specific to CAFs. Best Available Control Technologies and 

regulations adopted in other districts are discussed below. 

3.5 ISSUES REGARDING FEDERAL EXPECTATIONS FOR RACT 

RACT is a “moving target.” Technology considered RACT at the time of SIP-approval 

has always been made obsolete by more effective technology at a later date. This view 

of moving-target RACT requirements precludes using only comparing CTGs/ACTs or 

simply relying on EPA SIP-approval of rules as satisfying RACT requirements; 

therefore, other requirements must be considered. 

 

11 California Health and Safety Code (CH&SC) 40406: ... "best available retrofit control technology" means an 

emission limitation that is based on the maximum degree of reduction achievable, taking into account environmental, 

energy, and economic impacts by each class or category of source. 

12 United States Environmental Protection Agency – letter from Andrew Steckel, EPA Region IX to Kurt Karperos, 

ARB dated March 9, 2006 – RACT SIP 
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It should also be noted that since District rules usually fulfill BARCT requirements for 

state purposes, and the control technology established by a BARCT rule is the most 

effective retrofit control for the existing emission category; it can be assumed to, at a 

minimum, satisfy RACT requirements, if not go beyond RACT. 
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4 DEMONSTRATION THAT RULE 4570 SATISFIES RACT REQUIREMENTS 

This section of the Document shows how Rule 4570 satisfies federal RACT 

requirements. It focuses on the three broad elements that EPA generally reviews when 

evaluating a district rule for inclusion in the State implementation Plan (SIP): 

applicability, stringency, and enforceability. When EPA approves a rule for inclusion 

into the SIP, EPA must evaluate, at a minimum, if the rule fulfills RACT requirements. 

Rule 4570 was submitted to EPA for SIP approval on October 5, 2006, but has not yet 

been acted on by EPA. 

4.1 APPLICABILITY OF RULE 4570 COVERS ALL CAFS THAT ARE MAJOR 

SOURCES AND MANY SMALLER FACILITIES 

Pursuant to Section 3.25 of District Rule 2201 (New and Modified Stationary Source 

Review Rule), a major source is a stationary source with post-project emissions or a 

Post Project Stationary Source Potential to Emit, equal to or exceeding one or more of 

the specified threshold values. In determining whether a facility is a major source, 

fugitive emissions are not counted unless the facility belongs to certain specified source 

categories. 40 CFR 71.2 (Definitions, Major Source (2)) states the following: 

(2) A major stationary source of air pollutants or any group of stationary sources as 

defined in section 302 of the Act, that directly emits, or has the potential to emit, 100 

tpy or more of any air pollutant (including any major source of fugitive emissions of 

any such pollutant, as determined by rule by the Administrator). The fugitive 

emissions of a stationary source shall not be considered in determining whether it is 

a major stationary source for the purposes of section 302(j) of the Act, unless the 

source belongs to one of the following categories of stationary source: (i) Coal 

cleaning plants (with thermal dryers); (ii) Kraft pulp mills; (iii) Portland cement plants; 

(iv) Primary zinc smelters; (v) Iron and steel mills; (vi) Primary aluminum ore 

reduction plants; (vii) Primary copper smelters; (viii) Municipal incinerators capable 

of charging more than 250 tons of refuse per day; (ix) Hydrofluoric, sulfuric, or nitric 

acid plants; (x) Petroleum refineries; (xi) Lime plants; (xii) Phosphate rock 

processing plants; (xiii) Coke oven batteries; (xiv) Sulfur recovery plants; (xv) 

Carbon black plants (furnace process); (xvi) Primary lead smelters; (xvii) Fuel 

conversion plants; (xviii) Sintering plants; (xix) Secondary metal production plants; 

(xx) Chemical process plants; (xxi) Fossil-fuel boilers (or combination thereof) 

totaling more than 250 million British thermal units per hour heat input; (xxii) 

Petroleum storage and transfer units with a total storage capacity exceeding 

300,000 barrels; (xxiii) Taconite ore processing plants; (xxiv) Glass fiber processing 

plants; (xxv) Charcoal production plants; (xxvi) Fossil-fuel-fired steam electric plants 

of more than 250 million British thermal units per hour heat input; or (xxvii) Any other 

stationary source category which, as of August 7, 1980, is being regulated under 

section 111 or 112 of the Act. 

Because agricultural operations do not fall under any of the specific source categories 

listed above, fugitive emissions are not counted when determining if an agricultural 
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operation is a major source. 40 CFR 71.2 defines fugitive emissions as “those 

emissions which could not reasonably pass through a stack, chimney, vent, or other 

functionally-equivalent opening.” 

4.1.1 Dairy 

Since emissions at a dairy are not actually collected, a determination of whether 

emissions could be reasonably collected must be made by the permitting authority. The 

California Air Pollution Control Association (CAPCOA) prepared guidance in 2005 for 

estimating potential to emit of Volatile Organic Compounds from dairy farms. The 

guidance states that “VOC emissions from the milking centers, cow housing areas, 

corrals, common manure storage areas, and land application of manure are not 

physically contained and could not reasonably pass through a stack, chimney, vent, or 

other functionally-equivalent opening. No collection technologies currently exist for VOC 

emissions from these emissions units. Therefore, the VOC emissions from these 

sources are considered fugitive.” The guidance also concludes that, because VOC 

collection technologies do exist for liquid waste systems at dairies, “... the VOC 

emissions from waste lagoons and storage ponds are considered non-fugitive.” The 

District has researched this issue and concurs with the CAPCOA assessment, as 

discussed in more detail below. 

Milking Center: The mechanical system for the milking parlors can be utilized to capture 

the gases emitted from the milking parlors; however in order to capture all of the gases, 

and to keep an appropriate negative pressure throughout the system, the holding area 

would also need to be entirely enclosed. No facility currently encloses the holding area 

since cows are continuously going in and out of the barn throughout the day. The capital 

required to enclose this large area would also be significant. Since the holding area is 

primarily kept open, the District cannot reasonably demonstrate that emissions can pass 

through a stack, chimney, vent, or other functionally equivalent opening. 

Cow Housing: Although there are smaller dairy farms that have partially enclosed 

freestall barns, these barns are not fully enclosed and none of the barns have been 

found to vent the exhaust through a collection device. The airflow requirements through 

dairy barns are extremely high, primarily for herd health purposes. The airflow 

requirements will be even higher in the San Joaquin valley, where temperatures reach 

in excess of 110 degrees in the hot summer. Collection and control of the exhaust 

including the large amounts of airflow have not yet been achieved by any facility. Due to 

this difficultly, the District cannot reasonably demonstrate that emissions can pass 

through a stack, chimney, vent, or other functionally equivalent opening. 

It must also be noted that EPA has determined that emissions from open-air cattle 

feedlots are fugitive in nature.13 In the District’s judgment, this determination for 

emissions from open feedlots necessitates a similar determination for the open-sided 

 

13 Letter from William Wehrum, EPA Acting Administrator, to Terry Stokes, Chief Executive Officer – 

National Cattlemen’s Beef Association (November 2, 2006) 

(http://www.epa.gov/Region7/programs/artd/air/nsr/nsrmemos/cowdust.pdf) 
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freestalls (usually with open access to corrals or pens and free movement of cattle in 

and out of the covered area) typical of the San Joaquin Valley since the typical open 

freestall barn in the San Joaquin Valley bears a far greater resemblance to an extensive 

shade structure located in a large open lot than an actual enclosed building. Therefore, 

emissions from open freestall barns are most appropriately treated as fugitive. 

Manure Storage Areas: Many dairies have been found to cover dry manure piles. 

Covering dry manure piles is also a mitigation measure included in District Rule 4570. 

However, the District was not able to find any facility, which currently captures the 

emissions from the storage or handling of manure piles. Although many of these piles 

are covered, the emissions cannot reasonably be captured. Therefore, the District 

cannot reasonably demonstrate that these emissions can pass through a stack, 

chimney, vent, or other functionally equivalent opening. In addition, emissions from 

manure piles have been shown to be insignificant in recent studies. 

Land Application: Emissions generated from the application of manure on land cannot 

reasonably be captured due to the extremely large areas, in some cases thousands of 

acres, of cropland at dairies. Therefore, the District cannot reasonably demonstrate that 

these emissions can pass through a stack, chimney, vent, or other functionally 

equivalent opening. 

Feed Handling and Storage: The majority of dairies store the silage piles underneath a 

tarp or in an Agbag. The entire pile is covered except for the face of the pile. The face 

of the pile is kept open due to the continual need to extract the silage for feed purposes. 

The silage pile is disturbed 2-3 times per day. Because of the ongoing disturbance to 

these piles, it makes it extremely difficult to design a system to capture the emissions 

from these piles. In fact, as far as the District is aware, no system has been designed to 

successfully extract the gases from the face of the pile to capture them, and, as 

important, no study has assessed the potential impacts on silage quality of a continuous 

air flow across the silage pile, as would be required by such a collection system. 

Therefore, the District cannot demonstrate that these emissions can be reasonably 

expected to pass through a stack, chimney, vent, or other functionally equivalent 

opening. 

As discussed above, the VOC emissions from the milking center, cows housing, manure 

storage areas, land application of manure and feed handling and storage are 

considered fugitive. The District has determined that control technology to capture 

emissions from lagoons (biogas collection systems, for instance) is in use; therefore, 

these emissions can be reasonably collected and are not fugitive. Therefore, only 

emissions from the non-fugitive sources, such as lagoons, storage ponds, IC engines, 

and gasoline tanks, will be used to determine if dairies are major sources. 
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4.1.2 Poultry Houses 

As discussed in section 1.1.3.4, majority of poultry operations consist of ventilated 

houses. Since these houses have the potential of being fully enclosed and reasonably 

vented to a stack, the emissions from these sources will be considered non-fugitive. 

4.1.3 Conclusion – Rule 4570 Applicability Covers All Major Sources 

Based on the discussion above, the majority of the agricultural sources in the Valley will 

be considered fugitive sources of emissions. Since fugitive emissions are not 

considered in the determination of a major source, then the majority of facilities in the 

Valley will not be considered as major sources. The following table shows the number 

of facilities that will potentially be major sources in the Valley: 

Livestock 

Category

Applicability 

of Rule 4570 

# of facilities 

Subject to Rule 

4570 

Major Source 

Thresholds 

# of major 

sources 

Dairy 1,000 lactating 

cows 

≈550 7,407 milk cow 

equivalents 

22-29 

Beef Feedlots 3,500 beef 

cattle 

12 12,500 cattle only if 

lagoons on-site 

0 

Other Cattle 

Operations 

7,500 calves, 

heifers, and 

other cattle 

--- 16,667 heifers & 

22,222 calves 

0 

ChickensBroilers & Egg

Layers 

650,000 head 32 400,000 broilers & 

800,000 layers 

31 

Turkeys 100,000 head 35 200,000 turkeys 11 

Swine 3,000 head 1 ≈4,500 1 

Sheep and 

Goats 

15,000 head 0 --- --- 

Horses 2,500 head 0 --- --- 

Ducks 650,000 head 0 400,000 ducks 0 

Other 

Livestock Not 

Previously 

Mentioned 

30,000 head --- --- --- 

Given that RACT only applies to major sources of emissions, based on the table above, 

only a small percentage of facilities subject to Rule 4570 are actually subject to federal 

RACT requirements. However, Rule 4570 requires facilities greater than the thresholds 

listed above to comply with the requirements of Rule 4570, which is a much larger set of 

facilities, and hence more stringent. 
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4.2 THE REQUIREMENTS OF RULE 4570 ARE SUFFICIENTLY EFFECTIVE TO 

BE CONSIDERED RACT 

Rule 4570 requires operators of a CAF to implement multiple VOC mitigation measures 

for the major emission sources at each facility. The sources covered by the Rule and 

the number of measures required are shown in the following table: 

Summary of the Minimum Number of VOC Mitigation Measures Per 

Animal Type and Area Compared to Total Number of Options 

Area Dairy Beef Other 

Cattle 

Swine Poultry 

Feed 4 of 8 5 of 8 5 of 8 5 of 12 5 of 10 

Silage 1 of 6 1 of 6 1 of 6 0 of 0 0 of 0 

Milk Parlor 1of 3 0 of 0 0 of 0 0 of 0 0 of 0 

Housing 8 of 26 7 of 15 7 of 23 5 of 10 4 of 17 

Solid Manure 2 of 8 1 of 8 1 of 8 1 of 8 1 of 8 

Liquid Manure 1 of 11 1 of 11 1 of 11 1 of 11 1 of 11 

Land 

Application 2 of 7 2 of 7 2 of 7 2 of 7 0 of 0 

TOTAL 19 of 69 17 of 55 17 of 63 14 of 48 11 of 46 

As discussed earlier, there is no typical CAF. This menu option not only provides 

flexibility to facilities to select measures that are suitable to their particular operation, but 

the requirement to implement multiple mitigation measures in each source category 

results in a larger emission reduction. 

4.2.1 RULE 4570 REQUIREMENTS HAVE BEEN APPROVED BY EPA AS BACT 

The District has issued permits to well over 40 new and expanding dairies over the last 

few years. These permits were issued with Rule 4570 mitigation measures as a part of 

the Best Available Control Technology (BACT) requirements. The District also issued 

permits to a couple of new and modifying poultry operations. These permits were also 

issued with Rule 4570 mitigation measures as part of BACT. Since these measures 

have been considered to be BACT for these facilities, Rule 4570 exceeds the RACT 

requirements. In addition, BACT advances technology more so than the Rule process 

does. A copy of the poultry BACT analysis is attached as attachment xxx. 

4.2.2 RULE 4570 IS AS EFFECTIVE AS OTHER AIR DISTRICTS 

As the largest agriculture area in the state, the District took the lead in developing the 

variety of mitigation measures list in District Rule 4570. This list is essentially identical 

for all air districts that identify mitigation measures in their rules. While other air districts 

have adjusted some of the original mitigation measures; District Rule 4570 list still 

serves as the primary source for available emission controls for large CAFs. 
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Of all the air districts analyzed, only Sacramento Metropolitan AQMD and the District 

claimed emission reductions from adopting their rules. Emission reductions affected the 

various types of CAFs differently, however, in the final staff report for District Rule 4570, 

overall emission reductions were estimated at 28% of the calculated baseline 

emissions. Sac Metro used similar methodology for sources in their area and claimed a 

24% reduction from the total CAF baseline emissions. 

The following California air district rules were compared to District Rule 4570: 

• South Coast AQMD Rule 223 

• Bay Area AQMD Regulation 2 Rule 10 

• Ventura County APCD Rule 23 

• Sacramento Metropolitan AQMD Rule 496 

• Imperial County AQMD Rule 217 and Policy 38 

• Butte County APCD Rule 450 

It is important to note that only District Rule 4570 and Sacramento Metropolitan AQMD 

Rule 496 are prohibitory rules. For this reason, these rules include detailed 

recordkeeping as well as monitoring and testing requirements. Generally, the level of 

detail in a prohibitory rule is absent from permits rules because the purpose of a permit 

rule is different from the purpose of a prohibitory rule. 

4.2.2.1 South Coast AQMD Rule 223 

4.2.2.1.1 Applicability/Exemption/Large CAF Definition 

South Coast AQMD adopted ARB’s definition of large CAF. District Rule 4570 defines 

large CAF the same way except for a large horse CAF. District Rule 4570 defines a 

large horse CAF as 3,000 head, whereas South Coast AQMD defines it as 2,500 head.

4.2.2.1.2 Requirements for Dairy Large CAFs 

Feed Mitigation Measures 

District Rule 4570 has seven Class One mitigation measures for feed and three Class 

One mitigation measures for silage. There are three Class Two mitigation measures for 

silage. Operators must implement four feed mitigation measures and one silage 

mitigation measure for five total feed mitigation measures. In the South Coast AQMD 

rule, there are nine feed mitigation measures, from which the operator must implement 

five. In the South Coast AQMD rule, there is no requirement to control emissions from 

silage. In this respect, District Rule 4570 is more stringent. 

Within the Class One mitigation measures, removal of excess/spoilt feed from feed 

lanes/aprons, is more stringent under the South Coast AQMD rule. The South Coast 

AQMD rule requires excess/spoilt feed to be removed every 7 days, whereas Rule 4570 

requires this to be done every 14 days. 
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Milk Parlor Mitigation Measures 

The milk parlor mitigations measures are identical. Each rule has one Class One and 

one Class Two mitigation measure, from which operators are required to implement at 

least one. 

Freestall Mitigation Measures 

District Rule 4570 has eight Class One and one Class Two mitigation measures, from 

which facilities are required to implement at least two. South Coast AQMD Rule 223 

has eight Class One mitigations measures (no Class Two mitigation measures), from 

which facilities are required to implement at least two. The extra (Class Two) mitigation 

measure option offered by District Rule 4570 is vacuuming waste instead of scraping or 

flushing and injecting or incorporating into land with 72 hours of removal. 

South Coast AQMD Rule 223 has three Class One mitigation measures that are more 

stringent than the corresponding District Rule 4570 measures: (inspect water pipes and 

troughs and repair leaks; remove animal waste that is not dry from individual cow 

freestall beds; and rake, harrow, scrape, or grade bedding in freestalls). The South 

Coast rule requires pipes and troughs to be inspected daily, and manure from freestall 

beds to be removed daily, whereas District Rule 4570 requires both of these measures 

to be carried out only once only every 14 days. The South Coast rule also requires 

freestall beds to be raked/harrowed/graded at least twice every seven days, whereas 

District Rule 4570 requires this measure to be carried out only once every 14 days. 

Although, South Coast rule has a higher frequency for these measures, the emissions 

generated from these sources are not significant, including the reductions achieved 

from the overall dairy. In addition, the frequency required by the South Coast Rule 

exceeds RACT when compared to inspection leak requirements in other Rules and 

regulations. 

Corral Mitigation Measures 

District Rule 4570 has 15 Class One mitigation measures and three Class Two 

mitigation measures, from which facilities are required to choose at least six. South 

Coast AQMD Rule 223 has 14 Class One mitigation measures and two Class Two 

mitigation measures, from which facilities are required to choose at least six. 

South Coast AQMD Rule 223 has one Class One mitigation measure (inspect water 

pipes and troughs and repair leaks) that is more stringent than the corresponding 

District Rule 4570 measure. The South Coast rule requires this measure to be carried 

out daily, whereas District Rule 4570 requires it to be carried out only once every 14 

days. Although, South Coast rule has a higher frequency for this measure, the 

emissions generated from this source is not significant, including the reductions 

achieved from the overall dairy. In addition, the frequency required by the South Coast 

Rule exceeds RACT when compared to inspection leak requirements in other Rules and 

regulations. 
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The two rules also differ slightly in the categorization (Class One vs. Class Two) of 

mitigation measures relating to shade structures and corrals soil additives, but these 

differences are not expected to have any effect on the stringency of the mitigation 

measures. 

Solid Waste and Separated Solids Mitigation Measures 

District Rule 4570 has five Class One mitigation measures and three Class Two 

mitigation measures, from which operators are required to choose at least two. South 

Coast AQMD Rule 223 has three Class One mitigation measures and three Class Two 

mitigation measures, from which facilities are required to choose at least two. 

South Coast AQMD Rule 223 has one Class Two mitigation measure (send at least 

51% of the animal waste removed from animal housing to a digester) that is more 

stringent than the corresponding District Rule 4570 measure. The South Coast rule 

specifies that the animal waste must be sent to a digester within 72 hours of removal 

from housing, whereas District Rule 4570 does not specify a timeline within which this 

measure must be implemented. 

Since Class Two options are not required, they do not affect the stringency of the rule. 

In addition, the emissions from solid manure account for a fraction of emissions from the 

overall dairy, thus resulting in a very small reduction in emission regardless of the 

practice selected. 

Liquid Waste Mitigation Measures 

District Rule 4570 has five Class One mitigation measures and five Class Two 

mitigation measures, from which operators are required to choose at least one. South 

Coast AQMD Rule 223 has five Class One mitigation measures and five Class Two 

mitigation measures, from which operators are required to choose at least one. All the 

mitigation measures are similar in stringency. 

Land Application of Manure Mitigation Measures 

District Rule 4570 has six Class One mitigation measures, from which facilities are 

required to choose at least two. South Coast AQMD Rule 223 has four Class One 

mitigation measures, from which facilities are required to choose at least two. All the 

mitigation measures are similar in stringency. 

4.2.2.1.3 Requirements for Poultry Large CAFs 

Feed Mitigation Measures 

District Rule 4570 has nine Class One mitigation measures, from which facilities are 

required to choose at least five. South Coast AQMD Rule 223 has nine Class One 
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mitigation measures, from which facilities are required to choose at least five. All the 

mitigation measures are similar in stringency. 

Housing Mitigation Measures 

District Rule 4570 has twelve Class One mitigation measures and four Class Two 

mitigation measures, from which facilities are required to choose at least four. South 

Coast AQMD Rule 223 has twelve Class One mitigation measures and four Class Two 

mitigation measures, from which facilities are required to choose at least four. South 

Coast AQMD Rule 223 has four Class One mitigation measures (remove caked 

manure; clean under poultry cages; adjust the height, volume, and location of drinkers; 

and inspect water pipes and drinkers and repair leaks) that are more stringent than the 

corresponding District Rule 4570 measures. The South Coast rule requires these 

measures to be carried out daily, whereas District Rule 4570 requires them to be carried 

out only once every 14 days. 

Solid Waste and Separated Solids Mitigation Measures 

District Rule 4570 has four Class One mitigation measures and two Class Two 

mitigation measures, from which facilities are required to choose at least one. South 

Coast AQMD Rule 223 has four Class One mitigation measures and three Class Two 

mitigation measures, from which operators are required to choose at least one. District 

Rule 4570 has one Class One mitigation measure (send all animal waste to a lagoon) 

that is more stringent than the corresponding South Coast AQMD Rule 223 measure. 

District Rule 4570 requires this measure to be carried out within 72 hours of manure 

being removed from housing, whereas South Coast AQMD Rule 223 does not specify 

any timeline within which the measure is to be carried out. 

South Coast AQMD Rule 223 has one Class Two mitigation measure (send at least 

51% of the animal waste removed from animal housing to a digester) that is more 

stringent than the corresponding District Rule 4570 measure. The South Coast rule 

specifies that the animal waste must be sent to a digester within 72 hours of removal 

from housing, whereas District Rule 4570 does not specify a timeline within which this 

measure must be implemented. 

Since Class Two options are not required, they do not affect the stringency of the rule. 

In addition, the emissions from solid manure account for a fraction of emissions from the 

overall dairy, thus resulting in a very small reduction in emission regardless of the 

practice selected. 

Liquid Waste Mitigation Measures 

District Rule 4570 has five Class One mitigation measures and five Class Two 

mitigation measures, from which facilities are required to choose at least one. South 

Coast AQMD Rule 223 has five Class One mitigation measures and five Class Two 
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mitigation measures, from which facilities are required to choose at least one. All 

mitigation measures are similar in stringency. 

4.2.2.1.4 Requirements for Other Large CAF Categories 

In addition to dairy and poultry CAF mitigation measures discussed above, District Rule 

4570 provides specific mitigation measure option tables for beef cattle feedlots, other 

cattle, and swine CAFs. South Coast AQMD Rule 223 does not address mitigation 

measures for these additional CAF categories. For these types of large CAFs, District 

Rule 4570 is more stringent. 

4.2.2.1.5 Requirements – Suspension and Substitution of Mitigation Measures 

Both rules allow the temporary suspension of a mitigation measure upon the 

determination by a certified veterinarian or nutritionist that such a suspension is 

necessary for animal health purposes. The District must be notified within 48 hours, 

and a new measure must be implemented if the suspension is expected to last longer 

than 30 days. In addition, both rules allow for substitution of one mitigation measure 

with an equivalent or more stringent one with the submission of the appropriate 

application. 

4.2.2.1.6 Testing, Monitoring, Recordkeeping Requirements 

District Rule 4570 requires records to be maintained and retained for at least five years, 

whereas South Coast AQMD Rule 223 requires records to be retained for three years 

for non-Title V facilities and five years for Title V facilities. District Rule 4570 therefore 

has a more stringent record retention requirement. 

District Rule 4570 requires facilities not subject to the mitigation measure requirements 

to maintain sufficient records to demonstrate their exemption status. Facilities subject 

to the mitigation measure requirements must monitor, test, and maintain sufficient 

records to demonstrate implementation of each mitigation measure selected. Facilities 

must also maintain animal population records. 

South Coast AQMD Rule 223 requires the maintenance of animal population records 

but does not require specific records needed to demonstrate implementation of each 

mitigation measure selected. District Rule 4570 is therefore more stringent in the type 

of records required to be maintained. 

4.2.2.1.7 Conclusion – Comparison with South Coast AQMD Rule 223 

Under the dairy and poultry CAF categories, District Rule 4570 and South Coast AQMD 

Rule 223 have nearly identical mitigation measure options and requirements. There are 

slight differences in the frequency with which some mitigation measures are to be 

implemented. Specifically, there are a few measures that must be carried out weekly or 

daily under South Coast AQMD Rule 223 requirements, but only once every two weeks 
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under District Rule 4570 requirements. However, as stated earlier, many of these 

sources are a small portion of a dairy’s overall emissions. For the larger emission 

sources, such as feed handling and cow housing, emission strategies for both rules are 

fairly equivalent, resulting in larger emission reductions. Therefore, District staff does 

not consider the differences between the mitigation measures from the two rules to be 

significant overall. 

District Rule 4570 also provides mitigation for more CAF categories (beef feedlots, other 

cattle, and swine) that are not addressed by South Coast AQMD Rule 223, and also has 

much more detailed recordkeeping requirements to demonstrate implementation of 

selected mitigation measures. District Rule 4570 is, therefore, more stringent overall 

than South Coast AQMD Rule 223. 

4.2.2.2 South Coast AQMD Rule 1127 

4.2.2.2.1 Applicability/Exemption/Large CAF Definition 

South Coast AQMD Rule 1127 applies to dairies with 50 or more cows, heifers, and/or 

calves. The rule applies to dairy farms and related operations such as heifer and calf 

farms and the manure produced on them. By comparison, District Rule 4570 applies to 

large CAFs regardless of animal species and covers all major processes within the 

CAF. For dairies, District Rule 4570 applies to those CAFs with more than 1,000 

milking cows, but applies to more than manure-handling operations. 

4.2.2.2.2 Requirements for Dairy Large CAFs 

Feed, Milking Parlor, and Freestall Mitigation Measures 

District Rule 4570 has seven Class One mitigation measures for feed and three Class 

One mitigation measures for silage. There are three Class Two mitigation measures for 

silage. Operators must implement four feed mitigation measures and one silage 

mitigation measure for five total feed mitigation measures. For the milking parlor, the 

District rule has one Class One and one Class Two mitigation measure, from which 

operators are required to implement at least one. District Rule 4570 has eight Class 

One and one Class Two freestall mitigation measures, from which facilities are required 

to implement at least two. South Coast AQMD Rule 1127 does not address these 

operations. District Rule 4570 is more stringent than South Coast AQMD Rule 1127 for 

these dairy operations. 

Corral Mitigation Measures 

South Coast AQMD Rule 1127 requires a total of four corral mitigation measures. 

District Rule 4570 has 15 Class One mitigation measures and three Class Two 

mitigation measures, from which operators are required to choose at least six. While 

the mitigation measures in the two rules are not phrased the same way, they cover 

similar requirements. 
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Solid Waste, Separated Solids, and Liquid Waste, and Land Application Mitigation 

Measures 

District Rule 4570 has five Class One mitigation measures and three Class Two 

mitigation measures for solid waste/separated solids, from which operators are required 

to choose at least two. For liquid waste, District Rule 4570 has five Class One 

mitigation measures and five Class Two mitigation measures, from which operators are 

required to choose at least one. District Rule 4570 has six Class One mitigation 

measures for land application, from which operators are required to choose at least two. 

A dairy is able to comply fully with South Coast AQMD Rule 1127 by applying its 

manure to approved cropland, since composting and anaerobic digestion are options 

rather than requirements. Similarly, a dairy is able to comply fully with District Rule 4570 

by applying its manure to cropland, since composting, storage in enclosed containers 

and anaerobic digestion are all option rather than requirements. 

There is therefore no difference at all in stringency between South Coast AQMD Rule 

1127 and District Rule 4570 as far as disposal of manure is concerned. In this category, 

District Rule 4570 is as stringent as South Coast AQMD Rule 1127. 

4.2.2.2.3 Requirements for Other Large CAFs 

District Rule 4570 provides specific mitigation measures for beef cattle feedlots, other 

cattle, poultry, and swine CAFs. South Coast AQMD Rule 1127 does not address 

mitigation measures for these additional CAF categories. For these types of large 

CAFs, District Rule 4570 is more stringent. 

4.2.2.2.4 Requirements – Suspension and Substitution of Mitigation Measures 

South Coast AQMD Rule 1127 provides one exemption per year from one of the corral 

clearings required every 90 days if the moisture content in the corrals is greater than 

50%. The operator is required to notify the AQMD 30 days before the required cleaning, 

and test moisture content weekly. If moisture content is still above 50% when the 

cleaning is due, the operator may claim the exemption. 

In comparison, District Rule 4570 allows an operator to temporarily suspend any 

mitigation measure as long as the suspension is recommended by a licensed 

veterinarian of animal nutritionist on the basis of animal health. The operator must notify 

the District within 48 hours prior to the suspension. If the suspension is expected to last 

longer than 30 days, then the operator must submit a new mitigation plan that identifies 

a new mitigation measure to be implemented in place of the suspended one. 

District Rule 4570’s exemption under this category is much more stringent because it is 

only a temporary suspension that cannot exceed 30 days, whereas South Coast AQMD 

Rule 1127’s exemption is permanent, without any requirement to makeup for the 
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skipped mitigation. In addition, the exemption provided by Rule 1127 is very likely to be 

claimed much more frequently than the suspension provided by Rule 4570. This is 

because cattle corrals are usually waterlogged during winter rains and dairies whose 

corral clean-outs are due during such a period will qualify for the exemption. It is very 

unlikely that any of the mitigation measures required by District Rule 4570 will require 

suspension on animal health reasons, since most of the measures have been used in 

various dairies without any reported animal health issues. The District has not received 

any requests for suspension of any mitigation measure since the rule came into effect. 

In this category of mitigation measure exemptions, therefore, District Rule 4570 is more 

stringent than South Coast AQMD Rule 1127. 

4.2.2.2.5 Testing, Monitoring, Recordkeeping Requirements 

Both South Coast AQMD Rule 1127 and District Rule 4570 require monitoring, record 

keeping and source testing as appropriate and sufficient to provide evidence of each 

mitigation measure being implemented. 

In addition to record keeping, Rule 1127 requires an annual report of manure being 

shipped out of the dairy. No annual reporting is required by Rule 4570. Rule 1127 

requires records be retained for 3 years for minor sources and 5 years for major 

sources, whereas Rule 4570 requires records be retained for five years for all sources. 

Overall, the monitoring, testing and record keeping requirements are fairly similar for 

both rules. 

4.2.2.2.6 Conclusion – Comparison with South Coast AQMD Rule 1127 

For dairy CAFs, District Rule 4570 is more stringent than South Coast AQMD Rule 1127 

in one out of four comparable categories and as stringent as South Coast AQMD Rule 

1127 in an additional two out of the four comparable categories. 

Although District Rule 4570 is less stringent in the exemptions category (herd size 

exemption), it is more stringent overall because it requires emission reductions from 

four additional emission categories - milk parlors, feed, freestall barns, and liquid 

manure - that are not addressed at all by South Coast AQMD Rule 1127 as well as 

requiring emission reductions from CAFs fro other animal species. 

4.2.2.3 Bay Area AQMD Regulation 2 Rule 10 (Rule 2-10) 

Bay Area AQMD Rule 2-10 is a permit rule. As such, it has fewer specifics about large 

CAFs than District Rule 4570, which is a prohibitory rule. 
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4.2.2.3.1 Applicability/Exemption/Large CAF Definition 

Bay Area AQMD adopted ARB’s definition of large CAF. District Rule 4570 defines 

large CAF the same way except for a large horse CAF. District Rule 4570 defines a 

large horse CAF as 3,000 head, whereas Bay Area AQMD defines it as 2,500 head.

4.2.2.3.2 Requirements for Large CAFs 

The Bay Area permit conditions must implement control measures that represent 

reasonably available control technology (RACT) to reduce emissions of VOC, NOx and 

PM from the facility. Rule 2-10 requires RACT mitigation measures rather than the 

more stringent BARCT controls required by District Rule 4570 as specifically noted in 

the Bay Area AQMD staff report for their rule. A recent phone call to Bay Area AQMD 

staff verified that there is no list of RACT mitigation measures in place should a large 

CAF apply for a permit. In this respect, District Rule 4570 is more stringent than Bay 

Area AQMD Rule 2-10. 

4.2.2.3.3 Testing, Monitoring, Recordkeeping Requirements 

District Rule 4570 requires records to be maintained and retained for at least five years, 

whereas Bay Area AQMD Rule 2-10 requires records to be retained for three years. 

District Rule 4570 therefore has a more stringent record retention requirement. 

District Rule 4570 requires facilities not subject to the mitigation measure requirements 

to maintain sufficient records to demonstrate their exemption status. Facilities subject to 

the mitigation measure requirements must maintain sufficient records to demonstrate 

implementation of each mitigation measure selected. Facilities must also maintain 

animal population records. Bay Area AQMD Rule 2-10 requires the maintenance of 

animal population records but does not require specific records needed to demonstrate 

implementation of each mitigation measure selected. District Rule 4570 is therefore 

more stringent in the type of records required to be maintained. 

4.2.2.3.4 Conclusion – Comparison with Bay Area AQMD Regulation 2 Rule 10 

District staff concludes that District Rule 4570 is generally more stringent than Bay 

Area’s Rule 2-10. This is to be expected given the difference in ozone attainment status 

between Bay Area AQMD and the District.

4.2.2.4 Ventura County APCD Rule 23 – Exemptions from Permit 

In response to SB 700, Ventura County APCD revised its “Exemptions from Permit” rule 

to remove an exemption for agricultural operations, including CAFs. Ventura County 

APCD does not have a specific rule for CAFs. In its staff report for the rule revision, 

Ventura County APCD staff noted that no facilities in their jurisdiction would meet the 

“large CAF” definition and there was no expectation that a large CAF would move into 

the area in the foreseeable future; therefore, no separate CAF rule was necessary. 
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4.2.2.4.1 Applicability/Exemption/Large CAF Definition 

Ventura County APCD adopted ARB’s definition of large CAF. District Rule 4570 

defines large CAF the same way except for a large horse CAF. District Rule 4570 

defines a large horse CAF as 3,000 head, whereas Ventura County APCD defines it as 

2,500 head. At the time of rule amendment, there are no facilities that would trigger the 

large CAF threshold within Ventura County. 

4.2.2.4.2 Requirements for Large CAFs 

There are no facilities that would trigger the large CAF threshold within the county, as 

stated in the Ventura County staff report for amending Rule 23. The Ventura County 

APCD New Source Review Rule does not list mitigation measures for large CAFs. 

Instead, BACT would be triggered by a new CAF that met the “large CAF” definition or 

BACT would be triggered if an existing CAF expanded operations enough to meet the 

“large CAF” definition. At that point, Ventura County APCD staff would determine BACT 

for the CAF. 

4.2.2.4.3 Conclusion – Ventura County APCD Rule 23 

Ventura County APCD does not have a specific rule for CAFs, therefore District Rule 

4570 is more stringent. 

4.2.2.5 Sacramento Metropolitan AQMD Rule 496 

Like District Rule 4570, Sac Metro AQMD Rule 496 is a prohibitory rule, meaning that 

there are detailed requirements for operators. 

4.2.2.5.1 Applicability/Exemption/Large CAF Definition 

Sacramento Metropolitan (Sac Metro) AQMD Rule 496 adopted ARB’s definition of 

large CAF. District Rule 4570 defines large CAF the same way except for a large horse 

CAF. District Rule 4570 defines a large horse CAF as 3,000 head, whereas Sac Metro 

AQMD defines it as 2,500 head. 

4.2.2.5.2 Requirements for Dairy Large CAFs 

Feed Mitigation Measures 

District Rule 4570 has seven Class One mitigation measures for feed and three Class 

One mitigation measures for silage. There are three Class Two mitigation measures for 

silage. Operators must implement four feed mitigation measures and one silage 

mitigation measure for five total feed mitigation measures. Sac Metro AQMD has seven 

Class One mitigation measures for feed and three Class One mitigation measures for 

silage. There are three Class Two mitigation measures for silage. Operators must 

implement four feed mitigation measures and one silage mitigation measure for five 
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total feed mitigation measures. The Class One and Class Two mitigation measures are 

the same in both rules. 

Milk Parlor Mitigation Measures 

The milk parlor mitigations measures are identical for Sac Metro and for the District. 

Each rule has one Class One and one Class Two mitigation measure, from which 

facilities are required to choose at least one. 

Freestall Mitigation Measures 

District Rule 4570 has eight Class One and one Class Two mitigation measures, from 

which facilities are required to implement at least two. Sac Metro AQMD Rule 496 has 

eight Class One mitigations measures and one Class Two mitigation measure from 

which facilities are required to implement at least two. The Sac Metro AQMD freestall 

barn mitigations measures and the District Rule mitigation measures are identical. 

Sac Metro AQMD Rule 496 has one Class One mitigation measures that are more 

stringent than the corresponding District Rule 4570 measures - inspect water pipes and 

troughs and repair leaks. The Sac Metro AQMD rule requires pipes and troughs to be 

inspected and repaired daily, whereas District Rule 4570 requires that this mitigation 

measure be carried out once every 14 days. 

Corral Mitigation Measures 

District Rule 4570 has 15 Class One mitigation measures and three Class Two 

mitigation measures, from which facilities are required to choose at least six. Sac Metro 

AQMD Rule 496 has 15 Class One mitigation measures and three Class Two mitigation 

measures, from which facilities are required to choose at least six. 

Sac Metro AQMD Rule 496 has one Class One mitigation measure (inspect water pipes 

and troughs and repair leaks) that is more stringent than the corresponding District Rule 

4570 measure. The Sac Metro rule requires this measure to be carried out daily, 

whereas District Rule 4570 requires it to be carried out only once every 14 days. 

Solid Waste and Separated Solids Mitigation Measures 

District Rule 4570 has five Class One mitigation measures and three Class Two 

mitigation measures, from which operators are required to choose at least two. Sac 

Metro AQMD Rule 496 has five Class One mitigation measures and three Class Two 

mitigation measures, from which facilities are required to choose at least two. The 

Class One and Class Two mitigation measures are identical in both rules. 
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Liquid Waste Mitigation Measures 

District Rule 4570 has five Class One mitigation measures and five Class Two 

mitigation measures, from which facilities are required to choose at least one. The Sac 

Metro rule has four Class One mitigation measures and four Class Two mitigation 

measures, from which facilities are required to choose at least one. All the mitigation 

measures are similar in stringency. 

Land Application of Manure Mitigation Measures 

District Rule 4570 has six Class One mitigation measures, from which facilities are 

required to choose at least two. Sac Metro AQMD Rule 496 has six Class One 

mitigation measures, from which facilities are required to choose at least two. All the 

mitigation measures are similar in stringency. 

4.2.2.5.3 Requirements for Poultry Large CAFs 

Feed Mitigation Measures 

District Rule 4570 has nine Class One mitigation measures, from which facilities are 

required to choose at least five. Sac Metro AQMD Rule 496 has nine Class One 

mitigation measures, from which facilities are required to choose at least five. All the 

mitigation measures are similar in stringency. 

Housing Mitigation Measures 

District Rule 4570 has twelve Class One mitigation measures and four Class Two 

mitigation measures, from which facilities are required to choose at least four. Sac 

Metro AQMD Rule 496 has twelve Class One mitigation measures and four Class Two 

mitigation measures, from which facilities are required to choose at least four. Except 

as noted below, all the mitigation measures are similar in stringency. 

Sac Metro AQMD Rule 496 has one Class One mitigation measure - inspect water 

pipes and drinkers and repair leaks - that is more stringent than the corresponding 

District Rule 4570 measure. The Sac Metro AQMD rule requires the inspection and 

repair to be carried out daily, whereas District Rule 4570 requires the mitigation 

measure to be carried out once every 14 days. 

Solid Waste and Separated Solids Mitigation Measures 

District Rule 4570 has four Class One mitigation measures and two Class Two 

mitigation measures, from which facilities are required to choose at least one. Sac 

Metro AQMD Rule 496 has four Class One mitigation measures and two Class Two 

mitigation measures, from which operators are required to choose at least one. All the 

mitigation measures are similar in stringency. 
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Liquid Manure Handling 

District Rule 4570 has five Class One mitigation measures and five Class Two 

mitigation measures, from which facilities are required to choose at least one. Sac 

Metro AQMD Rule496 has five Class One mitigation measures and five Class Two 

mitigation measures, from which facilities are required to choose at least one. All 

mitigation measures are similar in stringency.

4.2.2.5.4 Other Large CAFs 

In addition to dairy and poultry CAF mitigation measures discussed above, District Rule 

4570 provides specific mitigation measure option tables for beef cattle feedlots, other 

cattle, and swine CAFs. Sac Metro AQMD Rule 496 does not address mitigation 

measures for these additional CAF categories. For these types of large CAFs, District 

Rule 4570 is more stringent. 

4.2.2.5.5 Requirements – Suspension and Substitution of Mitigation Measures 

Both rules allow for substitution of one mitigation measure with an equivalent or more 

stringent one with the submission of the appropriate application. District Rule 4570 also 

allows the temporary suspension of a mitigation measure upon the determination by a 

certified veterinarian or nutritionist that such a suspension is necessary for animal 

health purposes. The District must be notified within 48 hours, and a new measure 

must be implemented if the suspension is expected to last longer than 30 days. The 

Sac Metro AQMD rule does not have a specific provision for temporary suspension of 

mitigation measures.

4.2.2.5.6 Testing, Monitoring, Recordkeeping Requirements 

The testing, monitoring, and recordkeeping provisions of District Rule 4570 and Sac 

Metro Rule 496 are essentially identical, therefore, are of equal stringency. 

4.2.2.5.7 Conclusion – Comparison with Sac Metro AQMD Rule 496 

District Rule 4570 and Sac Metro Rule 496 are equivalent for large CAFs that are 

dairies and poultry operations, therefore, they are equally stringent for dairy and poultry 

CAFs. Since District Rule 4570 details mitigation measures for additional large CAFs, 

District staff concludes that District Rule 4570 is more stringent for large CAFs other 

than dairies and poultry operations. 

4.2.2.6 Imperial County APCD Rule 217 – Large Confined Animal Facilities 

Permits Required and ICAPCD Policy Number 38 

Imperial County APCD Rule 217 is a permits rule. The rule directs operators to a policy 

for the mitigation measures. The policy also spells out the number of mitigation 

measures the operator must implement for each operation within the CAF. The 
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following discussion compares the mitigation measures in the Imperial County policy to 

the measures in District Rule 4570. 

4.2.2.6.1 Applicability/Exemption/Large CAF Definition 

Although the definition of large CAF is the same for both air districts, Imperial County 

Policy Number 38 only lists mitigation measures for dairy operations and beef feedlot 

operations. Imperial County APCD policy’s menu of mitigation measures is essentially 

identical to the Class One mitigation measures in District Rule 4570. Imperial County 

policy does not have a separate group of mitigation measures equivalent to the District’s 

Class Two mitigation measures to offer large CAF operators. 

4.2.2.6.2 Requirements for Dairy Large CAFs 

Feed Mitigation Measures 

District Rule 4570 has seven Class One mitigation measures for feed and three Class 

One mitigation measures for silage. There are three Class Two mitigation measures for 

silage. Operators must implement four feed mitigation measures and one silage 

mitigation measure for five total feed mitigation measures. Imperial County APCD 

policy has a menu of nine mitigation measures for feed with mitigation measures for 

silage included in the menu. Imperial County APCD policy requires the selection of 

three feed mitigation measures. Including the silage mitigation measures, this is two 

less mitigation measures than required by District Rule 4570. Therefore, District Rule 

4570 is more stringent than the Imperial County APCD policy. 

Although the dairy feed mitigation measures are identical in both air districts, the 

compliance time for the mitigation measures in the Imperial County APCD are longer 

than for those in District Rule 4570. For removal of spilled or spoiled feed the 

compliance time is 30 days for Imperial County APCD versus 14 days for the District. 

The compliance time for removing feed after a rain event is 72 hours in the Imperial 

County policy and 24 hours in District Rule 4570. For these mitigation measures, the 

District rule is more stringent. 

Milk Parlor Mitigation Measures 

Imperial County Policy has only one mitigation measure for the milk parlor. The District 

rule has one Class One and one Class Two mitigation measure, from which operators 

are required to choose at least one. 

Freestall Mitigation Measures 

District Rule 4570 has eight Class One and one Class Two mitigation measures, from 

which facilities are required to implement at least two. Imperial County APCD policy 

has eight mitigation measures, from which operators are required to choose at least 

two. 
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The Class Two mitigation measure option offered by District Rule 4570 is vacuuming 

wasted instead of scraping or flushing and injecting or incorporating into land with 72 

hours of removal.

Imperial County APCD policy has one mitigation measure that is more stringent than the 

corresponding District Rule 4570 measure. The Imperial County APCD policy requires 

freestall beds to be raked/harrowed/graded at least twice every 7 days, whereas District 

Rule 4570 requires this measure to be carried out only once every 14 days. 

Corral Mitigation Measures 

District Rule 4570 has 15 Class One mitigation measures and three Class Two 

mitigation measures, from which facilities are required to choose at least six. Imperial 

County APCD Policy Number 38 has eight mitigation measures, from which facilities are 

required to choose at least four. 

For five of the mitigation measures, the compliance times differ significantly between the 

District rule and the Imperial County APCD policy. For these measures, the Imperial 

County policy compliance times are longer than the District rule time lines. For these 

five mitigation measures, the District rule is more stringent because the District rule’s 

compliance time is much shorter for otherwise identical mitigation measures. 

Imperial County APCD policy has one mitigation measure - inspect water pipes and 

troughs and repair leaks - that is more stringent than the corresponding District Rule 

4570 measure. The policy requires that this measure to be carried out daily, whereas 

District Rule 4570 requires it to be carried out once every 14 days. 

The two air districts also differ slightly in the categorization of the mitigation measure 

relating to corrals soil additives, but this difference is not expected to have any effect on 

the stringency of the mitigation measures. 

Solid Waste and Separated Solids Mitigation Measures 

District Rule 4570 has five Class One mitigation measures and three Class Two 

mitigation measures, from which operators are required to choose at least two. Imperial 

County APCD policy has four mitigation measures from which facilities are required to 

choose at least one. Since operators must implement fewer mitigation measures under 

the Imperial County APCD policy than required by District Rule 4570, District Rule 4570 

is more stringent. 

There are a few differences in the Imperial County APCD policy mitigation measures 

themselves, when compared to District Rule 4570. Imperial County APCD policy 

requires that manure piles are covered year round whereas District Rule 4570 requires 

that the piles be covered from October through May – the months the District is most 

likely to have rainfall. Storage in anaerobic digesters or aerobic lagoons is not an option 
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for Imperial County operations. Separated solids piles not specifically addressed in the 

Imperial County policy. District Rule 4570 does not have a “no-storage” option for 

operators. These differences, although worth noting, are not expected to influence the 

effectiveness of Rule 4570. 

Liquid Waste Mitigation Measures 

District Rule 4570 has five Class One mitigation measures and five Class Two 

mitigation measures, from which facilities are required to choose at least one. Imperial 

County APCD policy has five mitigation measures, from which operators are required to 

choose at least one. The District’s Class One mitigation measures and the Imperial 

County APCD policy mitigation measures are identical. 

Land Application of Manure Mitigation Measures 

District Rule 4570 has six Class One mitigation measures, from which facilities are 

required to choose at least two. Imperial County APCD policy has a menu of five 

mitigation measures from which operators are required to choose two. Imperial County 

APCD allows the application of composted manure with a moisture content of less than 

50% as a mitigation measure. Since the material has been through a composting 

process, the District views the composted material as no longer animal manure, so the 

not-apply mitigation measure in the District rule and the application of composted 

manure in the Imperial County policy are equivalent. 

4.2.2.6.3 Requirements for Beef Feedlot Large CAFs 

Feed Mitigation Measures 

District Rule 4570 has seven Class One mitigation measures for feed and three Class 

One mitigation measures for silage. There are three Class Two mitigation measures for 

silage. Operators must implement four feed mitigation measures and one silage 

mitigation measure for five total feed mitigation measures. Imperial County APCD 

policy has a menu of eight mitigation measures for feed with mitigation measures for 

silage included in the menu. Imperial County APCD policy requires the selection of 

three feed mitigation measures. Including the silage mitigation measures, this is two 

less mitigation measures than required by District Rule 4570. Therefore, District Rule 

4570 is more stringent than the Imperial County APCD policy 

Although the feed mitigation measures are identical, the compliance time for the 

mitigation measures in the Imperial County APCD are longer than for those in District 

Rule 4570. For removal of spilled or spoiled feed the compliance time is 30 days for 

Imperial County APCD versus 14 days for the District. The compliance time for 

removing feed after a rain event is 72 hours in the Imperial County policy and 24 hours 

in District Rule 4570. For these mitigation measures, the District rule is more stringent. 
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Animal Housing Mitigation Measures 

District Rule 4570 has 14 Class One mitigation measures and two Class Two mitigation 

measures, from which operators are required to choose at least seven. Imperial County 

APCD Policy Number 38 has nine mitigation measures, from which facilities are 

required to choose at least four. Since operators in Imperial County are required to 

implement fewer mitigation measures from a menu that is essentially identical to District 

Rue 4570, District Rule 4570 is more stringent. 

For five of the mitigation measures, the compliance times differ significantly between the 

District rule and the Imperial County APCD policy. For these measures, the Imperial 

County policy compliance times are longer than the District rule time lines. For these 

five mitigation measures, the District rule is more stringent because the District rule’s 

compliance time is much shorter for otherwise identical mitigation measures. 

Imperial County APCD policy has one mitigation measure - inspect water pipes and 

troughs and repair leaks - that is more stringent than the corresponding District Rule 

4570 measure. The policy requires that this measure to be carried out daily, whereas 

District Rule 4570 requires it to be carried out once every 14 days. 

Solid Waste and Separated Solids Mitigation Measures 

District Rule 4570 has four Class One mitigation measures and four Class Two 

mitigation measures, from which facilities are required to choose at least one. Imperial 

County APCD policy has five mitigation measures from which facilities are required to 

choose at least one. 

Imperial County APCD policy requires manure piles to be covered year round whereas 

District Rule 4570 requires that the piles be covered from October through May – the 

months most likely to have rainfall. District Rule 4570 does not have a “no-storage” 

option for operators. Composting of manure on-site is a menu option offered by the 

Imperial County policy, whereas the District rule lists this as a Class Two mitigation 

measure. The differences between the two districts, although noteworthy are not 

expected to influence the effectiveness of Rule 4570. 

Liquid Manure Handling 

Imperial County APCD policy does not address liquid manure handling for beef feedlot 

operations. District Rule 4570 has a menu of options – five Class One and four Class 

Two – from which the operator must choose one mitigation measure. 

Land Application of Manure Mitigation Measures 

District Rule 4570 has six Class One mitigation measures, from which facilities are 

required to choose at least two. Imperial County APCD policy has a menu of five 

mitigation measures from which operators are required to choose two. Imperial County 
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APCD allows the application of composted manure with a moisture content of less than 

50% as a mitigation measure. Since the material has been through a composting 

process, the District views the composted material as no longer animal manure, so the 

not-apply mitigation measure in the District rule and the application of composted 

manure in the Imperial County policy are equivalent. 

4.2.2.6.4 Requirements for Other Large CAFs 

In the same manner as for dairy and beef feedlot operations, District Rule 4570 

specifies mitigation methods for large confined animal facilities other than dairies and 

beef feedlots. Imperial County APCD Policy 38 only has mitigation measures for diary 

and beef feedlot operations. In comparing the two documents, District Rule 4570 is the 

more comprehensive document. 

4.2.2.6.5 Requirements – Suspension and Substitution of Mitigation Measures 

Both rules allow for substitution of one mitigation measure with an equivalent or more 

stringent one with the submission of the appropriate application. District Rule 4570 also 

allows the temporary suspension of a mitigation measure upon the determination by a 

certified veterinarian or nutritionist that such a suspension is necessary for animal 

health purposes. The District must be notified within 48 hours, and a new measure 

must be implemented if the suspension is expected to last longer than 30 days. The 

Imperial County APCD policy does allow for temporary suspension of mitigation 

measures under circumstances similar to District Rule 4570.

4.2.2.6.6 Testing, Monitoring, Recordkeeping Requirements 

District Rule 4570 requires records to be maintained and retained for at least five years, 

whereas Imperial County AQMD Rule 217 requires records to be retained for two years. 

District Rule 4570 therefore has a more stringent record retention requirement. 

District Rule 4570 requires facilities not subject to the mitigation measure requirements 

to maintain sufficient records to demonstrate their exemption status. Facilities subject 

to the mitigation measure requirements must maintain sufficient records to demonstrate 

implementation of each mitigation measure selected. Facilities must also maintain 

animal population records. Imperial County AQMD Rule 217 requires the maintenance 

of animal population records but does not require specific records needed to 

demonstrate implementation of each mitigation measure selected. District Rule 4570 is 

therefore more stringent in the type of records required to be maintained. 

4.2.2.6.7 Conclusion – Comparison with Imperial County AQMD Rule 217 

Overall, District Rule 4570 is more comprehensive than Imperial County AQMD Rule 

217 because it covers more types of CAFS and overall, is more stringent. 
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4.2.2.7 Butte County AQMD Rule 450 – Large Confined Animal Facilities 

Butte County AQMD Rule 450 is a permits rule. It outlines, in general terms, the 

requirements for a complete permit application and how the staff would evaluate and 

approve/disapprove the permit application. 

4.2.2.7.1 Applicability/Exemption/Large CAF Definition 

The definition of large CAF is identical for both rules, with the exception of horse 

facilities. District Rule 4570 defines a large horse CAF as 3,000 head, whereas Butte 

County AQMD Rule 450 defines it as 2,500 head. Also, the Butte County AQMD rule 

specifically mentions lambs in the sheep/goat large CAF definition, whereas the District 

rule only mentions sheep and goats. 

4.2.2.7.2 Large CAF Requirements 

The Butte County AQMD rule requires large CAFs to obtain a permit and to submit and 

implement a mitigation plan; however the number of mitigation measures required and 

specific mitigation measures is not listed. Additionally the mitigation measures are to 

meet RACT. District Rule 4570 spells out the number of mitigation measures an 

operator is required to implement and has a menu of specific mitigation measures. 

Operators are required to meet BACT. In this regard, District Rule 4570 is more 

stringent than the Butte County rule. 

4.2.2.7.3 Testing, Records, and Reporting Requirements 

The Butte County rule requires that all CAFs record the daily number of animals on-site. 

These records are to be kept on-site for two years and presented if requested. District 

Rule 4570 requires testing and records be kept to demonstrate compliance with the 

operator’s selected mitigation measures. The records are to be kept for five years and 

presented upon the request of EPA, ARB, or the District. Because District Rule 4570 

covers testing, as well as having a longer record retention time, it is more stringent than 

Butte County AQMD Rule 450. 

4.2.2.7.4 Conclusion – Comparison with Butte County AQMD Rule 450 

Overall, District Rule 4570 is more comprehensive than Butte County AQMD Rule 450 

because it covers more types of CAFS and overall, is more stringent. 

4.2.3 EFFECTIVENESS OF RULE 4570 

The number of mitigation measures required for each CAF are sufficient and effective in 

obtaining the required reductions regardless of the type of mitigation measure selected. 

In cases where similar measures or control efficiency exist under a category, Rule 4570 

only allows one of those measures to be selected and account towards the total overall 
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number of mitigation measures required, eliminating the possibility that the required 

reductions are not achieved. 

The District performed an emission reduction analysis as Appendix B in the Rule 4570 

Staff report, which demonstrated that even if the least costly mitigation measures were 

selected, the facility would still manage to achieve the emission reductions needed to be 

in compliance with the Rule. The Staff Report also mentions that the least costly 

controls are also the least efficient in reducing emissions amongst all the controls. 

Since facilities’ will most likely elect to implement measures that are the least costly and 

since the analyses in appendix B demonstrates that the emission reduction 

requirements would be met by selecting the least costly measures, then it is reasonable 

to state that any combination of mitigation measures will achieve the required 

reductions. 

4.2.4 WHY ADDITIONAL MITIGATION MEASURES (CLASS ONE AND CLASS TWO) 

ARE BEYOND RACT 

Rule 4570 has two classes of mitigation measures available as options. Class One 

mitigation measures are generally management practices such as washing off manure 

more frequently, covering feed and manure piles, and manipulating animal diets. Class 

one measures have been demonstrated in the Staff Rule to meet BARCT. Class Two 

mitigation measures are more technically advanced capture and control measures such 

as enclosing animal housing and venting to a control device, storing feed and manure in 

bags or enclosed structures and venting to a control device, and using digesters or 

advanced composting methods for manure treatment. Class two measures have been 

identified as measures/technology being beyond BARCT. 

Although there is potential for some of the class two measures to achieve a significant 

amount of reductions, there exists much uncertainty as to the proper operation and 

control of these mitigation measures. Based on the most recent information on similar 

installation and/or studies, some of the measures serve to the opposite for pollution 

control and may not necessarily be superior to the Class one measures. The issues 

associated with the Class two measures are demonstrated below: 

Enclose silage in a bag and vent to a VOC control device with a combined VOC capture 

and VOC control efficiency of at least 80%. Enclose silage in a weatherproof structure 

and vent to a VOC control device with a combined VOC capture and VOC control 

efficiency of at least 80%. 

The majority of dairies store the silage piles underneath a tarp or in an Agbag. The 

entire pile is covered except for the face of the pile. The face of the pile is kept open due 

to the continual need to extract the silage for feed purposes. The silage pile is disturbed 

2-3 times per day. Because of the ongoing disturbance to these piles, it makes it 

extremely difficult to design a system to capture the emissions from these piles. In fact, 

as far as the District is aware, no system has been designed to successfully extract the 

gases from the face of the pile to capture them, and, as important, no study has 
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assessed the potential impacts on silage quality of a continuous air flow across the 

silage pile, as would be required by such a collection system. Therefore, this 

technology is not only unproven but the ramifications of installing such a system are yet 

unknown. 

Enclose and vent the milk parlor to a VOC control device with an overall VOC capture 

and VOC control efficiency of at least 80% when animals are in the parlor.

Currently, there is no dairy as far as the District is aware of that has a fully enclosed 

milking parlor system. The milking parlor consists of an attached cow holding area, 

which temporarily holds the cows as they make their way into the milk parlor. This area 

is generally fully exposed with a partial cover. In order to capture all of the gases 

emitted from the milking parlor, and to keep an appropriate negative pressure 

throughout the system, the holding area would also need to be entirely enclosed. The 

capital required to enclose this large area would also be significant. In addition, the 

milking parlor has the least amount of emissions at the entire dairy. Even if such a 

system could be fully enclosed, a great deal of energy would be required to circulate the 

air and vent the gases into a control device. 

This technology is still unproven and may pan out to be ineffective due to the minor 

source of emissions. In addition, fully enclosing animals has the potential of causing a 

great deal of stress and negative health impacts to the animals, which have yet to be 

evaluated. Therefore, this technology may not only be feasible but may prove to be 

less superior to other mitigation measures. 

House animals in an enclosure vented to a VOC control device with a combined VOC 

capture and VOC control efficiency of at least 80%.

Although there are smaller dairy farms that have partially enclosed freestall barns, these 

barns are not fully enclosed and none of the barns have been found to vent the exhaust 

through a collection device. These partially enclosed barns are also found in the 

Midwest where the temperature is much cooler than the Valley. Freestall barns are 

large structures and the airflow requirements through these barns are also extremely 

high, primarily for herd health purposes (for cooling the cow). The airflow requirements 

will be even higher in the San Joaquin valley, where temperatures reach in excess of 

110 degrees in the hot summer. Milk cows have a very low threshold for heat stress, 

which can occur at temperatures of greater than 70 degree F. Therefore, one of the 

most critical factors in realizing a completely enclosed barn will be to provide sufficient 

amount of cooling so as not to cause a detriment to herd health. In addition, collection 

and control of the exhaust including the large amounts of airflow have not yet been 

achieved by any facility. Due to these difficulties and the lack of any installations of this 

type of technology, it is difficult to say at this time whether this technology is considered 

feasible. 
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Cover the lagoon or storage pond and vent to a VOC control device with an overall VOC 

capture and VOC control efficiency of at least 80%.

The covering of a lagoon in itself has been achieved in many facilities; however the 

control of the biogas poses some air quality challenges. There is a negative impact of 

emissions of other pollutants resulting from the combustion of biogas generated by 

anaerobic digestion. These pollutants include oxides of nitrogen (NOX), sulfur oxides 

(SOX), particulate matter (PM10 and PM2.5), and carbon monoxide (CO). Current air 

quality modeling has demonstrated that the high levels of biogenic and anthropogenic 

VOC emissions in the San Joaquin Valley Air Basin cause NOX to be the limiting 

reactant for ozone production. Therefore, in terms of ozone production, large 

reductions in VOC emissions can be offset by relatively smaller increases in NOX

emissions. This factor must be considered when determining if anaerobic digesters will 

reduce ozone formation in the San Joaquin Valley Air Basin. Furthermore, several 

recent studies have demonstrated that particulate matter, especially fine particulate 

(PM2.5) such as that produced by combustion, can pose a significant health risk. Since 

VOC emissions from waste storage lagoons are lower than previously thought, it is very 

likely that emissions of combustion contaminants (NOX, SOX, PM10, PM2.5, CO), 

including precursors for the formation ozone and fine particulate, will offset the benefits 

of any VOC reductions from the lagoons. 

In addition, although there are several digesters in operation at agricultural facilities, 

particularly dairies, only one installation in the District is equipped with advanced 

emission controls to reduce NOX. This installation has faced considerable difficulty in 

meeting the very strict NOX requirements that are needed in order for digesters to have 

an overall positive affect on air quality. The installation has had a variance for more 

than six months and will require even more time because of the inability to meet the 

NOX emission limit in the permit. Other installations are currently uncontrolled and have 

some of the highest levels of NOX from stationary equipment in the District resulting in 

an overall increase in ozone-forming potential in the San Joaquin Valley. 

In conclusion, anaerobic digesters with no or limited controls for combustion pollutants 

are not beneficial to the protection of air quality in the San Joaquin Valley unless 

significantly controlled. Although technologies for use of biogas with low NOX emissions 

(such as fuel cells) are being developed, these technologies are rarely used and the 

expense of such technologies is clearly far above the level of RACT including BARCT. 

These technologies have even yet to be considered Achieved in Practice as part of the 

District’s BACT analysis. 

While engineered controls are available and included as options in the rule, not only are 

some of them not functional or economically feasible, they are beyond BARCT and 

RACT. 
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4.3 RULE 4570 IS LEGALLY AND PRACTICALLY ENFORCEABLE 

Pursuant to Rule 4570 Section 7.1.1.2 , owners/operators subject to the requirements of 

Rule 4570 (section 5.0) shall maintain the following: 

• Copies of all of the facility's permits 

• Copies of all laboratory tests, calculations, logs, records, and other information 

required to demonstrate compliance with all applicable requirements of this rule, 

as determined by the APCO, ARB, EPA. 

• Records of the number of animals of each species and production group at the 

facility on the permit issuance date. Quarterly records of any changes to this 

information shall also be maintained, (e.g. Dairy Herd Improvement Association 

records, animal inventories done for financial purposes, etc.) 

Sections 7.1.1.2.4 through 7.1.12.21 require specific record keeping conditions for each 

mitigation measure. 

Section 7.2 requires specific monitoring or source testing conditions for each mitigation 

measure. 

Because permit rules and prohibitory rules have different purposes, they are not directly 

comparable in terms of monitoring, testing, and records. Prohibitory rules include these 

requirements so that the operator can demonstrate compliance with the rule’s control 

requirements. In a permit rule, it is expected that required monitoring, testing, and 

records would be outlined in a prohibitory rule applicable to the source category. 

All rules except District Rule 4570 and SacMetro Rule 459 are permit rules. These 

rules have one records provision - all CAF operators must keep records of the number 

of animals at the facility. By contrast, the SacMetro and District rules, which are 

prohibitory rules, outline specific records for each type of mitigation measure performed 

in addition to the number-of-animals provision. This means the SacMetro and District 

rules are more stringent than the other air districts’ rules, but that is to be expected 

given the difference in the types of rules being compared (permit versus prohibitory). 

The monitoring and measurement requirements of Rule 4570, which include minimum 

testing frequency, are designed to ensure that adequate testing is conducted to 

demonstrate compliance with the appropriate mitigation measures and such measures 

are operating in a manner that optimizes the VOC reductions. 

It should also be noted that owners may use documents, such as Regional Water 

Quality Board Waste Nutrient Management Plans that list the numbers of animals in 

each production group (e.g. calves, heifers, milkers, and dry cows) to comply with this 

monitoring requirement. The rule will not require owners/operators to maintain a set of 

records exclusively for the use of the San Joaquin Valley Air District. Other monitoring 

and testing requirements only apply to facilities that choose mitigation measures where 

such monitoring or testing would assist in demonstrating compliance. 
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4.4 EMISSION REDUCTIONS ACHIEVED BY RULE 4570 MEET DISTRICT 

PLANNING REQUIREMENTS 

Although some of the individual mitigation measures in District Rule 4570 were in use 

before Rule 4570 was adopted, there would be no requirement to keep emissionreducing measures in place if District Rule 4570 did not exist. Rule 4570 requires that 

large CAF operators put together a suite of mitigation measures into a mitigation plan 

which would reduce VOC emissions for every process within the CAF. This provides 

operators flexibility to reduce emissions in the most effective way for their facility while 

assuring that VOC emissions from all processes within the facility are controlled. Within 

the confines of Rule 4570, operators can change their mitigation measures through 

mitigation plan updates. The new mitigation measures could not be put in place until 

approved by the District. In this way, the mitigation plan to become a “living document” 

that allows the operators and the District to implement the best controls as operations 

change and scientific knowledge increases. The following paragraphs review the 

absolute emission control effectiveness of Rule 4570 in terms of facility mitigation plans 

rather than individual mitigation plans. 

According to USDA records, over 59% of California’s cattle and 80% of the state's swine 

population are raised in the San Joaquin Valley Air Basin (SJVAB). Approximately 42% 

of these animals are raised in facilities defined as "large CAF". In contrast, the majority 

of poultry, goats, sheep, and other animals are raised in facilities below the "large CAF" 

definition. Therefore, poultry, goats, sheep and other animals are not subject to the 

control requirements of the rule and no emission control effectiveness was calculated 

for these CAFs. 

In determining the emission control effectiveness, District staff assumed that operators 

would choose to implement the lowest cost mitigation measures. Also assumed was 

control effectiveness of 10% for mitigation measures that did not have peer-reviewed 

research associated with them. With both of these assumptions, District staff calculated 

the control efficiency for each operation within a given type of CAF, then the overall 

control effectiveness for the given type of CAF was determined. The results of that 

analysis are shown in the table below. 

Estimated Overall Control Efficiency by CAF Type (after full implementation) 

Type of CAF Dairy Beef Other Cattle Swine All Others 

Percent Control 36% 36% 42% 72% Not affected by 

rule 

Taken as a whole, there are significant emission reductions associated with District 

Rule 4570 compared to uncontrolled operations, even with conservative control 

efficiencies assumed for individual mitigation measures. The calculated overall control 

efficiency range is 36% to 72% with large swine CAFs having the highest overall VOC 

control efficiency. 
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4.4.2 Least Costly Mitigation Measure Requirements are Effective 

The number of mitigation measure required for each CAF are sufficient and effective in 

obtaining the required reductions regardless of the mitigation measure selected. In 

several cases, Rule 4570 only allows one of multiple measures under a category to be 

selected that go towards the total overall number required due to similar control 

efficiencies or similarity in the type of mitigation. The analysis shown below and also 

included in Appendix B of Rule 4570 Staff report, demonstrates that even if the least 

costly mitigation measures are selected, the facility would still manage to get the 

emission reductions needed and be in compliance with the Rule. The Staff Report also 

mentions that the least costly controls are also the least efficient in reducing emissions 

amongst all the controls. Since facilities’ will most likely elect to implement measures 

that are the least costly and since the analyses in appendix B of Rule 4570 staff report 

demonstrates that the emission reduction requirements would be met by selecting the 

least costly measures, then it is reasonable to state that any combination of mitigation 

measures will achieve the required reductions. In addition, since the mitigation 

measures in Rule 4570 meet BARCT, then these measures also meet RACT. 

4.4.2.1 EMISSION REDUCTION ANALYSIS 

4.4.2.1.1 Background 

In performing the analysis, several generalizations were made to reflect conservative 

emission reduction results. These include: 

• All mitigation measures achieve VOC reductions from facilities that use the 

mitigation measures. The rule achieves reductions by requiring the mitigation 

measure or by prohibiting the owner/operator from ceasing to use the mitigation 

measure. 

• Facilities will only implement the number of mitigation measures required by 

Proposed Rule 4570. Staff acknowledges that industry may do more than is 

required. Since the additional mitigation measures that industry implements that 

go beyond rule requirements can be ceased at any time, thus staff does not 

believe these reductions are permanent and the direct result of Rule 4570. 

Therefore, staff does not believe that it is appropriate to claim such reduction or 

costs in the Rule 4570 development process. 

• Facilities will choose the mitigation measures that are lowest cost BARCT 

options. Again, staff acknowledges that facilities may choose more costly 

options. Additionally many existing facilities already have installed more costly 

options, which are more effective at reducing VOC emissions. However, as 

mentioned in the previous bullet owner/operators could cease using the more 

costly option at anytime, thus staff does not believe that it is appropriate to claim 

reduction achieved in cases where the more costly option achieves greater 

reductions than the less costly option. 

• In some cases, no data could be found in the literature search on which to base a 

control efficiency factor for these practices. The District has conservatively 

assumed a minimal 10% control effectiveness. As information becomes 
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available, it will be added to this methodology. Additional air quality benefits and 

control effectiveness for these practices would need to be further evaluated 

through research studies and literature searches. 

• Emissions at each source are affected by emission reductions achieved from 

sources upstream of that source. For example, a mitigation measure for feed 

that reduces VOC in manure by 10% causes the emission factor for the lagoon, 

where the manure is processed, to have 10% less emissions. 

• Approximately 29% percent of the dairies have no freestalls, based on California 

Dairy Farmers Association (CDFA) data provided by Mike Francesconi. 

 

4.4.2.1.2 Excluded Activities and Facilities 

Based on the assumptions above, staff analyzed the cost effectiveness of least 

expensive BARCT options that owners/operators would likely choose to implement. 

4.4.2.1.3 Summary of Emissions and Reductions 

Tables 3 through 7 summarize the emission reduction calculations from the control 

measures included in the rule. Details of those calculations are discussed in Sections D 

through G.

4.4.2.1.4 Control Efficiency Calculations for Dairies 

The calculations for dairies are based on the following breakdown of the emission factor 

by source category. 

Emissions from Dairy Locations

Emission 

Unit 

Emission 

Factors 

(Freestall Dairies)

Emission Factors 

(Dairies without Freestalls)

Reference 

Manure & Feed 

in Housing 5.5 lb/hd-yr 4.8 lb/hd-yr 12/14/05 Draft Breakdown for Permitting 

Enteric 

Emissions in 

Housing 

7.6 lb/hd-yr 7.6 lb/hd-yr 12/14/05 Draft Breakdown for 

Permitting 

Enteric 

Emissions in 

Milking Center 

0.7 lb/hd-yr 0.7 lb/hd-yr 12/14/05 Draft Breakdown for 

Permitting 

Manure 

Emissions in 

Milking Center 

0.2 lb/hd-yr 0.2 lb/hd-yr 12/14/05 Draft Breakdown for 

Permitting 

Liquid Manure 

Handling 2.7 lb/hd-yr 2.3 lb/hd-yr 12/14/05 Draft Breakdown for Permitting 

Land 

Application 5.0 lb/hd-yr 3.7 lb/hd-yr 12/14/05 Draft Breakdown for Permitting 

SUBTOTAL 21.7 lb/hd/y 19.3 lb/hd-yr 

Value used for permitting 

purposes and emission 

inventory calculations 
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Solid Bedding 

Storage Piles 0.2 lb/hd-yr 0.2 lb/hd-yr 1/26/05 Schmidt Flux Chamber Presentation for ARB Meeting 

Feed Piles 0.63 lb/hd-yr 0.63 lb/hd-yr 

Data submitted to DPAG by 

Schmidt via ARB. NOTE: this 

only considered feed in 

feedlanes. It did not include 

emissions from every feed 

emission source. 

Please note that the values in the above table for: manure & feed in housing; enteric 

emissions in housing; enteric emissions in milking center; manure emissions in milking 

center; liquid manure handling; and land application subtotal to the current emission 

factors for permitting purposes. Since these values are used for permitting, these (21.7 

lb/hd-yr and 19.3 lb/hd-yr) were used in all calculations which applied to the entire 

facility to avoid overestimating emissions and emission reductions and maintain 

consistency. 

However, the Dairy Permitting Advisory Committee and APCO reports and the permit 

department noted that not all emission sources were included in these estimates. Two 

sources for which emissions were not counted are the solid bedding storage piles and 

the feed piles outside of the animal housing. Since there is research documenting 

emission from and VOC control options for these sources, staff estimated the emissions 

from these sources by using data from Schmidt's research. These emission factors are 

only used for calculating reductions from mitigation measures that control VOC 

emissions from solid bedding or feed storage piles. 

Based on Table 8 and the CDFA data showing that approximately 29% of dairies have 

no freestalls, staff calculated the weighted averages for emissions for each area on the 

dairy and the facilities as a whole by the following equation: 

Weighted average = Emission factor for facilities with freestalls x 71% + Emission factor 

for facilities with no freestalls x 29% 

The weighted averages, which staff used to calculate control efficiency of various 

control measures, are listed below. 

Weighted Emissions from Dairy Locations

Emission Unit 

Emission 

Factors 

(Freestall Dairies)

Emission Factors 

(Dairies without Freestalls)

Weighted Emission 

Factors 

Manure & Feed in 

Housing 5.5 lb/hd-yr 4.8 lb/hd-yr 5.3 lb/hd-yr 

Enteric Emissions 

in Housing 7.6 lb/hd-yr 7.6 lb/hd-yr 7.6 lb/hd-yr 

Enteric Emissions 

in Milking Center 0.7 lb/hd-yr 0.7 lb/hd-yr 0.7 lb/hd-yr 

Manure Emissions 

in Milking Center 0.2 lb/hd-yr 0.2 lb/hd-yr 0.2 lb/hd-yr 
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Liquid Manure 

Handling 2.7 lb/hd-yr 2.3 lb/hd-yr 2.6 lb/hd-yr 

Land Application 5.0 lb/hd-yr 3.7 lb/hd-yr 4.6 lb/hd-yr 

SUBTOTAL 21.7 lb/hd/y 19.3 lb/hd-yr 21.0 lb/hd-yr 

Solid Bedding 

Storage Piles 0.2 lb/hd-yr 0.2 lb/hd-yr 0.2 lb/hd-yr 

Feed 0.63 lb/hd-yr 0.63 lb/hd-yr 0.63 lb/hd-yr 

1. FEED PRACTICES CONTROL MEASURES 

Option 1: Feeding according to NRC guidelines

This practice is intended to minimize the excess nutrients fed to the animals. Based 

on research suggesting that nitrogen content in feed is directly proportional to 

nitrogen content in manure, staff believes that feeding according to the NRC 

guidelines, which minimizes excess nutrients in the diet, would reduce VOC 

emissions. Since there is little data quantifying this reduction, the 10% default is 

assumed. Since it reduces the content of VOC precursors being fed to the animal 

(entering the animal) it will reduce the VOC precursors exiting the animal and thus 

being treated in each animal waste system. It will also reduce the emissions from 

feed in the housing and stockpiles because there will be less VOC precursors in the 

feed, which could eventually decompose. Therefore, the 10% reduction was applied 

to the facility wide emission factors. This is expected to be used by all facilities since 

reductions in excess nutrients, such as protein, in feed would not increase costs 

significantly. Any additionally labor employed to determine what feed formulations 

would meet NRC guidelines would likely be offset by lower costs for feed due to 

lower nutrient content. The reduction calculations are: 

Option 1 Reductions = 10% 

Option 2: Store grain in a weatherproof storage structure from October through May

This measure is intended to reduce excess moisture. Since the microorganisms that 

degrade organic material to form VOCs require moisture, this is expected to reduce 

the VOC emissions from the feed storage. Since there is little data quantifying this 

reduction, the 10% default is assumed. However, it only affects the emissions from 

feed and these emissions were already reduced by 10% due to implementing an 

NRCS diet. The reduction calculations are: 

Option 2 Reductions = 0.63 lb/hd-yr (emissions from feed) x 90% (emissions 

remaining after implementing Option 1) x 10% (control efficiency from Option 2) = 

0.06 lb/hd-yr 

This is out of an emission factor of 21.0 lb/hd-yr. 
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The percent reductions = 0.06 lb/hd-yr ÷ 21.0 lb/hd-yr = 0.3% 

Option 3 and 4: Two mitigation measures for cleaning feed from housing

These measures are intended to minimize moisture, surface area for VOCs to move 

from the feed to the atmosphere, and anaerobic digestion due to wet conditions and 

thick depths of animal waste. Data suggests that these practices would minimize 

VOC emissions, however there are no peer-reviewed articles that quantify this. 

Therefore, staff assumed a default reduction of 10% for each measure. However, it 

only affects the emissions from feed and these emissions were already reduced by 

Option 1 and Option 2. 

Option 3 Reductions = 0.63 lb/hd-yr (emissions from feed) x 90% (emissions 

remaining after implementing Option 1) x 90% (emissions remaining after 

implementing Option 2) x 10% (control efficiency) = 0.05 lb/hd-yr 

Option 4 Reductions = 0.63 lb/hd-yr (emissions from feed) x 90% (emissions 

remaining after implementing Option 1) x 90% (emissions remaining after 

implementing Option 2) x 90% (emissions remaining after implementing Option 3) x 

10% (control efficiency) = 0.05 lb/hd-yr 

The total reductions from Option 3 and 4= 0.05 lb/hd-yr (Option 3) + 0.05 lb/hd-yr 

(Option 4) = 0.10 lb/hd-yr 

This is out of an emission factor of 21.0 lb/hd-yr. 

The percent reductions = 0.10 lb/hd-yr ÷ 21.0 lb/hd-yr = 0.5% 

2. SILAGE PRACTICES 

Option 5: Silage practices

These measures are intended to minimize moisture, surface area for VOCs to move 

from the feed to the atmosphere, anaerobic digestion due to wet conditions, and 

excess nutrients in animal waste due to silage practices. Data suggests that these 

practices would minimize VOC emissions, however there are no peer-reviewed 

articles that quantify this. Therefore, staff assumed a conservative reduction of 10% 

for each measure. However, it only affects the emissions from feed and these 

emissions were already reduced by Option 1. 

Option 5 Reductions = 0.63 lb/hd-yr (emissions from feed) x 90% (emissions 

remaining after implementing Option 1) x 10% (control efficiency) = 0.06 lb/hd-yr 

This is out of an emission factor of 21.0 lb/hd-yr. 
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The percent reductions = 0.06 lb/hd-yr ÷ 21.0 lb/hd-yr = 0.3% 

3. MILK PARLOR PRACTICES 

Option 6: Flush/clean milk parlor after each milking

In the studies used to calculate the emission factor this practice was being done. 

Therefore, the baseline assumes that all facilities implement this practice. Thus, no 

reduction from the baseline is anticipated. This measure was included to ensure all 

current and future facilities implement practices accounted for in the baseline 

emission estimate. 

4. FREESTALL PRACTICES 

Options 7 and 8: Vacuum or scrape freestalls after each milking or flush more 

frequently than milking and rake, harrow, scrape, or grade bedding at least once 

every two weeks

Typically, facilities flush once per milking or scrape once a day (once every two 

milkings). Typically, facilities clean to bedding no more than once a month. By 

cleaning twice as frequently you cut the time manure is in the freestalls by half. 

Therefore you reduce the emissions is the freestalls by 50%. The freestall emissions 

are approximately 97% of the total emissions from manure and feed in the housing 

(3% of the emissions are in the corrals). The reduction calculations are: 

Freestall emission = 5.3 lb/hd-yr x 97% (emissions from freestalls) 

 = 5.14 lb/hd-yr from freestalls. 

Options 7 and 8 Reductions = 5.14 x 90% (emissions remaining after implementing 

Option 1) x 98% (emissions remaining after implementing Option 3 and 4) x 50% 

(control efficiency)= 2.3 lb/hd-yr 

This is out of an emission factor of 21.7 lb/hd-yr, but only affects 71% of the facilities 

(facilities with freestalls). 

The percent reductions = 2.3 lb/hd-yr ÷ 21.7 lb/hd-yr x 71% = 8%

5. CORRAL PRACTICES 

Option 9, 10, 11, 12, 13, and 14: All housing measures to clean corals, manage 

manure depth, and minimize moisture

These are intended to minimize moisture and anaerobic digestion due to wet 

conditions or thick depths of manure that prevents the manure from drying 

completely and oxygen continuing to come in contact with all animal waste in the 
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pens and corrals. Data suggests that this would minimize VOC emissions, however 

there are no peer-reviewed articles that quantify this. Therefore, staff assumed a 

default reduction of 10% for each measure. The corrals account for approximately 

3% of the emissions from the animal housing. The reduction per measure is: 

Corral emissions = 5.3 lb/hd-yr x 3% (emissions from corrals) 

 =0.16 lb/hd-yr from corrals 

Option 9 Reductions = 0.16 x 90% (emissions remaining after implementing Option 

1) x 10% (control efficiency)= 0.01 lb/hd-yr 

Option 10 Reductions = 0.16 x 90% (emissions remaining after implementing Option 

1) x 90% (emissions remaining after implementing Option 9) x 10% (control 

efficiency)= 0.01 lb/hd-yr 

Option 11 Reductions = 0.16 x 90% (emissions remaining after implementing Option 

1) x 90% (emissions remaining after implementing Option 9) x 90% (emissions 

remaining after implementing Option 10) x 10% (control efficiency)= 0.01 lb/hd-yr 

Option 12 Reductions = 0.16 x 90% (emissions remaining after implementing Option 

1) x 90% (emissions remaining after implementing Option 9) x 90% (emissions 

remaining after implementing Option 10) x 90% (emissions remaining after 

implementing Option 11) x 10% (control efficiency)= 0.01 lb/hd-yr 

Option 13 Reductions = 0.16 x 90% (emissions remaining after implementing Option 

1) x 90% (emissions remaining after implementing Option 9) x 90% (emissions 

remaining after implementing Option 10) x 90% (emissions remaining after 

implementing Option 11) x 90% (emissions remaining after implementing Option 12) 

x 10% (control efficiency)= 0.01 lb/hd-yr 

Option 14 Reductions= 0.16 x 90% (emissions remaining after implementing Option 

1) x 90% (emissions remaining after implementing Option 9) x 90% (emissions 

remaining after implementing Option 10) x 90% (emissions remaining after 

implementing Option 11) x 90% (emissions remaining after implementing Option 12) 

x 90% (emissions remaining after implementing Option 13) x 10% (control 

efficiency)= 0.01 lb/hd-yr 

Options 9 through 14 Reduction = 0.01 lb/hd-yr (Option 9) + 0.01 lb/hd-yr (Option 10) 

+ 0.01 lb/hd-yr (Option 11) + 0.01 lb/hd-yr (Option 12) + 0.01 lb/hd-yr (Option 13) + 

0.01 lb/hd-yr (Option 14) = 0.06 lb/hd-yr 

This is out of an emission factor of 21.0 lb/hd-yr. 

The percent reductions = 0.06 lb/hd-yr ÷ 21.0 lb/hd-yr = 0.3% 
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6. SOLID MANURE/SEPARATED SOLIDS PRACTICES 

Options 15 and 16: Cover piles outside the pens 

These measures are intended to minimize moisture and anaerobic digestion due to 

wet conditions. There is no data regarding the amount of emissions from the 

manure storage piles, therefore staff conservatively estimated the separated solids 

and the manure piles emit approximately the same amount of VOC. Since there is 

little data regarding reductions staff assumed a default reduction of 10% for each 

mitigation measure. The reduction per measure is: 

Option 16 Reductions = 0.2 lb/hd-yr (piles) x 90% (emissions remaining after 

implementing Option 1) x 10% = 0.02 lb/hd-yr reductions. 

Option 17 Reductions = 0.2 lb/hd-yr (piles) x 90% (emissions remaining after 

implementing Option 1) x 10% = 0.02 lb/hd-yr reductions. 

Option 16 and 17 Reductions = 0.02 lb/hd-yr + 0.02 lb/hd-yr = 0.04 lb/hd-yr 

This is out of an emission factor of 21.0 lb/hd-yr. 

The percent reductions = 0.04 lb/hd-yr ÷ 21.0 lb/hd-yr = 0.2% 

7. LIQUID MANURE PRACTICES 

Option 17: All of the lagoon control options

AEM, 3/03, Vol 69, pg 1710-1720, indicates a 80-93% decrease in emissions from 

swine phototrophic lagoons; ILOC, 1995, pg 80-85, DiSpirito, found the same in 

swine lagoons; and JFB, 70:39-44, Hiraishi, found the same in sewage wastewater 

lagoons. The loading rate contributing to a phototrophic are typically found in 

lagoons utilizing a solid separator, NRCS guidelines for anaerobic lagoon design, 

and microaerobic nutrient management. However, these studies were for swine and 

not cattle. Based on AP42 by EPA, swine emit 63.5% of the volatile solids that cattle 

do. Therefore, in order to be conservative, staff assumed that cattle lagoons are 

63.5% as efficient as swine lagoons (63.5% x 80% = 50%). The baseline is 2.3 

lb/hr/yr, however there are fewer emissions due to the use of the NRC feed 

guidelines. The reduction per measure is: 

Option 17 Reductions = 2.6 lb/hd-yr x 90% (emissions remaining after implementing 

Option 1) x 50% (control efficiency) = 1.17 lb/hd-yr 

This is out of a total emission factor of 21.0 lb/hd-yr. 

The percent reductions = is 1.17 lb/hd-yr ÷21.0 lb/hd-yr = 6%. 
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8. LAND APPLICATION PRACTICES 

Option 18 & 19: All methods for crop application.

These practices are intended to rapidly land incorporate the manure or waste water. 

The soil is expected to act as a biofilter since it is an organic media with significant 

microbial populations and airflow. Research suggests biofilters range in efficiency 

from 10% to 90% depending on how they are maintained. Conservatively staff 

assumed 50% control. The baseline emissions from crop application are 4.6 lb/hdyr. The reduction per measure is: 

Options 18 & 19 Reductions = 4.6 lb/hd/year x 90% (emissions remaining after 

implementing Option 1) x 50% (control efficiency) = 2.07 lb/hd-yr 

This is out of a total emission factor of 21.0 lb/hd-yr. 

The percent reductions = is 2.07 lb/hd-yr ÷21.0 lb/hd-yr = 10%. 

9. TOTAL REDUCTIONS 

The total percent reductions can be calculated by summing the percent reductions 

for each mitigation measure above. 

Total Reductions = 36% 

As shown in the analysis above, the least costly mitigation measures and the most likely 

to be selected by facilities, achieves a significant amount of emission reductions, far 

greater than the 25% reductions required by Rule 4570. Since, Rule 4570 meets 

BARCT, and since BARCT is more stringent than RACT, then Rule 4570 also meets the 

definition of RACT. 

5 CONCLUSION AND FUTURE PLANS 

In determining whether District Rule 4570 meets RACT, the analysis has considered 

federal rules that cover large CAFs as well as rules in other California air districts. It 

can be concluded that District Rule 4570 exceeds RACT for the following reasons: 

• There are no federal rules that apply to this category; therefore federal rules 

(CTG, NSPS. NESHAP) do not infer RACT for large CAFs. 

• No rule has been approved into the California SIP for this source category, so 

there is no precedent that outlines RACT. 

• SB 700 required California air districts with certain non-attainment status to 

implement BARCT. District Rule 4570 was designed to satisfy SB 700 and as a 

consequence, implements BARCT for large CAFs within the Valley. BARCT is a 

level of control that is considered more stringent than RACT. 
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• The mitigation measures outlined in Rule 4570 have been required as Best 

Available Control Technology (BACT) for new and modifying sources that trigger 

the BACT threshold. 

• The Rule achieves a significant level of control even if the least costly measures 

are selected by the source. 

• Rule 4570 requires mitigation measures for all large Confined Animal Facilities 

and for all major sources of emissions from a facility. 

• A comparison of other California air district rules to District Rule 4570 shows that 

Rule 4570 is as stringent as rules in some air districts and is more stringent than 

rules in certain other air districts. No California air district rule is overall more 

stringent than District Rule 4570 for this source category. 

Although District Rule 4570 is more stringent than RACT for large CAFs, District staff is 

pursuing additional emission reductions from CAFs in an upcoming rule project. 

Reducing VOC emissions from CAFs is a strategic control measure in the District’s 

ozone attainment plan. The amendments to Rule 4570 will seek to obtain as much 

reduction of volatile organic compounds (VOCs) from CAFs as expeditiously 

practicable, technologically feasible, and economically reasonable, as determined by 

the District’s Governing Board. The District’s attainment plan anticipates an additional 

30% reduction in VOCs by 2014 as a result of the rule amendments. These additional 

controls will effectively move Rule 4570 even further beyond RACt in terms of 

applicability and stringency. 
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Rule 4601 – Architectural Coatings 

Emissions Inventory

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

VOC 9.1 9.4 9.6 9.7 10.2 10.5 10.9 11.2 

(Source: District 2007 Ozone Plan) 

District Rule 4601 Description

This rule is applicable to any person who supplies, sells, offers for sale, applies, or 

solicits the application of any architectural coating, or who manufactures any 

architectural coating for use within the District. District Rule 4601 specifies VOC coating 

limits from the state’s (ARB’s) 2000 Suggested Control Measure (SCM). 

How does District Rule 4601 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

There is no CTG for this source category. 

B. EPA – Alternative Control Technology (ACT) 

There is no ACT for this source category. 

C. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS for this source category. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There is no NESHAP or MACT for this source category. 

How does District Rule 4601 compare to rules in other air districts?

District staff compared VOC limits, optional control requirements, and work practice 

standards in District Rule 4601 to comparable requirements in rules from the following 

California nonattainment areas: 

• South Coast AQMD Rule 1113, as amended July 2007 
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• Bay Area AQMD Regulation 8 Rule 3, as amended November 2001 

• Ventura County APCD Rule 74.2 , as amended November 2001 

• Sacramento Metro AQMD Rule 442, as amended May 2001 

A. South Coast AQMD Rule 1113 

SCAQMD has introduced new coating limits that are more stringent than the state’s 

2000 SCM. As a result, coatings that meet these new limits have been introduced in 

the South Coast area beginning in 2005. The new limits were phased-in over three 

years, with the final phase effective in July 2008. 

District Rule 4601 is undergoing rule development process to incorporate South Coast 

limits for architectural coatings. Amendments are expected to be adopted in the fourth 

quarter of 2009. 

B. Bay Area AQMD Regulation 8 Rule 3; Ventura County APCD Rule 74.2, 

Sacramento Metropolitan AQMD Rule 442 

These air districts adopted ARB’s 2000 SCM for architectural coatings. Rule 4601 used 

the same SCM as a template and, therefore, is currently at the same level of stringency 

as these air district rules. District Rule 4601 is undergoing rule development process to 

incorporate South Coast’s limits for this source category. Rule 4601 amendments are 

expected to be adopted in the fourth quarter of 2009. 

Conclusion

After careful evaluation of prohibitory rules in other California nonattainment areas, 

District staff concludes that District Rule 4601 satisfies RACT for architectural coatings. 
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Rule 4603 – Surface Coating of Metal Parts and Products 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 0 0 0 0 0 0 0 0 

VOC 0.57 0.60 0.66 0.68 0.76 0.81 0.86 0.88 

(Source: District 2007 Ozone Plan) 

District Rule 4603 Description

District Rule 4603, recently amended on October 16, 2008, controls VOC emissions 

from miscellaneous metal part and products, including large appliances and metal 

furniture. The rule also controls emissions organic solvent cleaning, storage and 

disposal of solvents, and waste solvent materials associated with such coating 

operations. Rule 4603 establishes VOC content limits for coatings used in the 

manufacture and fabrication of metal parts and products as well as separate VOC limits 

for coatings used in large appliances and metal furniture. Except for large appliances or 

metal furniture, the general VOC limits for baked coatings and for air-dried coatings is 

275 grams per liter and 340 grams/liter, respectively. Except for large appliances or 

metal furniture coating operations, the VOC limits for specialty coatings (except for) 

ranging from 360 grams/liter to 880 grams/liter for baked coatings and 420 to 880 for 

air-dried coatings, depending on the category of coating. Specialty coating category 

includes camouflage, extreme performance, heat resistant, high gloss, high 

performance architectural, high temperature, metallic topcoat, pretreatment primer, 

silicone release, solar absorbent, and solid film lubricant. For large appliances or metal 

furniture coating operations the coating VOC limits range from 275 grams/liter to 420 

grams/liter depending on the type of coating and whether baked or air-dried. The VOC 

content limit for organic solvent cleaning materials is 25 grams/liter. 

In lieu of using compliant coatings and solvents, District Rule 4603 allows the use of an 

APCO-approved VOC emission control system with an overall capture and control 

efficiency of at least 90 percent by weight. Also, the rule includes coating application 

methods, work practice standards, recordkeeping, and test methods. 

District Rule 4603 exempts some source operations from certain requirements of the 

rule. It exempts facilities use a total of 55 gallons or less of non-compliant coatings per 

rolling consecutive 365-day period. Also exempt are sources that are regulated by 

other District’s coating rules such as Rule 4661 (Organic Solvents), Rule 4602 (Motor 

vehicle and Mobile Equipment Coating Operations), Rule 4612 (Motor Vehicle and 

Mobile Equipment Operations Phase II), and Rule 4605 (Aerospace Assembly and 

Component Manufacturing Operations) Rule 4604 (Can and Coil Coating Operations). 

Touch-up and repair, polyester resin operations and the application of polyester resin to 

metal parts and products are exempt from District 4603. Some solvent cleaning 
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operations are also exempt (e.g., cleaning solar cells, lasers, high precision optics, 

laboratory tests, analyses or bench scale/research projects, paper-based gasket, etc.). 

How does District Rule 4603 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

1. CTG for Large Appliance Coatings (EPA 453/R-07-004), September 2007 

The 2007 CTG for large appliance coatings mentioned that EPA published in December 

1977 a CTG for this same category, entitled Control of Volatile Organic Emissions from 

Existing Stationary Sources, Volume V: Surface Coating of Large Appliances OC 

Emissions (EPA-450/2-77-034). The 1977 CTG coating VOC limit is 2.8 lb/gallon for 

prime, single or topcoat application area, flashoff area and oven. The 2007 CTG limits 

for general, one component coating of 2.3 lb/gallon (air-dried or baked) is more stringent 

than the 1977 CTG VOC limit of 2.8 lb/gal. Also, the 1977 CTG specified only three 

coating categories whereas 2007 CTG has eight different categories. For this reason, 

District staff placed more emphasis in evaluating the more current emission standards 

of the 2007 CTG as RACT instead of the 1977 CTG. 

The 2007 CTG applies to large appliance parts and products coating operations whose 

VOC emissions, before consideration of controls, are equal to or greater than 15 lb/day. 

The CTG allows an alternative applicability trigger level of 3 tons of VOC per 12-month 

rolling period. The CTG coatings VOC content limits range from 275 grams/liter (2.3 

pounds/gallon) to 420 grams/liter (3.5 pounds/gallon) of coating, less water and exempt 

compounds, as applied, depending on the type of coating and whether air-dried or 

baked. In lieu of complying with the VOC coatings limits, an operator may install and 

operate a VOC emission control system that has an overall capture and control 

efficiency of at least 90 percent, by weight. 

The CTG establish work practice standards to reduce VOC emissions. The standards 

include: storing all VOC coatings, thinners, and cleaning materials in closed containers, 

minimizing spills of VOC-containing coatings, thinners, cleaning spills immediately, 

conveying VOC-containing materials in closed containers or pipes, closing mixing 

vessels which contain VOC coatings and other materials except when specifically in 

use, and minimizing emissions of VOC during cleaning of storage, mixing, and 

conveying equipment. 

The CTG exempts stencil coatings, safety-indicating coatings, solid-film lubricants, 

electric-insulating and thermal-conducting coatings, touch-up and repair coatings, and 

coating application utilizing hand-held aerosols. 
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2. CTG for Metal Furniture Coatings (EPA 453/R-07-005) 

The CTG applies to metal furniture coating operations. The applicability VOC emission 

threshold, coating VOC limits, VOC emission control system control efficiency, and work 

practice standards, and exemptions are identical to the requirements discussed above 

for the CTG on large parts and products. Therefore, the CTG does not apply to these 

refinishing facilities. Based on the above discussion, District staff deems that District 

Rule 4606 satisfies Reasonably Available Control Technology (RACT). 

3. CTG for Surface Coating of Miscellaneous Metal Parts and Products (EPA450/2-78-015) 

The CTG applies to surface coating of miscellaneous metal parts and products. The 

coating VOC limits is 3.5 lb/gallon for air or forced air-dried and 4.3 lb/gallon for clear 

coat. Nothing is mentioned about the VOC limit for baked coatings as well for specialty 

coatings. The CTG allows the use of a VOC control system with an efficiency of 90% in 

lieu of using compliant coatings. In addition, the CTG included discussions on different 

coating application equipment spray, electrodeposition, electrostatic, dip coating, etc. 

However, unlike the CTGs for large appliance and metal furniture coating operations, 

the miscellaneous parts and products CTG does not specify any applicability VOC 

emission threshold and any work practice standards. 

The coatings VOC limits in CTG EPA-450/2-78-015 for miscellaneous parts and 

products of 3.5 lb/gallon for air or forced air-dried and 4.3 lb/gallon for clear coat are 

less stringent than District Rule 4603 VOC limit of 2.8 for general coating, air-dried. 

Rule 4603 prohibits the use of organic solvents for cleaning operations that exceed 25 

grams per liter of material, but the CTG does not have any VOC limits for solvent 

cleaning operations. 

4. CTG for Miscellaneous Metal and Plastic Parts Coatings (EPA-453/R-08-003) 

The CTG applies to each miscellaneous metal products and miscellaneous plastic parts 

coating units at a facility where the total actual VOC emissions from all miscellaneous 

metal product and plastic parts surface coating operations, including related cleaning 

activities, at that facility are equal to or exceed 6.8 kg/day (15 lb/day), or an equivalent 

level of 2.7 tons per 12-month rolling period, before consideration of controls. EPA 

does not recommend the CTG’s control approaches for facilities that emit below this 

level because of the very low emissions reductions that can be achieved. 

For comparison with Rule 4603 (Surface Coating of Metal Parts and Products), only the 

CTG requirements that pertains to coating operations associated with miscellaneous 

metal parts and products will be discussed in this RACT analysis. For miscellaneous 

metal parts and products coating operations, the CTG coatings VOC content limits 

range from 2.3 pounds/gallon to 6.2 pounds/gallon) of coating, excluding water and 

exempt compounds, as applied, depending on the type of coating and whether air-dried 

or baked. As an option, the CTG allows the coatings VOC limits to be expressed in 
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terms of mass of VOC per volume of coating solids, as applied, for facilities that use a 

combination of low-VOC coatings and add-on control equipment on a coating unit. 

Using an assumed VOC density of 7.36 pounds per gallon, the equivalent limits in terms 

of mass of VOC per volume of solids, as applied, ranged from 3.35 pounds per gallon 

solids to 38 pounds per gallon solids, depending on the type of coating and whether airdried or baked. 

The CTG also allows a facility to use add-on control equipment with an overall control 

efficiency of 90 percent install and operate a VOC emission control system that has an 

overall capture and control efficiency of at least 90 percent in lieu of using low-VOC 

coatings and specified application methods. 

The CTG VOC limits and application methods do not apply to aerosol coating products 

or powder coatings. Except for work practice standards, CTG VOC limits do not apply 

to stencil coatings, safety-indicating coatings, solid-film lubricants; and electricinsulating and thermal-conducting coatings. 

The CTG included discussions on different coating application equipment such as air 

spray system (conventional, airless, air-assisted airless, electrostatic, HVLP, and zincarc), dip coating, powder coatings, flow coating, roll coating, electrocoating, and 

autophoretic. 

The CTG establish work practice standards for coating-related activities to reduce VOC 

emissions. The standards include: store all VOC-containing coatings, thinners, and 

coating-related waste materials in closed containers; ensure that mixing and storage 

containers used for VOC-containing coatings, thinners, and coating-related waste 

materials are kept closed at all times except when depositing or removing these 

materials; minimizing spills of VOC-containing coatings, thinners, and coating-related 

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

materials from one location to another in closed containers or pipes. 

The CTG does not specify any VOC limits for solvent cleaning operations other than 

work practice standards. The work practice standards for cleaning materials tor educe 

VOC emissions. The standards include: store all VOC-containing cleaning materials 

and used shop towels in closed containers; (2) ensure storage containers used for 

VOC-containing cleaning materials are kept closed at all times except when depositing 

or removing these materials; minimizing spills of VOC-containing cleaning materials; 

convey VOC-containing cleaning materials from one location to another in closed 

containers or pipes; and minimize VOC emissions from cleaning application, storage, 

mixing, and conveying equipment by ensuring that equipment cleaning performed 

without atomizing the cleaning solvent and all spent solvent is captured in closed 

containers. 

Rule 4603 general coating limits are: Air-dried - 275 grams per liter (2.3 pounds per 

gallon) of coating, less water and exempt compounds, as applied. Baked – 340 grams 

per liter (2.8 pounds per gallon) of coating, less water and exempt compounds, as 
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applied. The specialty coating limits for baked range from 880 grams per liter (7.3 

pounds per gallon) to 360 grams per liter (3.0 pounds per gallon) of coating, less water 

and exempt compound, as applied, depending on the type of specialty coating; and for 

air-dried the limits range from 880 grams per liter (7.3 pounds per gallon) to 420 grams 

per liter (3.5 pounds per gallon) of coating less water and exempt compound, as 

applied, depending on the type of specialty coating. Coatings that are not specified in 

the table of VOC limits for specialty coatings are defaulted to the general coating 

category as specified above. 

In comparison with the Rule 4603, the CTG limits are less stringent than Rule 4603 

general coating limits (baked – 2.8 pounds per gallon; air-dried – 2.3 pounds per gallon) 

for the following coating types: electric-insulating varnish - 3.5 pounds per gallon (baked 

or air dried) ; etching filler - 3.5 pounds per gallon (baked and air dried); mold seal - 3.5 

pounds per gallon (baked or air dried); pan backing - 3.5 pounds per gallon (baked or 

air dried) ; prefabricated architectural multi-component – 3.5 pounds per gallon (airdried); prefabricated architectural one-component – 3.5 pounds per gallon (air-dried); 

pretreatment coating – 3.5 pounds per gallon (baked and air dried); vacuum-metalizing 

– 3.5 pounds per gallon (baked or air-dried). In addition, the CTG limits for baked 

camouflage coating and for metallic coating of 3.5 pounds per gallon is less stringent 

than Rule 4603 limit of 3.0 pounds per gallon. The CTG limit for baked extreme 

performance coating of 3.0 pounds per gallon is slightly stringent than Rule 4603 limit of 

3.5 pounds per gallon. Repair and touch-up coating is exempt in Rule 4603 but the 

CTG has a VOC limit of 3.5 pounds per gallon (air-dried) and 3.0 pounds per gallon 

(baked). 

In response to April 1, 2009 EPA comments that the 2008 CTG for Miscellaneous Metal 

and Plastic Coatings is more stringent than Rule 4603 (VOC limits for baked extreme 

performance, repair and touch-up coatings, and work practices for miscellaneous parts 

and products), District staff believes that Rule 4603, overall, is as stringent as the CTG 

for the following reasons: 

• Rule 4603 only exempts touch-up and repair coating, but the CTG has more 

exempt coatings (i.e., stencil coatings, safety-indicating coatings, solid film 

lubricants, electric-insulating and thermal-conducting coatings, powder coatings, 

magnetic data storage disk coatings, plastic extruded onto metal parts to form a 

coating, and aerosol coatings. Except for powder coatings and aerosol coating 

exemption, the CTG provides no explanation why such coatings have been 

exempted. District staff believes that the potential VOC emissions from the 

CTG’s numerous exempt coating categories as mentioned above would be 

greater than the emissions from just one exempt touch-up and repair coating 

category. It is important to mention that District Compliance staff’s field 

inspections show that, for touch and repair, operators generally use the same 

VOC-compliant coatings that are being applied during the fabrication process 

because of ease of color matching and for economic reason that they do not 

have to buy a separate coating exclusively for touch-up and repair. 
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• Although the CTG limit of 3.0 lb/gal is slightly lower than Rule 4603 limit of 3.5 

lb/gal for baked extreme performance coating, it is important to mention that the 

CTG has higher limits for 10 coating categories compared to a higher limit for 

only one coating in Rule 4603 as discussed above. District staff believes that 

the potential emissions from the CTG higher limits for 10 coatings would be 

greater than the emissions from Rule 4603 higher limit for only one coating 

category. 

• Rule 4603 has work practice standards only for large appliances and metal 

furniture coating operations similar to the CTG but none for miscellaneous metal 

parts and products. The CTG only recommends work practice standards for 

cleaning materials but no specific VOC limit because EPA stated that they have 

no information available regarding current VOC content to determine RACT for 

cleaning materials. Although Rule 4603 does not have work practice standards 

for miscellaneous metal parts and products coatings, District staff believes that 

Rule 4603, overall, is equivalent in stringency because the rule prohibits the use 

organic solvent cleaning materials that contain more than 25 grams VOC per 

liter, as well as compliance with certain work practice standards for which the 

CTG have specific no requirements. 

5. EPA 453/R-07-004 and EPA 453/R-07-005 

District Rule 4603 coatings VOC limits for large appliances and metal furniture coatings 

VOC limits, which range from 275 grams/liter to 420 grams/liter depending on the type 

of coating and whether baked or air-dried, are exactly the same as the limits specified 

by the CTGs . Unlike the CTGs for large appliances or metal furniture coating 

operations, District Rule 4603 does not exempt stencil coatings, safety-indicating 

coatings, solid-film lubricants, electric-insulating and thermal-conducting coatings. The 

work practice standards for large appliances or metal furniture coating operations are 

identical to the CTGs. Unlike the CTG which does not have any VOC limits for solvent 

cleaning operations, Rule 4603 prohibits the use of organic solvents for cleaning 

operations that exceed 25 grams per liter of material. As an alternative to complying 

with the solvent cleaning VOC limit, Rule 4603 allows the use of add-on emission 

control system that an overall capture and control efficiency of 90 percent, by weight. 

Based on the discussion above, District staff deems District Rule 4603 overall is as 

stringent as the CTGs and satisfies RACT. 

B. EPA – Alternative Control Techniques (ACT) Document 

ACT for Industrial Cleaning Solvents (EPA-453-94-015), February 1994 

This ACT contained detailed discussion on solvent cleaning activities (i.e., dipping, 

flushing, purging, spraying, and wiping) and factors that affect emissions. However, the 

ACT does not specify any solvent VOC limit or emission standards. Therefore, it does 
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not serve any meaningful purpose for RACT determination of organic solvent cleaning 

activities. 

In comparison, District Rule 4603 requires the use of cleaning solvents with a VOC 

content of no more than 25 grams/liter. As an alternative to using compliant cleaning 

solvents, an operator may operate an APCO-approved VOC emission control system 

that has an overall capture and control efficiency of 90%. In addition, District Rule 4603 

also specifies allowable cleaning methods such as wipe cleaning, non-atomized solvent 

flow, and solvent flushing. The rule prohibits atomization of solvent into open air unless 

it is vented to an APCO-approved VOC emission control system, and also prohibits use 

of VOC containing materials to clean spray equipment unless an enclosed system is 

used. A spray equipment cleaning method other than an enclosed system may be used 

provided it is proven to be equally as an enclosed effective in controlling emissions. 

Based on the discussion above, District staff deems District Rule 4603 satisfies RACT. 

C. Standards of Performance for New Stationary Sources (NSPS) 

1. 40 CFR 60 Subpart EE (Surface Coating of Metal Furniture) 

This NSPS applies to metal furniture coating operation facility that commences 

construction, modification, or reconstruction after November 28, 1980. Facilities using 

less than 3,842 liters of coating, as applied, per year are exempt. The NSPS prohibits 

the discharge into the atmosphere of VOC emissions from coating operations in excess 

of 0.90 kg/liter (900 grams/liter) of coating solids applied. In lieu of using compliant 

coatings, a VOC capture and control system may be used provided the performance 

monitoring requirements specified in the NSPS are met. The NSPS specifies coating 

application methods and corresponding transfer efficiencies (air atomized spray - 0.25; 

airless spray – 0.25; manual electrostatic spray – 0.60; nonrotational automatic 

electrostatic spray – 0.70; rotating head electrostatic spray manual and automatic – 

0.80%; dip and flow coating – 0.90; electrodeposition – 0.95). The NSPS details the 

methodology and mathematical equations for calculating the VOC emissions using the 

information VOC content of the coatings and the application method (with the 

corresponding transfer efficiency) to determine compliance with the 0.90 kg/liter limit. 

2. 40 CFR 60 Subpart SS (Industrial Surface Coating of Large Appliances) 

This NSPS applies to large appliance surface coating facility that commences 

construction, modification, or reconstruction after December 24, 1980. The NSPS 

prohibits the discharge into the atmosphere of VOC emissions from coating operations 

in excess of 0.90 kg/liter of coating solids applied. In lieu of using compliant coatings, a 

VOC capture and control system may be used provided the performance monitoring 

requirements specified in the NSPS are met. The NSPS specifies coating application 

methods and corresponding transfer efficiencies (air atomized spray – 0.40; airless 

spray – 0.45; manual electrostatic spray – 0.60; nonrotational automatic electrostatic 

spray – 0.85; rotating head automatic electrostatic spray – 0.90; dip and flow coating – 

0.85; electrodeposition – 0.95). The NSPS details the methodology and mathematical 
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equations for calculating the VOC emissions using the information VOC content of the 

coatings and the application method (with the corresponding transfer efficiency) to 

determine compliance with the 0.90 kg/liter limit. 

District Rule 4603 coatings VOC limits for large appliances and metal furniture coatings 

VOC limits, which range from 275 grams/liter (2.3 lb/gallon) to 420 grams/liter (3.5 

lb/gallon) of coating, applied, depending on the type of coating and whether baked or 

air-dried, are more stringent than the NSPS VOC emission limit of 0.90 kg/liter of 

coating solids applied (equivalent to 3.7 lb/gallon of coating, assuming an average 

solvent solids density of 10 lb/gallon and an average solids solvent density of 7.34 

lb/gallon). 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

NESHAPs and MACTs are requirements contained in 40 Code of Federal Regulations 

(CFR) Part 61 and 40 CFR Part 63. Since EPA has delegated the authority to 

implement NESHAP requirements to the District, NESHAPs and MACTs promulgated 

by EPA are usually incorporated by reference into District Rule 4002 (National Emission 

Standards for Hazardous Air Pollutants). It is important to mention that the District 

implements NESHAPs and MACTs by incorporating the emission standards as 

conditions of the Permits to Operate that are issued to affected sources. The three 

NESHAPs that apply to miscellaneous metal parts and products, large appliances, and 

metal furniture coating operations are briefly discussed below. 

1. 40 CFR Part 63 Subpart MMMM (NESHAP for Surface Coating of Miscellaneous 

Metal Parts and Products) 

This NESHAP applies to new, reconstructed, or existing affected source that uses 946 

liters (250 gallons) per year or more of coatings that contain hazardous air pollutants 

(HAPs) in surface coating of miscellaneous metal parts and products defined in the 

NESHAP, and that is a major source, located at a major source, or a part of a major 

source. A major source of HAP emissions is a stationary source that emits or has the 

potential to emit any single HAP at a rate of 9.07 megagrams (10 tons) or more per 

year, or any combination of HAP at a rate of 22.68 megagrams (25 tons) or more per 

year. The NESHAP include provisions for complying with the applicable emission limits, 

work practice standards, recordkeeping and reporting requirements. The NESHAP also 

contains exemptions for certain types of surface coating operations. Work practice 

standards are also specified by the NESHAP. The standards include storing all organic 

containing materials in closed containers, minimizing spills of all HAP materials, 

conveying HAP materials from one location to another in closed containers or pipes, 

closing mixing vessels except when adding, removing, or mixing the contents; and 

minimizing emissions during cleaning of storage, mixing, and conveying equipment. 

It is important to mention that the NESHAP HAP emission limits which are expressed in 

terms of mass (kg) of HAP per volume (liter) of coating solids are not directly 
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comparable to the coatings VOC limits which are expressed in terms of grams (or lb) of 

VOC per liter (or gallons) of coatings, less water and exempt compounds, as applied. In 

addition, some HAPs may be exempt VOCs, and some VOCs may be HAPs; therefore, 

there is no direct correlation between the NESHAP limit versus District Rule 4606 VOC 

limits. 

2. 40 CFR Part 63 Subpart NNNN (NESHAP for Surface Coating of Large 

Appliances) 

This NESHAP applies to each new, reconstructed, and existing large appliance parts 

and products coating facility that is a major source of hazardous air pollutants (HAPs) 

that emits or has the potential to emit a single HAP of 9.07 megagrams (10 tons) per 

year, or any combination of HAPs of 22.68 megagrams (25 tons) per year. It applies to 

a new affected source that commences construction after July 23, 2002 and the 

construction is of a completely new large appliance surface coating facility where 

previously no large appliance surface coating facility had existed. The NESHAP 

include provisions for complying with the applicable emission limits, work practice 

standards, and recordkeeping and reporting requirements. The NESHAP also contains 

exemptions for certain types of surface coating operations. Work practice standards are 

also specified by the NESHAP. The standards include storing all organic containing 

materials in closed containers, minimizing spills of all HAP materials, conveying HAP 

materials from one location to another in closed containers or pipes, closing mixing 

vessels except when adding, removing, or mixing the contents; and minimizing 

emissions during cleaning of storage, mixing, and conveying equipment. 

It is important to mention that the NESHAP HAP emission limits which are expressed in 

terms of mass (kg) of HAP per volume (liter) of coating solids are not directly 

comparable to the coatings VOC limits which are expressed in terms of grams (or lb) of 

VOC per liter (or gallons) of coatings, less water and exempt compounds, as applied. In 

addition, some HAPs may be exempt VOCs, and some VOCs may be HAPs; therefore, 

there is no direct correlation between the NESHAP limit versus District Rule 4606 VOC 

limits. 

3. 40 CFR Part 63 Subpart RRRR (NESHAP for Surface Coating of Metal Furniture) 

This NESHAP applies to each new, reconstructed, and existing metal furniture coating 

facility that is a major source, is located at a major source, or is a part of a major source 

of emissions of HAPs. A major source of HAP emissions is any stationary source or 

group of stationary source located within a contiguous area and under common control 

that emits or has the potential to emit a single HAP of 9.07 megagrams (10 tons) per 

year, or any combination of HAPs of 22.68 megagrams (25 tons) per year. An affected 

source is a new affected source if it commenced its construction after April 24, 2002, 

and the construction is of a completely new metal furniture coating operation facility 

where previously no metal furniture surface coating facility existed. 
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The NESHAP include provisions for complying with the applicable emission limits, work 

practice standards, and recordkeeping and reporting requirements. The NESHAP also 

contains exemptions for certain types of surface coating operations. Work practice 

standards are also specified by the NESHAP. The standards include storing all organic 

containing materials in closed containers, minimizing spills of all HAP materials, 

conveying HAP materials from one location to another in closed containers or pipes, 

closing mixing vessels except when adding, removing, or mixing the contents; and 

minimizing emissions during cleaning of storage, mixing, and conveying equipment. 

It is important to mention that the NESHAP HAP emission limits which are expressed in 

terms of mass (kg) of HAP per volume (liter) of coating solids are not directly 

comparable to the coatings VOC limits which are expressed in terms of grams (or lb) of 

VOC per liter (or gallons) of coatings, less water and exempt compounds, as applied. In 

addition, some HAPs may be exempt VOCs, and some VOCs may be HAPs; therefore, 

there is no direct correlation between the NESHAP limit versus District Rule 4606 VOC 

limits. 

How does District Rule 4603 compare to rules in other air districts?

District staff compared VOC limits, optional control requirements, and work practice 

standards in District Rule 4601 to comparable requirements in rules from the following 

California nonattainment areas: 

• South Coast AQMD Rule 1136 

• South Coast AQMD Rule 1107 (Coating of Metal Parts and Products) amended 

January 6, 2006 

• BAAQMD Regulation 8 Rule 19 (Surface Preparation and Coating of Miscellaneous 

Metal Parts and Products) amended October 16, 2002 

• BAAQMD Regulation 8, Rule 14 (Surface Preparation and Coating of Large 

Appliances and Metal Furniture) amended October 16, 2002 

• Sacramento Metropolitan Air Quality Management District (SMQMD) Rule 451 

(Surface Coating of Miscellaneous Metal Parts and Products) amended October 

10, 1997 

• Ventura County Air Pollution Control District (VCPCD) Rule 74.12 (Surface Coating 

of Metal Parts and Products) amended April 8, 2008 

A. SCAQMD Rule 1136 

SCAQMD Rule 1136 applies to all metal coating coatings operations except those 

performed on aerospace assembly, magnet wire, marine craft, vehicle, metal container, 

and coil coating operations. It also does not apply to the coating of architectural 

components at the structure site or at a temporary unimproved location designated 

exclusively for coating of structural components. SCAQMD Rule 1136 specifies the 

VOC limits for 22 categories of coatings. The VOC limits range from 275 to 420 

grams/liter for coatings depending on the coating type and whether air-dried or baked. 
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The VOC limit for stripping any coating is 200 grams/liter or less. As an alternate 

compliance option to using compliant coatings, the rule allows operators to use 

approved air pollution control equipment with a collection efficiency of 90% and a 

control efficiency of 95% (or the output of the control device is no more than 5 ppmv 

VOC calculated as carbon without dilution). The rule includes coating application 

equipment requirements and a VOC limit for solvent cleaning and surface preparation 

pursuant to SCAQMD Rule 1171 (Solvent Cleaning Operations). 

B. SCAQMD Rule 1107 (Coating of Metal Parts and Products) 

SCAQMD Rule 1107 exempts the following coatings or coating operations: 

• Stencil, safety indicating, magnetic data storage disk, solid film lubricants, and 

electric-insulating and thermal-conducting coatings 

• Coatings and cleaning solvents used in performance tests on coatings at paint 

manufacturing facilities. 

• High performance architectural, vacuum-metalizing, or pretreatment coatings used 

at a facility which has a potential to emit a total of 10 tons or less per year, before 

consideration of controls. 

• Aerosol coating products. 

• Use of aggregate 55 gallons or less of essential public service coatings per year per 

facility. 

• Use of aggregate 10 gallons or less of optical anti-reflective coatings per year per 

facility. 

• Use of 66 gallons of electrocoatings per month per facility provided the VOC content 

does not exceed 450 grams/liter, less water and less exempt compounds as 

applied. 

• Photoresist operations applying liquid photoresist coating used for photofabrication 

of metal substrates with a thickness not exceeding 0.060 inch provided the usgae 

does not exceed 10 gallons per year per facility. 

District Rule 4603 coatings VOC limits are subdivided into two major categories (i.e., 

general coatings and specialty coatings). For general coatings, the VOC limits are 340 

grams/liter for air-dried and 275 for baked. The specialty coatings are subdivided into 

eight types of coatings. In addition, District Rule 4603 has separate VOC limits for 

coatings used in metal furniture and large appliance coating operations versus coatings 

used for other metal parts and products coating operations. In contrast, SCAQMD Rule 

1107 does not have a general coating VOC limits, but the rule specifies VOC limits for 

22 coating types. All the specialty coatings VOC limits of District Rule 4603 for metal 

parts and products are as stringent as SCAQMD Rule 1107, except for extreme high 

gloss, extreme performance, metallic, and camouflage coatings. SCAQMD Rule 1107 

VOC limits for extreme high gloss air-dried of 340 grams/liter is stringent than 420 

grams/liter limit of District Rule 4603. However, SCAQMD Rule 1107 VOC limit for 

metallic coating and camouflage coating of 420 grams/liter baked is less stringent than 

District Rule 4603 limit of 360 grams/liter air dried. SCAQMD Rule 1107 coatings VOC 

limit for etching filler, vacuum-metalizing, mold seal, electric-insulating varnish, and pan 

backing coatings is 420 grams/liter is less stringent than District Rule 4603 coatings 
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limits of 275 grams/liter baked and 340 grams/liter air-dried (comparison is made using 

the general coatings limits since District Rule 4603 has no corresponding coating 

types). For large appliances and metal furniture coating operations, District Rule 4603 

VOC limits are the as stringent as SCAQMD Rule 1175. SCAQMD Rule 1107 has a 

VOC limit of 420 grams/liter air-dried and 360 grams/liter baked for touch-up coatings 

and repair coatings. District Rule 4603, however, does not have a VOC limit because 

touch and repair are exempt from the rule requirements. 

The solvents cleaning VOC limit of 25 grams/liter in District Rule 4603 is the same as 

the SCAQMD solvent cleaning limit for this source category which regulated under 

SCAQMD Rule 1171 (Solvent Cleaning Operations). 

Although SCAQMD Rule 1107 has slight more stringent VOC limits for extreme high 

gloss and extreme performance coatings than District Rule 4603, there are some 

coating types where SCAQMD Rule 1107 has less stringent limits as discussed above. 

It important to mention SCAQMD Rule 1107 has more exemptions than District Rule 

4603. Based on the above discussion District staff deems that overall District Rule 

4603 is as stringent as SCAQMD Rule 1107. 

C. BAAQMD Regulation 8 Rule 19 (Surface Preparation and Coating of 

Miscellaneous Metal Parts and Products) 

BAAQMD Regulation 8 Rule 19 applies to surface preparation and coating of 

miscellaneous parts and products. The VOC limits for general coatings are 340 

grams/liter for air-dried and 275 for baked. For specialty coatings, the VOC limits range 

from 360 grams/liter to 420 grams/liter depending on the coating type and whether 

baked or air-dried. In lieu of using compliant coatings, BAAQMD Regulation 8 Rule 19 

allows the use of an air pollution abatement equipment with an efficiency of at least 85% 

provided the emissions are reduced to a level that is at least equivalent to the emissions 

generated by using compliant coatings. 

BAAQMD Regulation 8 Rule 19 specifies the requirements for spray application 

equipment such as HVLP, electrostatic spray, detailing gun, or other spray application 

equipment that achieves equivalent transfer efficiency. The solvent evaporative loss 

minimization provisions require closed containers for storage or disposal of materials 

used for solvent surface preparation and cleanup; prohibits use of organic solvents that 

have a VOC content in excess of 50 grams/liter for cleanup of spray equipment and 

paint lines unless a spray gun washer that complies with Regulation 8, Rule 16 as well 

is used, or the solvent is pressurized through spray equipment with atomizing air off or 

disposed from a small non-atomizing container, and collected and stored in a closed 

container until recycled or properly disposed. The surface preparation solvent limit is 

50 grams/liter or the use of an approved emission control system with an overall 

abatement efficiency of at least 85%. 
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BAAQMD Regulation 8 Rule 19 exempts the following: 

• Usage of any coating that does not meet the applicable coating VOC limits if such 

usage is less than 75.7 liters (20 gallons) in any one calendar year and provided the 

total amount of all noncompliant coatings used does not exceed 100 gallons in any 

calendar year. 

• Application of adhesives; touch-up operations; metal containers and closures 

(drums, cans, lid, etc.) and metal coil; magnet wire for use in electrical machinery; 

metal furniture and large appliances (subject to Regulation 8, Rule 14); aircraft or 

aerospace vehicles; motor vehicles and mobile equipment; marine vessels and 

component parts; stationary structures and appurtenances which require 

architectural coatings except where bake coatings are required; stencil coatings, 

powder coatings provided the VOC emissions do not exceed that which is equivalent 

to the use of compliant coatings, solid film lubricants, chemical milling maskant, and 

coatings applied to printed board circuits, and other exemptions. 

• Specialty coatings (high performance; pretreatment wash primer; silicon release, 

extreme performance, and high temperature) provided they meet the VOC limits 

which range from 550 to 780 grams/liter depending on the type of coating and 

provided the usage of such coatings does not exceed 3,785 liters (100 gallons) in 

any calendar year. 

• Source operations using less than 20 gallons of coating in any calendar year is 

exempt from recordkeeping requirements. 

• Certain spray application equipment are exempt but with specific conditions of use. 

The coatings VOC limits of District Rule 4603 for metal parts and products are as 

stringent as the limits of BAAQMD Regulation 8, Rule 19. District Rule 4603 has VOC 

limit of 880 grams/liter for solid film lubricant, but BAAQMD Regulation 8, Rule 19 

exempts such coating. In lieu of using compliant coatings District Rule 4603 allows the 

use of a VOC emission control system with an overall capture and control efficiency of 

90%, which is more stringent than BAAQMD Regulation 8, Rule 19 requirement of 85% 

abatement efficiency. 

BAAQMD Regulation 8, Rule 19 requirements on spray application equipment and work 

practice standards (solvent evaporative loss minimization) are as stringent as District 

Rule 4603. However, the surface preparation and solvent clean-up VOC limit of 25 

grams/liter of District Rule 4603 is more stringent than the BAAQMD Regulation 8, Rule 

19 limit of 50 grams/liter. With regard to exempt operations, District Rule 4603 has 

lesser exempt operations than BAAQMD regulation 8, Rule 19. Based on the above 

discussions, District staff deems that overall District Rule 4603 is more stringent than 

BAAQMD Regulation 8, Rule 19. 

D. BAAQMD Regulation 8, Rule 14 (Surface Preparation and Coating of Large 

Appliances and Metal Furniture) 

BAAQMD Regulation 8, Rule 14 applies to surface preparation and coating of large 

appliances and metal furniture. The VOC limits for general coatings (high gloss, heat 

resistant, metallic topcoat, pretreatment wash primer, and solar adsorbant) are 340 
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grams/liter for air-dried and 275 for baked. For specialty coatings, the VOC limits range 

from 360 grams/liter to 420 grams/liter depending on the coating type and whether 

baked or air-dried. In lieu of using compliant coatings, BAAQMD Regulation 8 Rule 19 

allows the use of an air pollution abatement equipment with an efficiency of at least 85% 

provided the emissions are reduced to a level that is at least equivalent to the emissions 

generated by using compliant coatings. 

BAAQMD Regulation 8 Rule14 specifies the requirements for spray application 

equipment such as HVLP, electrostatic spray, flow coat, roller coat, dip coat, 

electrodeposition, and brush coat. The solvent evaporative loss minimization provisions 

require closed containers for storage or disposal of materials used for solvent surface 

preparation and cleanup; prohibits use of organic solvents that have a VOC content in 

excess of 50 grams/liter for cleanup of spray equipment and paint lines unless a spray 

gun washer that complies with Regulation 8, Rule 16 as well is used, or the solvent is 

pressurized through spray equipment with atomizing air off or disposed from a small 

non-atomizing container, and collected and stored in a closed container until recycled or 

properly disposed. The surface preparation solvent limit is 50 grams/liter or the use of 

an approved emission control system with an overall abatement efficiency of at least 

85%. 

BAAQMD Regulation 8 Rule 19 exempts the following: 

• Use of any coating that does not meet the applicable coating VOC limits if such 

usage is less than 75.7 liters (20 gallons) in any one calendar year and provided the 

total amount of all noncompliant coatings used does not exceed 208.1 liters (55 

gallons) in any calendar year. 

• Touch coating operation; adhesives application; aerosol cans, powder coatings 

provided the VOC emissions do not exceed that which is equivalent to the use of 

compliant coatings. 

• Surface preparation of electrical and electronic components; stripping of cured 

coatings, inks, and adhesives; research and development surface preparation; 

performance testing of adhesives, inks, and coatings; quality control and quality 

assurance testing. 

The coatings VOC limits of District Rule 4603 for metal parts and products are as 

stringent as the limits of BAAQMD Regulation 8, Rule 14, except the baked metallic 

topcoat VOC limit of 420 grams/liter is slight more stringent than District Rule 4603 limit 

of 420 grams/liter. However, BAAQMD Regulation 8, Rule 14 general coating VOC 

limit for air dried coatings of 340 grams/liter is less stringent than District Rule 4603 

VOC limit 275 grams/liter for air dried one component coating. In lieu of using compliant 

coatings District Rule 4603 allows the use of a VOC emission control system with an 

overall capture and control efficiency of 90%, which is more stringent than BAAQMD 

Regulation 8, Rule 14 requirement of 85% abatement efficiency. 

BAAQMD Regulation 8, Rule 14 requirements on spray application equipment and work 

practice standards (solvent evaporative loss minimization) are as stringent as District 

Rule 4603. However, the surface preparation and solvent clean-up VOC limit of 25 
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grams/liter of District Rule 4603 is more stringent than the BAAQMD Regulation 8, Rule 

19 limit of 50 grams/liter. With regard to exempt operations, District Rule 4603 has 

lesser exempt operations than BAAQMD Regulation 8, Rule 14. Based on the above 

discussions, District staff deems that overall District Rule 4603 is more stringent than 

BAAQMD Regulation 8, Rule 14. 

E. Sacramento Metropolitan Air Quality Management District (SMQMD) Rule 

451 (Surface Coating of Miscellaneous Metal Parts and Products) 

SMAQMD Rule 451 applies to the coating of miscellaneous parts and products 

including removal (stripping), surface preparation and cleanup operations. The coatings 

VOC limits range from 340 to 420 grams/liter for air dried coatings and from 275 to 420 

grams/liter for baked coatings, depending on the type of coatings. As an alternative to 

using compliant coatings, an APCO-approved air pollution control equipment which has 

an overall system efficiency of 85% may be used to comply with the rule. The VOC limit 

for strippers is 200 grams/liter. The rule includes requirements for coating application 

equipment (roll coater, dip coat, electrostatic spray, flow coat, HVPL, LVLP, hand 

application such as brush or roller, or any other method approved by the APCO and 

EPA. Surface preparation, cleanup, and storage requirements include using closed 

containers for disposal of cloth, paper, or sponges used for surface preparation cleanup 

and coating removal; closed containers for storing VOC-containing materials except 

when in use; use enclosed gun cleaner or use cleanup solvent with a VOC content that 

does not exceed 72 grams/liter; spray guns only may be soaked in solvent-based 

materials in a container not exceeding 5 gallons is tightly covered at all times except 

when accessing the container. 

SMAQMD Rule 451 exempts the following: 

• Use of any coating that does not meet the applicable coating VOC limits if such 

usage is less than 55 gallons per calendar year, per stationary source, except for 

complying with recordkeeping requirements. 

• Use of any aluminum coating for window and door frames exceeding the specified 

VOC limit if the usage is less than 200 gallons per calendar year, per stationary 

source, except for complying with the recordkeeping requirements. 

• Use of pretreatment wash primer that exceeds the specified VOC limit if the usage is 

less than 200 gallons per calendar year, per stationary source, except for complying 

with the recordkeeping requirements. 

• Coating of prefabricated architectural components or structures not coated in a shop 

which are regulated by Rule 442 (Architectural Coatings). 

• Coating of motor vehicles, excluding radiators, drive trains, differentials, and engine 

components which by Rule 459 (Automotive, Truck and heavy Equipment 

Refinishing Operations). 

• Coating of aircraft or aerospace vehicles; cans, coils or magnetic wire; adhesives; 

magnetic data storage disc; safety indicating coatings; stencil coatings; conformal 

coatings (e.g., coating of electronic circuit boards or assembled components); and 

hand lettering. 
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The coatings VOC limits of SMAQMD Rule 451 are as stringent as District Rule 4603, 

except SMAQMD Rule 451 aluminum coating limit of 420 grams per liter for baked and 

air-dried coating, 420 grams/liter for baked metallic/irridescent, and baked non-skid 360 

grams/liter are less stringent than District Rule 4603 general coatings limits of 275 

grams/liter for baked and 340 grams/liter for air dried coatings and baked metallic 

coating limit of 360 grams/liter. In lieu of using compliant coatings, SCAQMD Rule 451 

allows the use of an APCO-approved air pollution control equipment with an overall 

system efficiency of 85% compared to District Rule 4603 more stringent overall capture 

and control efficiency of 90%. SCAQMD Rule 551 solvent cleaning and surface 

preparation VOC limit of 72 grams/liter is less stringent than District Rule 4603 VOC 

limit of 25 grams/liter. 

Unlike the exemptions in SMAQMD Rule 451, District Rule 4603 does not exempt 

aluminum coating for window and door frames exceeding the specified VOC limit if the 

usage is less than 200 gallons per calendar year; coatings used on magnetic data 

storage disc; safety indicating coatings; stencil coatings; conformal coatings (e.g., 

coating of electronic circuit boards or assembled components); and hand lettering. 

Based on the above discussion, District staff deems that District Rule 4603 overall is 

more stringent than SCAQMD Rule 451. 

F. Ventura County APCD Rule 74.12 (Surface Coating of Metal Parts and 

Products) 

VCPCD Rule 74.12 applies to surface coating of metal parts and products. The 

coatings VOC limits range from 275 to 420 grams/liter depending on the type of coating 

and whether the coating is air-dried or baked. As an alternative to using compliant 

coatings, an APCO-approved air pollution control equipment which has an overall 

system efficiency of 90% may be used to comply with the rule. VCPCD Rule 74.12 

contains coating application equipment and solvent cleanup and surface preparation 

requirements, but the rule does not include any work practice standards. The VOC limit 

for substrate surface cleaning and spray equipment cleaning or cleanup is 25 

grams/liter. 

VCPCD Rule 74.12 exempts the following: 

• If no complying coatings are available, total usage of non-complying coatings has 

not exceeded 55 gallons in any calendar year. 

• Aircraft or aerospace vehicle coating operations; marine vessel exteriors; motor 

vehicle and mobile equipment; and aerosol coating products. 

• Stationary source that emits less than 200 lb ROC (VOC) in every rolling period of 

12 consecutive months from metal parts and products coating operations (emissions 

from aerosol products, cold cleaners and vapor degreasers should not be included in 

this determination). 

• Surface preparation and cleanup requirements do not apply to metal parts and 

products coating operations if the total usage of non-complying substrate surface 

cleaners does not exceed 5 gallons per rolling 12-month period. 
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VCPACD Rule 74.12 coatings VOC limits of 275 grams per liter for air-dried for “all 

coatings” category, 360 grams/liter for baked extreme performance coating, and 420 

grams/liter for air-dried and 275 grams/liter for baked pretreatment wash primer are 

slightly more stringent than District Rule 4603 limits of 340 grams/liter for air-dried 

general coatings, 420 grams/liter for baked extreme performance, and 420 grams/liter 

for both air-dried and baked pretreatment coating. However, District Rule 4603 coatings 

VOC limits of 340 grams/liter air-dried and 275 grams/liter baked for general coatings 

are more stringent than VCPACD Rule 74.12 limits of 420 grams/liter for air-dried or 

baked mold seal coating, 420 grams/liter for air-dried or baked pan backing coating, and 

420 grams/liter for air-dried and baked vacuum metalizing coating. It is important to 

mention that since District Rule 4603 does include mold seal, pan backing, and vacuum 

metalizing coating categories, such coatings are subject to the “general coatings” VOC 

limits of District Rule 4603. District Rule 4603 includes work practice standards while 

VCPACD Rule 74.12 has none specified. In addition, District Rule 4603 has VOC limits 

for metal parts and products coating operations and separate limits for large appliances 

and metal furniture coating operations. Unlike District Rule 4603, VCAPCD Rule 74.12 

exempts sources that emit less than 200 lb ROC (VOC) in every rolling period of 12 

consecutive months from metal parts and products coating operations (emissions from 

aerosol products, cold cleaners and vapor degreasers should not be included in this 

determination). Based on the above discussion, District staff deems that overall District 

Rule 4603 is as stringent as VCAPCD Rule 74.12. 

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4603 

satisfies RACT for metal parts and products, large appliance parts and products, and 

metal furniture coating operations. However, in order to incorporate the recent CTG 

requirements, as outlined in Table 4-3, the rule is on a schedule for amendment. 
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Rule 4604 - Can and Coil Coating Operations 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 0 0 0 0 0 0 0 0 

VOC 1.0 1.0 1.1 1.1 1.2 1.3 1.3 1.4 

(Source: District Ozone Plan) 

District Rule 4604 Description

District Rule 4604, recently amended on September 20, 2007, controls VOC emissions 

from can and coil coating operations, and from organic solvent cleaning, storage and 

disposal associated with can coating and coil coating operations. 

The rule limits the VOC content of different coatings and allows an emission control 

device for those companies who use non-compliant coatings. Alternative emission 

control plans are also allowed under certain conditions. The emission control system or 

alternative emission control plan must reduce emissions to no more than the amount of 

VOCs that would have been emitted had rule-compliant coatings been used. The rule 

contains provisions for organic solvent cleaning, storage and disposal requirements, 

monitoring provisions, and recordkeeping. 

There are a limited number of sources subject to Rule 4604 (less than ten). There are 

neither two-piece can manufacturers nor coil coating operations in the SJVAB. Except 

for the closed manufacturing site, the companies subject to this rule have year-round 

operations, although some of the equipment under permit is operated only during peak 

periods. 

How does District Rule 4604 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

EPA-450/2-77-008 1977/05

The CTG applies to surface coating of cans, coils, paper, fabrics, automobiles, and 

light-duty trucks operations located in marginal, moderate, serious or severe ozone 

nonattainment areas that has the potential to emit greater than or equal to 25 tons/year 

of VOC, and equal to greater than 10 tons/year of VOC for extreme ozone 

nonattainment areas. 

The table below identifies the CTG requirements and how Rule 4604 compares to those 

requirements. 
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Coating Type CTG (lb/gal) Rule 4604 (lb/gal) 

Can Sheet basecoat 2.8 2.1 

Can Interior Body 4.2 3.5 

Can Side Seam 5.5 5.5 

Can End Seal 3.7 0.2 

Coil Prime and Topcoat 2.6 1.7 

As shown in the table above, District Rule 4604 is as stringent or more stringent than all 

CTG limits. 

B. EPA - Alternative Control Technology (ACT) 

There is no EPA ACT guidance document for can and coil coating operations. 

C. Standards of Performance for New Stationary Sources (NSPS) 

1. 40 CFR 60 Subpart TT (Standards of Performance for Metal Coil Surface 

Coating) 

The table below identifies the NSPS requirements and how Rule 4604 compares to 

those requirements. 

Coating Type NSPS (kg/l) 4604 (kg/l) 

Coil Surface – No 

Control Device 0.28 (monthly average) 0.20 

Coil Surface – 

W/Control Device 

0.14 (monthly average) or 

90% VOC reduction 90% VOC reduction 

As shown in the table above, District Rule 4604 is as stringent or more stringent than all 

NSPS limits. 

2. 40 CFR 60 Subpart WW (Standards of Performance for Beverage Can Surface 

Coating Industry) 

The table below identifies the NSPS requirements and how Rule 4604 compares to 

those requirements. 

Coating Type NSPS (kg/l) 4604 (kg/l) 

2-Piece can exterior base 

coat 0.29 0.25 

2-Piece can clear base 

coat 0.46 0.25 

2-Piece can overvarnish 0.46 0.25 

2-Piece can inside spray 0.89 0.36 
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As shown in the table above, District Rule 4604 is as stringent or more stringent than all 

NSPS limits. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

NESHAPs and MACTs are requirements contained in 40 Code of Federal Regulations 

(CFR) Part 61 and 40 CFR Part 63. Since EPA has delegated the authority to 

implement NESHAP requirements to the District, NESHAPs and MACTs promulgated 

by EPA are usually incorporated by reference into District Rule 4002 (National Emission 

Standards for Hazardous Air Pollutants). It is important to mention that the District 

implements NESHAPs and MACTs by incorporating the emission standards as 

conditions of the Permits to Operate issued to affected sources. 

1. 40 CFR 63 Subpart KKKK (National Emission Standards for HAPs: Surface 

Coating of Metal Cans) 

Per Section 63.3481, this Subpart does not apply since 40 CFR 63 Subpart SSSS 

(National Emission Standards for HAPs: Surface Coating of Metal Coil) applies to this 

emission source category. 

2. 40 CFR 63 Subpart SSSS (National Emission Standards for HAPs: Surface 

Coating of Metal Coil) 

The requirements in this subpart are not directly comparable to the District Rule 4604 

limit of 200 g/L of coil coating. The NESHAP HAP emission limits which are expressed 

in terms of % HAP, HAP emission concentration, and mass (kg) of HAP per mass (kg) 

of solids are not directly comparable to the coatings VOC limit which is expressed in 

terms of grams (or lb) of VOC per liter (or gallons) of coatings, less water and exempt 

compounds, as applied. In addition, some HAPs may be exempt VOCs, and some 

VOCs may be HAPs; therefore, there is no direct correlation between the NESHAP limit 

versus District Rule 4604 VOC limits. 

How does District Rule 4604 compare to rules in other air districts?

District staff compared VOC limits, optional control requirements, and work practice 

standards in District Rule 4604 to comparable requirements in rules from the following 

California nonattainment areas: 

• South Coast AQMD Rule 1125 - Metal Container, Closure, and Coil Coating 

Operations, amended March 7, 2008 

• BAAQMD Regulation 8 Rule 11 - Metal Container, Closure and Coil Coating, as 

amended November 19, 1997 
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• Sacramento Metropolitan Air Quality Management District (SMQMD) Rule 452 (Can 

Coating), as amended September 25, 2008 

• Ventura County Air Pollution Control District (VCPCD) - No rule for can or coil 

coating facilities.

A. South Coast Air Quality Management District (SCAQMD) Rule 1125 - Metal Container, 

Closure, and Coil Coating Operations 

SCAQMD Rule 1125 applies to can and coil coating operations. The table below 

identifies where the rules differ in VOC requirements. Categories not discussed, such 

as solvents, means the two rules have the same requirement. 

Category South Coast 

(g/l) SJ Valley (g/l) More Stringent for Category 

Exemption Throughput 1 gal/day 55 gal/year SJ Valley 

Necker Lubricants 100 Exempt South Coast 

Stripping of Cured Materials 25 Exempt South Coast 

Cleaning Solvents Lab/Research 25 Exempt South Coast 

2-Piece can interior spray 440 420 SJ Valley 

End Seal Compound 

(Food/Beverage) 440 20 SJ Valley 

End Seal Compound (NonFood/Beverage) 0 20 South Coast 

Inks 250 - 800 See Rule 4607 

RACT Analysis 

See Rule 4607 

RACT Analysis 

Due the central locality of the agriculture industry, the SJ Valley’s can/coil coating 

facilities overwhelmingly manufacture food/beverage products compared to nonfood/beverage products. As such, the SJ Valley’s stringent rule limit of 20 g/l (versus 

the South Coast limit of 440 g/l) has a greater affect on VOC emissions compared to the 

insignificant categories where the South Coast is more stringent, such as the 

small/exempt operations and end seal compound for non-food/beverage. Overall 

SJVAPCD Rule 4604 is at least as stringent as SCAQMD Rule 1125. 

B. Bay Area Air Quality Management District (BAAQMD) Regulation 8 Rule 11 – 

(Metal Container, Closure and Coil Coating ) 

BAAQMD Reg 8 Rule 11 applies to can and coil coating operations. The table below 

identifies where the rules differ in VOC requirements. Categories not discussed means 

the two rules have the same requirement. 
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Category Bay Area (g/l) SJ Valley (g/l) More Stringent 

for Category 

Exemptions 

Facilities Using < 55 gal/year Not Exempt Exempt Bay Area

Two Piece Can Coating

Exterior Sheet Base Coating 225 250 Bay Area 

End Coating (Interior or Exterior) 250 420 Bay Area 

Repair Coating No Limit 750 SJ Valley 

Three Piece Can Coating

Overvarnish (Exterior or Interior) 250 225 SJ Valley 

End Coating (Exterior or Interior) 250 225 SJ Valley 

Repair Coating No Limit 750 SJ Valley 

Drum Pails, Pails, and Lids

Sheet Base Coating No Limit 225 SJ Valley 

Overvarnish (Exterior or Interior) No Limit 225 SJ Valley 

Interior End Coating (New) No Limit 420 SJ Valley 

Interior End Coating 

(Reconditioned) No Limit 510 SJ Valley 

Exterior End Coating (New) No Limit 340 SJ Valley 

Exterior End Coating 

(Reconditioned) No Limit 420 SJ Valley 

Side Seam Coating No Limit 660 SJ Valley 

Inks 300 See Rule 4607 

RACT Analysis 

See Rule 4607 

RACT Analysis 

Solvents

Surface Preparation No Limit 25 SJ Valley 

Repair and maintenance No Limit 25 SJ Valley 

Cleaning of Coating Application 

Equipment (except 3-piece can 

sheet coater) 

No Limit 25 SJ Valley 

Cleaning of 3-piece can sheet 

coater No Limit 550 SJ Valley 

As shown in the table above, the SJVAPCD rule contains an overwhelmingly amount of 

requirements that are more stringent than the Bay Area Rule. Also, potential reductions 

from two-piece can coating are non-existent since there are no two-piece can coating 

operations in the SJVAPCD. Overall SJVAPCD Rule 4604 is at least as stringent as 

BAAQMD Regulation 8 Rule 11. 
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C. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 

452 (Can Coating) 

SMAQMD Rule 452 applies to can coating operations. The table below identifies where 

the rules differ in VOC requirements. Categories not discussed means the two rules 

have the same requirement. 

Category Sac Metro (g/l) SJ Valley (g/l) More Stringent 

for Category 

Exemptions 

Facilities Using < 55 gal/year Not Exempt Exempt Sac Metro

Two Piece Can Coating

Exterior Body Spray No Limit 420 SJ Valley 

End Coating (Interior or Exterior) 250 420 Sac Metro 

End Seal Compound (Non-Food) 0 20 Sac Metro 

Repair Coating No Limit 750 SJ Valley 

Three Piece Can Coating

Exterior Body Spray No Limit 420 SJ Valley 

End Coating (Exterior or Interior) No Limit 250 SJ Valley 

End Seal Compound (Non-Food) 0 20 Sac Metro 

Repair Coating No Limit 750 SJ Valley 

Coil 

Prime and topcoat or single coat 225 200 SJ Valley

Solvents

Surface Preparation 25 (starting 

9/25/09) 25 SJ Valley 

Repair and maintenance 25 (starting 

9/25/09) 25 SJ Valley 

Cleaning of Coating Application 

Equipment (except 3-piece can 

sheet coater) 

25 (starting 

9/25/09) 25 SJ Valley 

Cleaning of 3-piece can sheet 

coater 

25 (after 

9/25/09) 

550 (until 

9/30/11) 

250 (after 

9/25/09 

Sac Metro 

Cleaning side seam spray 

applicators No Limits 25 SJ Valley 

Not shown in the table above is a comparison for drum, pail, and lid coating categories. 

The SJVAPCD rule contains limits for drum, pail, and lid coating, whereas the 

SMAQMD rule does not. The SJVAPCD will assume that since SMAQMD rule has no 
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limits for this category, there are no facilities of this nature in the SMAQMD. As such, 

the two District rules will be considered equivalent for the drum, pail, and lid coating 

categories. 

As shown in the table above, the SJVAPCD rule contains several requirements that are 

more stringent than the SMAQMD Rule. Also, potential reductions from two-piece can 

coating are non-existent since there are no two-piece can coating operations in the 

SJVAPCD. Overall SJVAPCD Rule 4604 is at least as stringent as SMAQMD Rule 452. 

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4604 

satisfies RACT for can and coil coating operations. 
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Rule 4605 – Aerospace Assembly and Component Coating Operations 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

VOC 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 

(Source: District 2007 Ozone Plan) 

District Rule 4605 Description

District Rule 4605, recently amended on September 20, 2007, sets VOC content limits 

for coatings, adhesives, and other related VOC-containing materials for coating 

operations related to aerospace assemblies and components. 

The flushing of jet or rocket engines using any solvent other than trichloroethylene is 

exempt. Aerospace assembly and component coating operations using less than four 

gallons per day of VOC-containing products are exempt as are other coatings or 

adhesives. Materials used in laboratories associated with research and development, 

quality control, or production testing are exempt from VOC content limits. There is also 

a limited exemption from application equipment standards. VOC emissions are 50% 

controlled compared to uncontrolled emissions. 

How does District Rule 4605 compare with federal rules and regulations?

A. EPA-Control Technique Guidelines (CTG) 

1. The CTG EPA-453/R-97-004 1997/12 applies to Surface Coating Operations at 

Aerospace Manufacturing and Rework Operations located in marginal, moderate, 

serious or severe ozone nonattainment areas that has the potential to emit 

greater than or equal to 25 tons/year of VOC, and equal to greater than 10 

tons/year of VOC for extreme ozone nonattainment areas. 

The table below identifies the CTG requirements and how Rule 4605 compares 

to those requirements. 

Coating Type CTG (g/L) 4605 (g/L) 

Ablative 600 - 

Adhesion Promoter 890 850 

Adhesive Bonding Primers 850 805 

Adhesive (Non-Structural) 360 250 

Adhesive (Structural Autoclavable) 60 50 

Adhesive (Structural Non-Autoclavable) 850 850 

Antichafe 660 600 

Bearing Coating 620 -- 
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Coating Type CTG (g/L) 4605 (g/L) 

Caulking and Smoothing Compounds 850 -- 

Chemical Agent Resistant Coating 550 -- 

Conformal Coating -- 750 

Dry Lubricative Material 880 675 

Electric/Radiation Effect Coating 800 800 

Electromagnetic Interference Coating 800 -- 

Fire-Resistant Coatings 800 650 

Flight Test Coatings (Missiles or Single Use Target Craft) 420 420 

Flight Test Coatings (Other) 840 600 

Fuel Tank Coatings 720 420 

High Temperature Coating 850 850 

Impact Resistant Coating -- 420 

Intermediate Release Coating 750 -- 

Lacquer 830 -- 

Maskants 1,020 250 

Metalized Epoxy Coating 740 -- 

Mold Release 780 -- 

Optical Anti-Reflective Coating 750 700 

Part Marking Coating 850 -- 

Pretreatment Coatings 780 780 

Primer (Commercial Exterior Aerodynamic Structure) 650 350 

Primer (General) -- 350 

Primer (Compatible Substrate) 780 350 

Primer (Cryogenic Flexible) 645 350 

Primer (Flexible) 640 350 

Primer (Elevated Temperature Skydrol Resistant 

Commercial) 740 350 

Rain Erosion Resistant Coating 850 800 

Rocket Motor Nozzle Coating 660 -- 

Scale Inhibitor 880 880 

Screen Print Ink 840 -- 

Sealant (Extrudable/Rollable/Brushable) 280 600 

Sealant (Fastener) 600 675 

Sealant (Sprayable) 600 600 

Silicone Insulation Material 850 -- 

Solid Film Lubricant (Fastener Mfr) 880 250 

Solid Film Lubricant (Fastener Installation) 880 880 

Solid Film Lubricant (Non-Fastener Mfr) 880 880 

Space Vehicle Coatings (Electrostatic Discharge 

Protection) -- 800 

Space Vehicle Coatings (Adhesives) -- 800 

Space Vehicle Coatings (Other) -- 1,000 

Specialized Function Coating 890 -- 

Temporary Protective Coating 320 250 

Thermal Control Coating 800 -- 

Topcoat (General) -- 420 

Topcoat (Barrier) -- 420 

Topcoat (Clear) 720 520 

Topcoat (Epoxy Polyamide) 660 -- 

Topcoat (Self Priming - Unicoat) -- 420 

Wet Fastener Installation Coating 675 -- 

Wing Coating 850 750 
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Coating Type CTG (g/L) 4605 (g/L) 

Wire Coating (Electronic) -- 420 

Wire Coating (Anti-Wicking) -- 420 

Wire Coating (Pre-Bonding Etching) -- 420 

Wire Coating (Phosphate Ester Resistant Ink) -- 925 

As shown in the table above, District Rule 4605 is more stringent than the CTG 

limits for 34 categories, while the CTG is more stringent than District Rule 4605 

in 19 categories. As such, District staff concludes that District Rule 4605 is at 

least as stringent overall than the CTG. 

2. The CTG EPA-450/2-77-034 1977/12 applies to Surface Coating of Large 

Appliances operations located in marginal, moderate, serious or severe ozone 

nonattainment areas that have the potential to emit greater than or equal to 25 

tons/year of VOC, and equal to greater than 10 tons/year of VOC for extreme 

ozone nonattainment areas. 

Since this CTG applies to large appliance coating; therefore, it will not be 

compared to SJVAPCD Rule 4605 which covers aerospace coating. 

3. The CTG EPA-450/2-77-022 1977/11 applies to VOC Emissions from 

Solvent Metal Cleaning operations located in marginal, moderate, serious or 

severe ozone nonattainment areas that have the potential to emit greater than or 

equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of VOC for 

extreme ozone nonattainment areas. 

This CTG applies to the use of the following degreasing equipment: cold 

cleaners, open top vapor degreasers, and conveyorized degreasers. Identified in 

the CTG are design and work practice standards for cold cleaners, open top 

vapor degreasers, and conveyorized degreasers, for example: cover the solvent 

tank, have a facility for waste solvent and draining cleaned parts, permanent 

labels on operating parts, close degreaser when not in use, drain parts until 

dripping ceases, no excessive splashing if solvent is sprayed. The CTG also 

identifies add-on controls such as refrigeration chillers and carbon control. 

SJVACPD Rule 4605 identifies solvent VOC content limits or a control system 

with efficiencies of at least 90% capture and 95% control, and that would not 

allow more emissions than if compliant materials were utilized. The general 

solvent limit is 200 g/L; the coating stripper solvent limit is currently 300 g/L. 

Since the CTG does not identify control requirements any more stringent than 

SJVACPD Rule 4605, District staff considers Rule 4605 at least as stringent as 

the CTG. 

B. EPA - Alternative Control Technology (ACT) 

There is no EPA ACT guidance document for aerospace coating operations. 
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C. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS guidance document for aerospace coating operations. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

NESHAPs and MACTs are requirements contained in 40 Code of Federal 

Regulations (CFR) Part 61 and 40 CFR Part 63. Since EPA has delegated the 

authority to implement NESHAP requirements to the District, NESHAPs and 

MACTs promulgated by EPA are usually incorporated by reference into District 

Rule 4002 (National Emission Standards for Hazardous Air Pollutants). It is 

important to mention that the District implements NESHAPs and MACTs by 

incorporating the emission standards as conditions of the Permits to Operate 

issued to affected sources. 

1. 40 CFR 63 Subpart GG (National Emission Standards for HAPs: Aerospace 

Manufacturing and Rework Facilities) 

The requirements in this subpart are not directly comparable to the District 

Rule 4605 VOC limits. The NESHAP HAP emission limits which are 

expressed in terms of % HAP, HAP emission concentration, and mass (kg) of 

HAP per mass (kg) of solids are not directly comparable to the coatings VOC 

limit which is expressed in terms of grams (or lb) of VOC per liter (or gallons) 

of coatings, less water and exempt compounds, as applied. In addition, some 

HAPs may be exempt VOCs, and some VOCs may be HAPs; therefore, there 

is no direct correlation between the NESHAP limit versus District Rule 4605 

VOC limits. 

How does District Rule 4605 compare to rules in other air districts?

District staff compared District Rule 4605 with the rules of other California ozone 

nonattainment air districts’ rules (listed below) for aerospace operations. The results of 

the analysis are discussed below. 

A. South Coast Air Quality Management District (SCAQMD) Rule 1124 - Aerospace 

Assembly and Component Manufacturing Operations (Amended September 21, 

2001) 

B. Bay Area Air Quality Management District (BAAQMD) Regulation 8 Rule 29 - 

Adhesive and Sealant Products (Amended December 20, 1995) 

C. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 456 - 

Aerospace Assembly and Component Coating Operations (Amended October 

23, 2008) 
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D. Ventura County Air Pollution Control District (VCPCD) Rule 74.13 - Aerospace 

Assembly and Component Manufacturing Operations (Amended November 11, 

2003) 

The table below compares requirements for each of the rules. All coating and solvent 

limits are in g/L. 

Exemptions Bay Area 

(Rule 8-29) 

South Coast 

(Rule 1124) 

Sac Metro 

(Rule 456) 

Ventura 

(Rule 74.13) 

SJV 

(Rule 

4605) 

Airbrushing X 

Fabrication of Electronic 

Components X 

Assembled Circuit Boards X 

Low Use Facility 3 gal/day 200 lbVOC/yr 4 gal/day 

Military Corrosion Repair 

Coating 5 gal/day 

Clear/Translucent Coatings on 

Clear/Transparent Surfaces X 

Paper Fabric Film X 

Tank-Type Stripper X 

Adhesives X X 10 gal/yr 

Aerosol Cans X X X X X 

Non-Compliant Coatings 200 gal/yr 200 gal/yr 55 gal/yr 200 gal/yr 20 gal/yr 

Stencil Coatings X X 

Touch Up Coatings X 

Recoating of Assembled 

Aircraft with Original Coating 

Formulations 

 X 

Materials Marking Coatings X 

R&D Laboratories X X 

Solid Film Lubricant (Antichafe) X 

Test Panels X 

Temporary Marking Coatings X 

Solvents (Space Vehicle) X X 

Solvents (Rocket Motor Lining) X 

Solvents (Jet Engine or Rocket 

Engine Flushing) X 

Solvents (Prior to Adhesive 

Bonding) X 

Solvents (Solar Cells, Fluid 

Systems, Avionic Equipment, 

Laser Optics) 

 X 

Solvents (Surfaces exposed to 

strong oxidizers or reducers) X 

Satellite Coatings X 

Primer (High Temp Curing 

Adhesive Bonding) X 
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Exemptions Bay Area 

(Rule 8-29) 

South Coast 

(Rule 1124) 

Sac Metro 

(Rule 456) 

Ventura 

(Rule 74.13) 

SJV 

(Rule 

4605) 

Spray Application Equipment 

(360 Degree Spray Gun 

Nozzle) 

X 

Spray Application Equipment 

(Waterborne Extreme 

Performance Interior Topcoat) 

X 

Spray Application Equipment 

(Adhesive 

Bonding/Pretreatment Wash 

Primers) 

X 

Spray Application Equipment 

(Textured Finish Coat) X 

Application Equipment (Touch 

Up and Repair) X 

Coatings that contain fillers to 

decrease atomization with 

HVLP guns 

 X 

Hand Held Spray Containers 

w/non-refillable propellant X 

Coatings added via Template, 

Stencil, Stamp, Hand Lettering X 

Coating Type Bay Area 

(Rule 8-29) 

South Coast 

(Rule 1124) 

Sac Metro 

(Rule 456) 

Ventura 

(Rule 74.13) 

SJV 

(Rule 

4605) 

Ablative 600 

Adhesion Promoter 850 850 850 

Adhesion Promoter (Sealant) 750 

Adhesive (Bonding Agent) 780 

Adhesive (General) 600 

Adhesive (Fuel Tank) 620 620 620 

Adhesive (Non-Structural) 250 250 250 

Adhesive (Structural 

Autoclavable) 50 50 50 

Adhesive (Structural NonAutoclavable) 850 850 850 

Antichafe 420 600 600 

Conformal Coating 750 600 750 750 

Dry Lubricative Material 675 

Electric/Radiation Effect 

Coating 800 800 800 800 

Electrostatic Discharge 612 

Extreme Performance 750 

Fire-Resistant Coatings 

(Commercial) 600 650 600 650 650 

Fire-Resistant Coatings 

(Military) 800 

Flight Test Coatings (Missiles 420 420 420 420 
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Coating Type Bay Area 

(Rule 8-29) 

South Coast 

(Rule 1124) 

Sac Metro 

(Rule 456) 

Ventura 

(Rule 74.13) 

SJV 

(Rule 

4605) 

or Single Use Target Craft) 

Flight Test Coatings (Other) 840 600 600 

Fuel Tank Coatings 720 420 650 420 420 

High Temperature Coating 850 420 850 850 

Impact Resistant Coating 420 420 420 

Lubricant (Solid Film - Fastener 

Mfr) 250 250 250 

Lubricant (Dry Lubricative - 

Fastener Mfr) 120 250 120 

Lubricant (Barrier - Fastener 

Mfr) 420 

Lubricant (Solid Film - Fastener 

Installation) 880 880 880 880 

Lubricant (Dry Lubricative - 

Fastener Installation) 675 

Lubricant (Solid Film NonFastener Mfr) 880 880 880 880 

Lubricant (Dry Lubricative NonFastener Mfr) 675 880 675 

Maskants (General) 850 250 

Maskants (Chemical 

Processing) 250 

Maskants (Chemical Milling 

Type I) 250 622 250 250 

Maskants (Chemical Milling 

Type II) 160 160 250 250 

Maskants (Photolithographic) 850 

Maskants (Touch-up, Line 

Sealer) 750 

Metalized Epoxy Coating 700 

Mold Release Coatings 780 762 

Optical Anti-Reflective Coating 700 700 700 

Part Marking Coating 850 

Pretreatment Coatings 780 780 

Primer (Commercial Exterior 

Aerodynamic Structure) 350 

Primer (Adhesive Bonding) 850 780 805 

Primer (Adhesive Bonding - 

New Commercial Aircraft) 250 250 

Primer (Adhesive Bonding - 

Military Aircraft) 805 805 

Primer (Adhesive Bonding - 

Remanufactured Commercial 

Aircraft Parts) 

 805 805 

Primer (Adhesive Bonding - 

Sonic and Accoustic 

Applications) 

 805 805 

Primer (Adhesive Bonding - 250 250 
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Coating Type Bay Area 

(Rule 8-29) 

South Coast 

(Rule 1124) 

Sac Metro 

(Rule 456) 

Ventura 

(Rule 74.13) 

SJV 

(Rule 

4605) 

Long Term) 

Primer (Adhesive Bonding - 

Short Term) 250 250 

Primer (General) 350 350 350 350 350 

Primer (Compatible Substrate) 350 

Primer (Cryogenic Flexible) 350 

Primer (Flexible) 350 

Primer (Elevated Temperature 

Skydrol Resistant Commercial) 350 

Primer (Low-Solids Corrosion 

Resistant Primer) 350 

Primer (Pretreatment) 780 

Primer (Pretreatment Wash) 420 780 350 

Primer (Rain Erosion Resistant) 850 

Primer (Sealant Bonding) 720 350 

Radiation Effect 600 

Rain Erosion Resistant Coating 800 600 420 800 

Rain Erosion Resistant Coating 

(Fluoroelastomer) 800 

Scale Inhibitor 880 880 880 

Sealant 

(Extrudable/Rollable/Brushable) 600 280 600 

Sealant (Fastener) 600 675 675 675 

Sealant (Other) 600 600 600 600 

Sealant (Sprayable) 600 600 

Space Vehicle Coatings 

(Electrostatic Discharge 

Protection) 

 800 880 800 800 

Space Vehicle Coatings 

(Adhesives) 800 800 800 

Space Vehicle Coatings (Other) 1,000 1,000 1,000 1,000 

Temporary Protective Coating 250 250 250 250 250 

Thermal Control Coating 600 

Thermal Expansion Release 762 

Topcoat (Acrylic Lacquer for F111) 780 

Topcoat (General) 420 420 420 420 420 

Topcoat (Barrier) 420 420 

Topcoat (Clear) 520 520 520 

Topcoat (Interior) 340 420 

Topcoat (Interior - Extreme 

Performance) 420 420 

Topcoat (Epoxy Polyamide) 420 

Topcoat (Self Priming - 

Unicoat) 420 420 420 420 420 
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Coating Type Bay Area 

(Rule 8-29) 

South Coast 

(Rule 1124) 

Sac Metro 

(Rule 456) 

Ventura 

(Rule 74.13) 

SJV 

(Rule 

4605) 

Wet Fastener Installation 

Coating 620 

Wing Coating 750 420 750 

Wire Coating (Electronic) 420 420 

Wire Coating (Anti-Wicking) 420 420 

Wire Coating (Other) 420 

Wire Coating (Pre-Bonding 

Etching) 420 420 

Wire Coating (Phosphate Ester 

Resistant Ink) 925 925 925 

Application Methods Bay Area 

(Rule 8-29) 

South Coast 

(Rule 1124) 

Sac Metro 

(Rule 456) 

Ventura 

(Rule 74.13) 

SJV 

(Rule 

4605) 

Brush or Roll Coat X X X X X 

Dip Coat X X X X X 

Detailing Gun X X X X X 

Electro deposition X X X X X 

Electrostatic Spray X X X X X 

Flow Coat X X X X X 

Hand Application X X X X X 

HVLP Spray X X X X X 

LVLP Spray X 

Other, Transfer Efficiency 

Minimum X X X X X 

Add-on Control Efficiency Bay Area 

(Rule 8-29) 

South Coast 

(Rule 1124) 

Sac Metro 

(Rule 456) 

Ventura 

(Rule 74.13) 

SJV 

(Rule 

4605) 

Capture 90% 90% 

Control 85% 95% 95% 

Overall Control 86% 85% 85% 86% 

Solvents Bay Area 

(Rule 8-29) 

South Coast 

(Rule 1171)* 

Sac Metro 

(Rule 456) 

Ventura 

(Rule 74.13) 

SJV 

(Rule 

4605) 

Cleaning (General) No Limit Exempt 200 200 200 

Coating Strippers 400 Exempt 300 300 300 

Cleaning (Application 

Equipment) 

Enclosed 

system (or 

Equiv) 

Enclosed 

system (or 

Equiv) 

Enclosed 

system (or 

Equiv) 

Enclosed 

system (or 

Equiv) 

Enclosed 

system 

(or 

Equiv) 

*Per Rule 1171 (Solvent Cleaning) 
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As shown in the table above, SJVAPCD Rule 4605 varies in stringency when compared 

to other Districts’ adhesive requirements. However, for the majority of categories, Rule 

4605 is as stringent as or more stringent than the other District Rules. 

Conclusion

District staff concludes that District Rule 4605 satisfies RACT for aerospace assembly 

and component coating operations. 
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Rule 4606 – Wood Products and Flat Wood Products Coating 

Operations 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 0 0 0 0 0 0 0 0 

VOC 1.2 1.3 1.4 1.5 1.6 1.7 1.8 1.9 

(Source: District 2007 Ozone Plan) 

District Rule 4606 Description

District Rule 4606, recently amended on October 16, 2008, controls VOC emissions 

from wood products coating operations and flat wood paneling products coating 

operations, and from the organic solvent cleaning, storage and disposal of solvents, and 

waste solvent materials associated with such coating operations. District Rule 4606 

rule specifies the VOC content limits of coatings used on wood products which range 

from 125 grams/liter to 750 grams/liter (excluding water and exempt compounds, as 

applied) depending on the type of coating. For flat wood paneling products, the VOC 

content limit is 250 grams/liter (excluding water and exempt compounds, as applied). 

The VOC content limit for solvents used in cleaning operations is 25 grams/liter of 

material. In lieu of complying with the specified VOC content limits of coatings and 

solvents, operators may use a VOC emission control system with specified capture and 

control efficiency of at least 85 percent for wood coating operation, and at least 90 

percent for flat wood paneling products coating operations. 

District Rule 4606 exempts aerosol coatings for touch up and repair; wood products 

coating operations that use a total of less than 20 gallons per year in a stationary 

source; coatings application by template to add letters, designs or numbers to wood 

products; coating application to wooden musical instruments; residential noncommercial coating operation; architectural coating application; refinishing, 

replacement, and custom replica furniture operations; and specific finishes coatings. 

How does District Rule 4606 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

1. EPA-453/R-96-007 CTG for Wood Furniture Manufacturing Operations 

The CTG applies to wood furniture manufacturing facilities located in marginal, 

moderate, serious or severe ozone nonattainment areas that has the potential to emit 

greater than or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of 

VOC for extreme ozone nonattainment areas. The CTG specifies VOC limits only for 
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topcoats and sealers, but not for any other coating types which range from 0.8 to 2.3 lb 

VOC/lb solid (equivalent to 460 to 660 grams/liter of coating). District Rule 4606 VOC 

limits 275 grams/liter for topcoats and sealers are more stringent than the CTG limits. 

The CTG does not exempt refinishing, replacement and custom replica furniture coating 

operations, but District Rule 4606 exempts such operations from meeting the VOC 

limits. However, a review of the District’s Permit to Operate (PTO) database indicates 

that there are only two permitted refinishing coating application facilities operating in the 

San Joaquin Valley. The annual VOC emission of one facility is 0.2 tons/year and is 

using a coating with a VOC limit of 2.14 lb/gal which is less than 2.3 lb/gal VOC limit of 

District Rule 4606. The annual VOC emissions of the other facility is 0.8 tons/year and 

uses low VOC stains with a VOC content of 0.58 lb/gal, sealers with a VOC content of 

0.51 lb/gal, topcoats with a VOC content of 0.58 lb/gal, pigmented coatings with a VOC 

content of 2.3 lb/gal which are within the specified VOC limits of District Rule 4606. 

In response to April 1, 2009 EPA comments recommending more detailed discussion 

regarding the exemption Rule 4606 exemption for refinishing, replacement and custom 

replica coating operations, District staff has included the following justifications: 

• The only two permitted facilities in the San Joaquin Valley are using compliant 

coatings that meet the VOC limits of Rule 4606 as discussed above. 

• The total VOC emissions of 0.28 tons/year (0.00077 tons/day) from refinishing, 

replacement and custom replica furniture coating operations in the District is 

only 0.05% of 474.5 tons/year (1.3 tons/day) 2008 baseline emissions 

inventory. 

• The annual VOC emissions of each exempted facility (0.2 tons/year and 8 

tons/year) are much less than the CTG applicability threshold of 10 tons/year of 

VOC per facility. Therefore, the CTG does not apply to these refinishing 

facilities. 

2. EPA 453-06-004 CTG for Flat Wood Paneling Coatings 

District Rule 4606 VOC limit of 250 grams/liter for coatings, inks, or adhesives applied 

to flat wood paneling products are the same as the limit in the CTG. Based on the 

discussion above, District staff deems District Rule 4606 satisfies RACT. 

B. EPA – Alternative Control Technology (ACT) 

There is no EPA ACT guidance document for wood coating operations. 

C. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS for wood products coating operations or flat wood paneling products 

coating operations. 
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D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

NESHAPs and MACTs are requirements contained in 40 Code of Federal Regulations 

(CFR) Part 61 and 40 CFR Part 63. Since EPA has delegated the authority to 

implement NESHAP requirements to the District, NESHAPs and MACTs promulgated 

by EPA are usually incorporated by reference into District Rule 4002 (National Emission 

Standards for Hazardous Air Pollutants). It is important to mention that the District 

implements NESHAPs and MACTs by incorporating the emission standards as 

conditions of the Permits to Operate issued to affected sources. 

1. 40 CFR 63 Subpart JJ (National Emission Standards for Wood Furniture 

Manufacturing) 

This NESHAP applies to wood furniture manufacturing sources that are not exempt 

under the following conditions: (1) a source that uses no more than 250 gallons per 

month, for every month, of coating, gluing, cleaning, and wash off materials at the 

source; (2) a source that uses no more than 3,000 gallons per rolling 12-month period, 

for every 12-month period, of coating, gluing, cleaning, and wash off materials at the 

source, including materials used for source categories other than wood furniture 

(surface coating); or (3) a source that emits no more than 4.5 Mg (5 tons) of any one 

HAP per rolling 12-month period and no more than 11.4 Mg (12.5 tons) of any 

combination of HAP per rolling 12-month period, and at least 90 percent of the plant 

wide emissions per rolling 12-month period are associated with the manufacture of 

wood furniture or wood furniture components. Exempt sources are required to maintain 

monthly records of the amount of VOC-containing materials used and such records 

have to be kept for a period of five years. 

It is important to mention that the NESHAP HAP emission limit which is expressed in 

terms of mass (kg) of HAP per mass (kg) of solids is not directly comparable to the 

coatings VOC limit which is expressed in terms of grams (or lb) of VOC per liter (or 

gallons) of coatings, less water and exempt compounds, as applied. In addition, some 

HAPs may be exempt VOCs, and some VOCs may be HAPs; therefore, there is no 

direct correlation between the NESHAP limit versus District Rule 4606 VOC limits. 

2. 40 CFR 63 Subpart DDDD—National Emission Standards for Hazardous Air 

Pollutants: Plywood and Composite Wood Products 

This NESHAP applies sources that manufacture plywood and/or composite wood 

products by bonding wood material (fibers, particles, strands, veneers, etc.) or 

agricultural fiber, generally with resin under heat and pressure, to form a structural 

panel or engineered wood product, and that emit or have the potential to emit any single 

HAP at a rate of 9.07 megagrams (10 tons) or more per year or any combination of HAP 

at a rate of 22.68 megagrams (25 tons) or more per year. Plywood and composite 

wood products manufacturing facilities also include facilities that manufacture dry 

veneer and lumber kilns located at any facility. 
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It is important to mention that the NESHAP HAP emission limit which is expressed in 

terms of mass (kg) of HAP per mass (kg) of solids is not directly comparable to the 

coatings VOC limit which is expressed in terms of grams (or lb) of VOC per liter (or 

gallons) of coatings, less water and exempt compounds, as applied. In addition, some 

HAPs may be exempt VOCs, and some VOCs may be HAPs; therefore, there is no 

direct correlation between the NESHAP limit versus District Rule 4606 VOC limits. 

Currently, there is no plywood or composite wood products manufacturing companies 

operating within the San Joaquin Valley.

3. 40 CFR 63 Subpart QQQQ (National Emission Standards for Surface Coating of 

Wood Building Products) 

This NESHAP applies to sources that perform surface coating operations involving 

wood building products that use at least 4,170 liters (1,100 gallons) of coating per year, 

and is a major source, is located at a major source, or is a part of a major source of 

HAP emissions. A major source is a source that has the potential to emit 9.0 

megagrams/yr (10 tons/yr) of any single HAP or 22.68 megagrams/yr (25 tons/yr) of any 

combination of HAP. This NESHAP applies to new, reconstructed, and existing source 

(a new affected source is one on which construction commenced after 6/21/02). The 

NESHAP specifies work practice standards, monitoring and recordkeeping. 

It is important to mention that the NESHAP HAP emission limit which is expressed in 

terms of mass (kg) of HAP per mass (kg) of solids is not directly comparable to the 

coatings VOC limit which is expressed in terms of grams (or lb) of VOC per liter (or 

gallons) of coatings, less water and exempt compounds, as applied. In addition, some 

HAPs may be exempt VOCs, and some VOCs may be HAPs; therefore, there is no 

direct correlation between the NESHAP limit versus District Rule 4606 VOC limits. 

How does District Rule 4606 compare to rules in other air districts?

District staff compared VOC limits, optional control requirements, and work practice 

standards in District Rule 4604 to comparable requirements in rules from the following 

California nonattainment areas: 

• South Coast AQMD Rule 1136 (Wood Products Coatings) amended June 14, 1996 

• SCAQMD Rule 1104 (Wood Flat Stock Coating Operations) amended August 13, 

1999 

• BAAQMD Regulation 8 Rule 23 (Coating of Flat Wood Paneling and Wood Flat 

Stock) amended December 20, 1995 

• BAAQMD Regulation 8 Rule 32 (Wood Products Coatings) amended June 19, 1996 

• Sacramento Metropolitan Air Quality Management District (SMQMD) Rule 463 

(Wood Products Coating) amended July 23, 1998

• Ventura County Air Pollution Control District (VCPCD) Rule 74.30 (Wood Products 

Coatings) amended June 6, 2006. 
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A. SCAQMD Rule 1136 (Wood Products Coatings) 

SCAQMD Rule 1136 applies to coating operations on any wood products. The VOC 

limits range from 120 to 750 grams/liter for coatings depending on the coating type and 

500 grams/liter for inks. As an alternate compliance option to using compliant coatings, 

the rule allows operators to use emissions averaging for all or a portion of the coatings 

at a facility in provided the actual emissions from the coatings being averaged do not 

exceed the emissions generated by complying with the specified coating limits. The rule 

includes coating application equipment requirements and a VOC limit for solvent 

cleaning and surface preparation pursuant to SCAQMD Rule 1171 (Solvent Cleaning 

Operations). The rule exempts facilities that use one gallon/day or less of coating. In 

addition, the rule exempts japans provided the VOC content is 700 grams/liter or less. 

The rule also allows the addition of 10% by volume to topcoat, primer, sealer or 

undercoat to avoid blushing during high humidity provided the coating contains no more 

than 550 grams/liter of VOC and the coating is not applied from April 1 to October 31 of 

any year. The rule does not exempt refinishing, replacement, and custom replica 

furniture coating operations. 

District Rule 4606 has the same VOC content limits as SCAQMD Rule 1136, except 

that District Rule 4606 VOC limit of 240 grams/liter is lower than SCAQMD Rule 1136 

limit of 350 grams/liter. District Rule 4606 does not allow operators to use emissions 

averaging, but SCAQMD Rule 1136 allows it as a compliance option instead of using 

compliant materials. District Rule 4606 allows an operator to install and operate a VOC 

emission control system with a specified capture and control efficiency in lieu of using 

compliant coatings. The coating application methods specified in District Rule 4606 are 

identical to SCAQMD Rule 1136. The solvents cleaning VOC limit of 25 grams/liter in 

District Rule 4606 is the same as the SCAQMD solvent cleaning limit for this source 

category which regulated under SCAQMD Rule 1171. 

SCAQMD Rule 1136 exemption from the VOC limits and coating application method for 

facilities that use less than one gallon per day or less of coating is less stringent than 

District Rule 4606 exemption for facilities that use 20 gallons per year of coating. 

District Rule 4606 exempts refinishing, replacement, and custom replica furniture 

coating operations but SCAQMD Rule 1136 does not exempt such coating operations. 

As discussed in Section III.A above, there are only two permitted facilities that performs 

refinishing coating operations and their total combined annual VOC emissions are 

insignificant (1 ton/year or 5 lb/day of VOC) which is insignificant. SCAQMD Rule 1136 

allows the use of japans with a high VOC limit of 700 grams/liter, but District Rule 4606 

considers japans as pigmented coating subject to 275 grams/liter VOC limit. District 

SCAQMD Rule 1136 allows the addition of 10% by volume to topcoat, primer, sealer or 

undercoat, but District Rule 4606 does not allow it. The coating application equipment 

and solvent cleaning requirements of District Rule 4606 are as stringent as SCAQMD 

Rule 1136. Based on the above discussion, in spite of exemption for refinishing 

operations, District staff deems that overall District Rule 4606 is as stringent as 

SCAQMD Rule 1136. 
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B. SCAQMD Rule 1104 (Wood Flat Stock Coating Operations) 

SCAQMD Rule 1104 applies to manufacturing of finished wood panel. The VOC limit is 

250 grams/liter for coatings, inks, and adhesives. In lieu of complying with the VOC 

limit, an operator may use a VOC control equipment that reduces the emissions by at 

least 95 percent or the output of the control device is less than 50 ppm and provided the 

efficiency of the collection system is at least 90 percent. District Rule 4606 has the 

same coating VOC limits but the VOC emission system’s capture and control efficiency 

is more stringent by an additional 5 percent [i.e., 90 percent overall capture and control 

efficiency for flat wood paneling products coating operations versus SCAQMD Rule 

1104 control efficiency of 85.5 percent (95 percent control x 90 percent capture)]. 

The coating application methods specified in District Rule 4606 are identical to 

SCAQMD Rule 1104. The solvents cleaning VOC limit of 25 grams/liter in Rule 4606 is 

the same as the SCAQMD solvent cleaning limit for this source category which 

regulated under a separate rule SCAQMD Rule 1171 (Solvent Cleaning Operations). 

Based on the above discussion, District Rule 4606 is more stringent than SCAQMD 

Rule 1104 based on the VOC emission control system overall capture and control 

efficiency. 

C. BAAQMD Regulation 8 Rule 23 (Coating of Flat Wood Paneling and Wood 

Flat Stock) 

BAAQMD Regulation 8 Rule 23 applies to the application of coatings and adhesives to 

flat wood and wood flat stock products. The VOC limit for coatings, adhesives, and inks 

is 250 grams/liter. The rule allows operators to use an air pollution abatement device 

with an efficiency of at least 90 percent. Overall, the emission limits and control device 

efficiency requirements of BAAQMD Regulation 8 Rule 23 is as stringent as District 

Rule 4606 for this source category. 

D. BAAQMD Regulation 8 Rule 32 (Wood Products Coatings) 

BAAQMD Regulation 8 Rule 32 applies to wood products coating operations. The rule 

has separate coating VOC limits depending on the type of wood products. The VOC 

limits for general wood product range from 275 to 700 grams/liter depending on the type 

of coating. The VOC limits for furniture, custom cabinetry, and custom architectural 

millwork range from 480 to 700 grams/liter. For custom and contract furniture, the VOC 

limits range from 480 to 700 grams/liter. The rule does not have a VOC limit for stripper. 

In lieu of using compliant coatings, the rule allows an operator to use an air pollution 

abatement equipment has an abatement efficiency of at lest 85 percent. In addition, 

operators may demonstrate compliance with the VOC limits by averaging (multiple day 

periods on a rolling basis for a period no greater than 30 days) any or all coatings and 

solvent usage directly to the coating of wood products. The rule contains several 

exemptions such as facilities that use a total of less than 20 gallons of coatings per 

year; refinishing, replacement, and custom replica furniture; stencil coatings; musical 
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instruments; and other types of exemptions. In addition the rule also exempts facilities 

that use low VOC coatings that at are high solid coatings with a VOC content of no 

more than 275 grams/liter and low solids coatings with a VOC content of no more than 

120 grams/liter. The rule includes solvent evaporative loss minimization as well as 

coating application equipment requirements. 

In comparison, District Rule 4606 VOC limits range from 120 to 500 grams/liter for 

coatings and 750 grams/liter for inks for all types of wood products. The stripper VOC 

limit is 350 grams/liter. District Rule 4606 also exempts refinishing, replacement, and 

custom replica furniture coating operations and facilities that use less than 20 gallons 

per year of coatings, but does not exempt facilities that use low VOC coatings as 

provided by BAAQMD Regulation 8 Rule 32. Based on the above discussion staff 

deems that, overall, District Rule 4606 is more stringent than BAAQMD Regulation 8 

Rule 32. 

E. Sacramento Metropolitan Air Quality Management District (SMQMD) Rule 

463 (Wood Products Coating) 

SCAQMD Rule 463 applies to coatings, strippers, used in wood products wood products 

coating operations and solvents used in surface preparation and cleanup. The coatings 

VOC limits for new wood products range from 120 to 750 grams/liter of coating 

depending on the type coating. The coatings VOC limits for refinishing, repairing, 

preserving, or restoring wood products range from 480 to 700 grams/liter depending on 

the type of coating. The VOC limit for stripper is 350 grams/liter or a VOC composite 

partial vapor pressure of 2 mm Hg (0.04 psia) or less at 680

F. In lieu of complying with 

the VOC limits, an operator may use an air pollution control device which reduces the 

emissions by an equivalent or greater amount than the emissions resulting from the use 

of compliant coatings and strippers. The rule also allows operators to use an approved 

emission averaging method which demonstrates that the emissions from all the coatings 

being averaged are less than the allowable emissions from using compliant materials. 

The rule contains coating application equipment and solvent cleanup and surface 

preparation requirements. The VOC limit for solvent cleanup and surface preparation is 

200 grams/liter. The rule contains several exemptions such as sources using less than 

55 gallons/year, coating operations for the purpose of manufacturing finished wood 

panels, non-refillable aerosol coatings, and stencil coatings. 

In comparison, District Rule 4606 coatings VOC limits are the same as SMAQMD Rule 

463 limits for new wood products. However, District Rule 4606 exempts refinishing, 

replacement, and custom replica furniture coatings operations. As discussed in Section 

III.A above, there are only two permitted facilities that performs refinishing coating 

operations and their total combined annual VOC emissions are insignificant (1 ton/year 

or 5.5 lb/day of VOC). District Rule 4606 only allows the use of strippers with a VOC 

limit of 350 grams/liter, but SMAQMD Rule 463 allows the use of a stripper with either a 

composite partial vapor of 2 mm Hg (0.04 psia) or less at 680

F or with a VOC limit of 

350 grams/liter. In addition, District Rule 4606 solvent cleanup and surface preparation 

VOC limit is 25 grams/liter which is more stringent than SMAQMD Rule 462 limit of 200 
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grams/liter. Based on the above discussion, District staff deems that overall District 

Rule 4606 is as stringent as SCAQMD Rule 463. 

F. Ventura County Air Pollution Control District (VCPCD) Rule 74.30 (Wood 

Products Coatings) 

VCPCD Rule 74.30 applies to coatings used in wood products. The VOC limits for new 

wood product or new simulated wood products range from 120 to 500 grams/liter for 

coatings, 240 grams/liter for sealers, and 750 grams/liter for inks. For refinishing 

operation, the VOC limits range from 480 to 680 grams for coatings and 750 grams/liter 

for inks. The VOC limit for stripper is 350 grams/liter or a VOC composite partial vapor 

pressure of 2 mm Hg (0.04 psia) or less at 680

F. The rule allows the use of an emission 

control system that achieves a combined capture and control efficiency of at least 90 

percent. The rule contains coating application equipment and solvent cleanup and 

surface preparation requirements. The VOC limit for solvent cleaning is 25 grams/liter. 

The rule exempts facilities that emit less than 200 pounds in every rolling 12 

consecutive calendar months. Also exempt is coating of wooden musical instruments. 

In comparison, District Rule 4606 coatings VOC limits are the same as VCAPCD Rule 

74.30 limits for new wood products, except the VOC limit of 275 grams/liter for sealers 

is slightly higher than Ventura’s 240 grams/liter limit. Unlike VCAPCD Rule 74.30, 

District Rule 4606 exempts sources that perform refinishing coating operations. As 

discussed in Section III.A above, there are only two permitted facilities that perform 

refinishing coating operations and their total combined annual VOC emissions are not 

significant (1 ton/year or 5.5 lb/day of VOC). District Rule 4606 only allows the use of 

strippers with a VOC limit of 350 grams/liter, but VCPCD Rule 74.30 allows the use of a 

stripper with either a composite partial vapor of 2 mm Hg (0.04 psia) or less at 680

F or 

with a VOC limit of 350 grams/liter. District Rule 4606 emission control system 

efficiency of 85 percent for wood products coating operations is less stringent than 

VCPACD Rule 74.30 control efficiency of 90 percent. However, a review of the District’s 

Permit to Operate database indicates that there are no wood coating facilities in the San 

Joaquin Valley that operate a VOC emission control system as a compliance option in 

lieu of using compliant coatings required by District Rule 4606. Therefore, increasing 

the capture and control efficiency of the VOC control system from 85 percent to 90 

percent would not result in any emissions reductions from current level. 

VCPCD Rule 74.30 exemption for facilities that emit 200 lb/year of VOC or less is 

slightly less stringent than District Rule 4606 exemption of 20 gallons/year per facility 

(assume a VOC limit of 6.7 lb/gal, 20 gallons of coating/year exemption would only emit 

134 lb/year of VOC). Based on the above discussion staff deems that, overall, District 

Rule 4606 as stringent as VCPACD Rule 74.30. 
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Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4606 

satisfies RACT for wood products and flat wood products coating operations. 
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Rule 4607 – Graphic Arts 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

VOC 1.7 1.7 1.9 1.9 2.1 2.2 2.3 2.3 

(Source: District 2007 Ozone Plan) 

District Rule 4607 Description

This source category includes any graphic arts printing operation, to any paper, fabric film, 

or foil coating operation, to the organic solvent cleaning, and to the storage and disposal 

of solvents and waste solvent materials associated with these operations. 

How does District Rule 4607 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

1. EPA 450/2-77-008 –Control Technique Guidelines for Control of VOCs from 

Existing Stationary Sources – Volume II: Surface Coating of Cans, Coils, Paper, 

Fabrics, Automobiles, and Light-Duty Trucks 

Out of the six surface coating operations covered by the CTG, two are part of District 

Rule 4607 (Graphic Arts) – paper coating and fabric coating. The CTG-recommended 

VOC content limits for coatings within these source categories ranges from 290 grams 

per liter to 380 grams per liter depending on coating type. The CTG also allows 

operators to use higher VOC content materials if the operator uses an add-on VOC 

emission control system with overall capture and control efficiency of at least 81%. 

The coating VOC content limits in the CTG are higher than the VOC content limit of 265 

grams per liter for the same categories in District Rule 4607. The required overall 

capture and control efficiency for paper and fabric coating operations in District Rule 

4607 is 90%, which is higher than the 81% overall capture and control efficiency 

recommended in the CTG. 

2. EPA 450/2-78-033 – Control Techniques Guidelines for Control of VOCs from 

Existing Stationary Sources – Volume VIII: Graphic Arts - Rotogravure and 

Flexography 

This CTG applies to printing and coating operations using rotogravure (gravure) and 

flexography (flexo). The CTG acknowledges that these operations tend to use high 
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VOC inks and coatings for technical reasons. Because of this, the CTG first discusses 

add-on controls for these operations, followed by ink VOC content limits. 

Recommended overall capture and control efficiencies depend on the printing 

technology and the product. For publication gravure and publication flexo, 

recommended the overall capture and control is broken into its components - 75% 

capture and 90 to 95% control, meaning that the overall capture and control would be 

the capture multiplied by the control, which is minimally 67.5%. For packaging gravure, 

overall capture and control efficiency is recommended at 65% and all non-publication 

flexo at 60% overall capture and control. 

The CTG recommends that 25% of the volatile portion of the ink as solvent for waterborne gravure and water-borne flexo inks and a 70% reduction in solvent usage 

compared to all-solvent inks as being comparable to an add-on VOC control system. 

The CTG also recommends an exemption for inks with more than 60% non-volatiles. 

The CTG recommendations for inks cannot be directly compared to the VOC content 

limits for inks in District Rule 4607. The District rule limits inks and other materials to a 

specific VOC content in grams VOC per liter material, minus water and exempt 

compounds. The CTG does not have VOC content expressed in these units; therefore 

it is difficult to determine whether the CTG and the District rule are equivalent. Any 

comparison for water-borne inks would have to be done on a case-by-case basis for 

individual inks because the ratio of water to solvent could be different for each waterborne ink and the water/solvent ratio is not directly tied to the VOC content as evaluated 

by the District rule. Evaluating solvent-based ink reductions would also be problematic 

since the volume of solids per volume of material could greatly affect the overall VOC 

content when the content is expressed per liter of material, minus water and exempt 

compounds. 

Current District Rule 4607 specifies overall control for add-on control devices used in 

graphic arts operations into three groups. The VOC emission control system is required 

to have an overall capture and control efficiency of at least 80% for flexible packaging 

printing (regardless of printing technology used), 85% for publication gravure, and 75% 

for other types of graphic arts printing operations. 

3. EPA 453/R-06-002 – Control Techniques Guidelines for Offset Lithographic Printing 

and Letterpress Printing 

This CTG, promulgated by EPA September 2006, provides control recommendations for 

reducing VOC emissions stemming from the use of fountain solutions, cleaning 

materials, inks in offset lithographic printing and cleaning materials, and inks in 

letterpress printing. The CTG contains three mechanisms to reduce VOC emissions 

from offset lithographic printing and letterpress printing. These options are add-on 

controls, process modifications or work practices, and material reformulation or 

substitution. The recommended level of control for VOC emissions from dryers for heatset operations is either 90% or 95% control efficiency depending on the control device’s 
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installation date. The CTG recommends applying controls to offset lithographic printing 

operation where emissions associated with all aspects of that operation equal or exceed 

6.8 kg per day (15 pounds per day) actual emissions of VOC or an equivalent level, 

before consideration of controls. The allowable VOC content depends on the specific 

ink (heat-set or cold-set) and feed type (web-fed or sheet-fed). The allowable VOC 

content is further modified through how much alcohol is allowed in the fountain solution. 

The CTG recommends that the control for fountain solution not be applied to sheet-fed 

presses with maximum sheet size of 11X17 inches or smaller, or to any press with total 

fountain solution reservoir of less than 1 gallon. District Rule 4607 has been recently 

amended to incorporate the recommendations of this CTG. 

The CTG recommends the use of cleaning materials with a VOC composite vapor 

pressure less than 10mm Hg at 20o

C or cleaning materials containing less than 70 

weight percent VOC for blanket washing, roller washing, plate cleaners, metering roller 

cleaners, impression cylinder cleaners, rubber rejuvenators, and other cleaners used for 

cleaning a press, press parts, or to remove dried ink from areas around a press. 

Additionally, cleaning materials and used shop towels should be kept in closed 

containers. Current District Rule 4607 has a specific allowable VOC content limit for 

different cleaning operations, which is not directly comparable to a vapor pressure limit. 

The solvent cleaning VOC content limit for solvent cleaning related to flexo and gravure 

printing are less than the recommended VOC content recommended in the CTG. The 

District rule incorporates work practices similar to the CTG. 

4. EPA 453/R-06-003 – Control Techniques Guidelines for Flexible Package 

Printing 

This CTG, promulgated by EPA September 2006, provides control recommendations for 

reducing VOC emissions from inks, coatings, adhesives and cleaning materials used by 

the rotogravure and flexographic printing industries for flexible packaging printing. The 

two approaches to reducing VOC emissions from inks, coatings, and adhesives used in 

the flexible package printing industry are adding or improving add-on emission controls, 

and material reformulation or substitution. 

The primary thrust of the CTG is control of emissions through add-on emission controls. 

As such, the CTG outlines overall control efficiency for presses, depending on the date 

the press was first installed and the date an add-on control was first installed. The 

range of overall control is 65% to 80%. As an alternative to the overall control 

requirements, the CTG also recommends two equivalent VOC content limits for inks 

which can be met by use of low VOC content materials or a combination of materials 

and controls. These VOC content limits are consistent with an 80 percent overall 

emission reduction level and reflect similar control levels as the capture and control 

option. The CTG does not recommend a specific VOC content limit for materials used 

during cleaning, but does recommend certain work practices to limit emissions during 

cleaning. Current District Rule 4607 has a specific allowable VOC content limit for 

different cleaning operations and incorporates work practices similar to the CTG. 
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District Rule 4607 has recently been amended to incorporate those CTG 

recommendations that were less stringent. 

5. EPA 453/R-07-003 – Control Techniques Guidelines for Paper, Film, and Foil 

Coatings 

This CTG provides control recommendations for reducing VOC emissions stemming 

from the use of coatings in paper, film, and foil surface coating operations. Coating 

performed on or in-line with any offset lithographic, screen, letterpress, flexographic, 

rotogravure, or digital printing press is part of a printing process and is not part of the 

paper, film, and foil coating category. Common control techniques for reducing VOC 

emissions from paper, film, and foil surface coatings include pollution prevention 

measures and the operation of emission capture and add-on control systems. 

Overall VOC control efficiency of 90 percent is recommended for each paper, film, and 

foil surface coating line. As an alternative to an overall 90 percent control efficiency, the 

CTG recommends VOC content-based emission limits that are equivalent to 90 percent 

overall control, which can be met by use of low-VOC content materials or combinations 

of materials and controls. EPA recommends the limit of 0.20 kg VOC/kg (0.20 lb 

VOC/lb) solids applied and an additional equivalent limit of 0.067 kg VOC/kg (0.067 lb 

VOC/lb) of coatings as RACT for pressure sensitive tape and label surface coating 

lines. District Rule 4607 has been recently amended to include the recommendations of 

this CTG. 

The CTG does not recommend a specific VOC content limit for materials used during 

cleaning, but does recommend certain work practices to limit emissions during cleaning. 

Current District Rule 4607 has a specific allowable VOC content limit for different 

cleaning operations and includes the CTG-recommended work practices. 

B. EPA – Alternative Control Technology (ACT) 

There is no ACT for this source category. 

C. Standards of Performance for New Stationary Sources (NSPS) 

1. 40 CFR 60 Subpart QQ – Standards of Performance for the Graphic Arts Industry: 

Publication Rotogravure Printing 

This NSPS applies to each publication rotogravure printing press at a facility that 

commenced construction, modification, or reconstruction after October 28, 1980. The 

NSPS does not apply to proof presses. 

The NSPS requires that emitted VOC be no more than 16 percent of the total mass of 

VOC solvent and water used at that facility during any 30-consecutive calendar day 

averaging period. The water used includes only that water contained in the waterborne 
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raw inks and related coatings and the water added for dilution with waterborne ink 

systems. 

The NSPS provision cannot be directly compared to the VOC content limits for inks or 

compared to the control efficiency limits in District Rule 4607. The NSPS is based on 

the volatile (water plus solvent) emissions from the operation as a whole and, therefore, 

it is difficult to determine whether the NSPS and the District rule are equivalent. The 

District rule limits inks and other materials to a specific VOC content in grams VOC per 

liter material, minus water and minus exempt compounds. Further, the District rule has 

a minimum overall capture and control requirement for add-on emission control 

systems. Any comparison for would have to be done on a case-by-case basis for 

individual facilities because the ratio of water to solvent could be different for each 

facility and the solvent-to-water ratio is not directly tied to the VOC content or the 

emission control system control efficiency. 

2. 40 CFR 60 Subpart RR – Standards of Performance for Pressure Sensitive Tape 

and Label Surface Coating Operations 

This NSPS applies to coatings for pressure sensitive tape and labels where the coating 

operations are located at a facility which began construction, modification, or 

reconstruction after December 30, 1980. There are two ways to control emissions – 

through VOC content limit and by specifying the overall capture and control of the addon control device. The VOC content limit is listed in pounds of VOC per pound of 

coatings solids. The alternative overall capture and control required is 90%. 

District Rule 4607 incorporates the VOC content limits as a specific requirement in the 

rule as well as having an overall capture and control efficiency of at least 90% for these 

operations. 

3. 40 CFR 60 Subpart FFF – Standards of Performance for Flexible Vinyl and 

Urethane Coating and Printing 

The affected facility is a facility which began construction, modification, or reconstruction 

after January 18, 1983. The operation subject to the NSPS is rotogravure printers used 

to print or coat flexible vinyl or urethane products. The NSPS requires that the operator 

use inks with a weighted average VOC content less than 1.0 kilogram VOC per kilogram 

ink solids at each affected facility, or, equivalently, to reduce VOC emissions by 85 

percent from the facility. 

District Rule 4607 does not address this source category as a specific sub-category of 

the graphic arts. Gravure printers/coaters are held to an ink VOC content of 300 grams 

per liter of material, minus water and exempt compounds. This is not directly 

comparable to the NSPS VOC content. In lieu of meeting the VOC content limits, 

operators could choose to use a VOC control system to reduce their emissions from 

printing, however, use of the system cannot have emission more than would have 

occurred if the operator used compliant materials. In District Rule 4607, the minimum 
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overall capture and control efficiency is 75% for VOC emission control systems for 

gravure printing/coating other than flexible packaging and publication. It is difficult to 

determine whether the NSPS and the current District rule are equivalent – such 

comparisons would need to be done on a coating-by-coating basis. 

4. 40 CFR 60 Subpart SSS – Standards of Performance for Magnetic Tape Coating 

Facilities 

Subpart SSS applies to coating operations and coating mix preparation operations 

located at a magnetic tape manufacturing facility for which construction, modification, or 

reconstruction began after January 22, 1986. Of the two operations, only the coating 

operations correspond to District Rule 4607 sources. The provisions of this subpart that 

apply to coating operations will be used for this analysis. 

Control of coating VOCs is through a VOC emission control device with overall capture 

and control ranging from 90% to 95%, depending on whether a the operation is new or 

modified/reconstructed and whether the VOC emission control system is control device 

is new or has been modified/reconstructed. 

Because magnetic tape is a special coating on film, magnetic tape manufacturers would 

be considered film coaters for District Rule 4607. As such, they would be subject to an 

overall capture and control efficiency of at least 90%. However, the District has no 

sources that manufacture magnetic tape. Any new source that would begin operations 

would be subjet to the District New and Modified Source Review Rule, which would 

require that the new operation meet this NSPS as a minimum standard. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There are no NESHAPs in 40 CFR 61 directly applicable to sources subject to District 

Rule 4607. There are three MACTs in 40 CFR 63 that apply to sources subject to 

District Rule 4607. 

1. 40 CFR 63 Subpart KK – National Emission Standards for the Printing and 

Publishing Industry 

This MACT applies to major sources of hazardous air pollutants (HAPs) that perform 

rotogravure printing for the publication, product, or packaging markets. It also applies to 

wide-web flexographic printing that is a major source of HAPs. 

For publication rotogravure, emissions of HAPs are limited to no more than 8% of the 

total volatile matter used each month. Operators may comply with this limit with an addon emission control system having overall capture and control efficiency of at least 92%, 

by substitution of non-HAP materials for organic HAP, or by a combination of both. 
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In the case of product rotogravure, packaging rotogravure, and wide-web flexographic 

printing operations, the emission of HAPs has three numeric limits. The first limit is that 

emissions are limited to no more than 5% of the organic HAP applied for the month. 

The second limits is that the HAPs emissions are no more than 4% of the total mass of 

inks, coatings, varnishes, adhesives, primers, solvents, reducers, thinners, and other 

materials applied during the month. The third limit is that HAPs emissions are no more 

than 20% of the mass of solids applied during the month. Operators may use an 

emission control device with overall HAP control efficiency of at least 95% and that 

limits the emissions to no more than would have been emitted had they complied with 

all three numeric limits. 

HAPs and VOCs are not directly comparable. The VOC contents in District Rule 4607 

are given in units of pounds of VOC per liter of material, minus water and minus exempt 

compounds. Subpart KK has different units of measure for HAPs. Not only are the 

units of measure different, a given HAP compound may not be photo-chemically 

reactive, meaning that the HAP is an exempt compound and not counted as a VOC. 

Thus, the NESHAP does not define applicable RACT for these sources. 

2. 40 CFR 63 Subpart JJJJ – National Emission Standards for Hazardous Air 

Pollutants: Paper and Other Web Coating 

This subpart of the CFR applies to facilities that perform web coating and the facility is a 

major source of HAPs. Exemptions include web coating done with lithography, screen 

printing, letterpress, and narrow-web flexographic printing as well as any web coating 

subject to a different subpart of 40 CFR 63. Research and laboratory equipment is also 

exempt. 

The subpart limits the emission of HAPs relative to the amount of HAPs. Because the 

particular HAPs emitted may not be an exempt compound and not, therefore, a VOC, 

the emission limits in this MACT are not directly comparable to VOC content limits. 

HAPs and VOCs are not directly comparable. The VOC content limits in District Rule 

4607 are given in units of pounds of VOC per liter of material, minus water and minus 

exempt compounds. Thus, the NESHAP does not define applicable RACT for these 

sources. 

3. 40 CFR 63 Subpart OOOO – National Emission Standards for Hazardous Air 

Pollutants: Printing, Coating, and Dyeing of Fabrics and Other Textiles 

40 CFR 63 Subpart OOOO applies to facilities that are major HAPs sources that coat, 

print, dye, slash, or finish fabrics and other textiles. There are five exemptions: if the 

particular operation does not use materials with organic HAPs, if the operations occur at 

a research or laboratory, if the materials are used internally (not for commerce), if the 

operations are conducted at ambient temperatures (no heaters or dryers), and if the 

facility is located on a US Armed Forces installation. 
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HAPs and VOCs are not directly comparable. The VOC contents in District Rule 4607 

are given in units of pounds of VOC per liter of material, minus water and minus exempt 

compounds. Subpart KK has different units of measure for HAPs. Not only are the 

units of measure different, a given HAP compound may not be photo-chemically 

reactive, meaning that the HAP is an exempt compound and not counted as a VOC. 

Thus, the NESHAP does not define applicable RACT for these sources. 

How does District Rule 4607 compare to rules in other air districts?

District staff compared VOC content limits, optional control requirements, and work 

practice standards in District Rule 4607 to comparable requirements in rules from the 

following California nonattainment areas: 

• South Coast AQMD Rule 1128, as amended March 1996 

• South Coast AQMD Rule 1130, as amended October 1999 

• South Coast AQMD Rule 1130.1, as amended December 1996 

• South Coast AQMD Rule 1171, as amended February 2008 

• Bay Area AQMD Regulation 8 Rule 4, as amended October 2002 

• Bay Area AQMD Regulation 8 Rule 12, as amended December 1995 

• Bay Area AQMD Regulation 8 Rule 20, as amended November 2008 

• Sacramento Metropolitan AQMD Rule 450, as amended March 2000 

• Sacramento Metropolitan does not have a prohibitory rule for paper, film, foil or 

fabric coating. 

• Ventura County APCD Rule 74.19, as amended November 2003 

• Ventura County APCD Rule 74.19-1, as amended November 2003 

• Ventura County APCD Rule 74.3, as amended December 1991 

A. South Coast AQMD Rule 1128 (Paper, Fabric and Film Coating Operations) 

South Coast AQMD Rule 1128 applies to all persons applying coatings or wash primers 

to paper, fabric, or film substrates. Coating VOC content is limited to 265 grams VOC 

per liter of coating less water and less exempt compounds, as applied. Plastisol is 

limited to 20 grams VOC per liter of material less water and less exempt compounds, as 

applied. Wash primer is limited to 365 grams VOC per liter of material used. In lieu of 

using compliant materials, an operator may install and operate an approved VOC 

emission control system. The collection portion of the system must collect at least 90% 

of the VOC vapors and the control portion of the system must destroy at least 95% of 

the collected vapors or the control device emit no more than 50 parts per million without 

dilution. 

District Rule 4607 VOC content limits for materials used for paper, fabric, and film are 

similar to South Coast Rule 1128 for coatings. The overall capture and control 

efficiency for these operations in at least 90% which is higher than the overall capture 

and control of the South Coast rule (90% times 95% or 85.5%). 
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B. South Coast AQMD Rule 1130 (Graphic Arts) 

South Coast Rule 1130 applies to persons performing graphic arts operations or who 

solicit, specify, offer for sale, sell, or distribute graphic arts materials for use in the South 

Coast AQMD. 

If an operation is subject to the control requirements of the rule, there are VOC content 

limits. Coatings and inks have a VOC content limit of 300 grams VOC per liter material, 

minus water and exempt compounds, as applied; except certain flexographic inks. The 

VOC content limit for flexographic ink applied on a non-porous substrate is the same as 

for other inks and coatings – 300 grams per liter minus water and exempt compounds. 

The VOC content limit for flexographic ink on a porous substrate is 225 grams per liter 

minus water and exempt compounds, as applied. Adhesives and web-splicing 

adhesives have a limit of 150 grams per liter minus water and exempt compounds. The 

VOC content of fountain solution is limited to no greater than 80 grams per liter of 

material, or if a refrigerated chiller is used, no greater than 100 grams per liter of 

material. Matte finish and metallic inks have VOC content limits, however, the limits 

apply only at facilities with potential to emit and actual emissions not more than ten tons 

per year of VOCs. In addition to specific VOC content limits, the operator has a limit on 

the total quantity of matte finish and metallic coating used each day and each year. If a 

source does not meet the daily/annual coatings usage or total facility emission 

requirements for matte finish and metallic coatings, the general coating VOC content 

limit of 300 gram per liter (less water and exempt compounds) applies to these coatings. 

In place of using compliant materials, an operator may utilize a VOC control system. 

The overall (capture and) control efficiency must be at least 85% for publication gravure 

and 75% for all other graphic arts operations. An approved emission control system 

must reduce emissions to a level equal to or lower than that which would have been 

achieved through use of compliant or meets the applicable overall control efficiency 

limits, whichever results in lower emissions. 

Except as noted in the exemption section, a person is not allowed to sell or specify a 

graphic arts material with VOC content greater than the VOC content in the rule within 

the South Coast AQMD boundaries.

District Rule 4607 mirrors the VOC content limits in South Coast AQMD Rule 1130 with 

a few exceptions – the use metallic inks/matte finish inks in flexo printing. The VOC 

content limits for matte finish and metallic inks in Rule 4607 apply regardless of the size 

of the facility. In contrast, the South Coast rule applies only to facilities that are not 

major sources for VOC. In both rules, use of these specialty inks is limited on a per-day 

and per-year basis. District Rule 4607 also has an even lower VOC content for flexo 

metallic ink and matte finish inks for facilities that emit at least ten tons per year of 

VOCs. 
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C. South Coast AQMD Rule 1130.1 (Screen Printing) 

This rule applies to persons performing screen printing operations or who sell, 

distribute, or require the use of screen printing materials in the South Coast AQMD. 

South Coast AQMD Rule 1130.1 divides screen-printing operations into several special 

groups as well as dividing by substrate. The VOC content limits range between 400 

and 850 grams VOC per liter, less water and less exempt compounds, as applied. The 

total usage of high-VOC serigraph inks cannot exceed 10 percent of the total usage of 

screen printing materials applied on all serigraphs at a facility, on a monthly basis, 

unless an approved emission control system is used to reduce emissions from highVOC serigraph inks by an equivalent or greater level to that which would have been 

achieved by the use of an ink containing 400 grams VOC per liter (less water and 

exempt compounds).

In lieu of complying with the VOC content limits for graphic arts material, an operator 

may install and operate a VOC emission control system. If an operator chooses to 

utilize a VOC emission control system, the control device must destroy at least 95% of 

the collected vapors and the total emissions from the operation must not exceed the 

amount of VOC that would have been emitted if the operator had used compliant 

material. Except as noted in the exemptions, a person cannot specify that an operator 

use of a material that has a higher VOC content than in the rule nor can a person sell or 

distribute high-VOC material within the South Coast AQMD. 

District Rule 4607 VOC content limits for screen printing operations are equal to or less 

than the VOC content limits in South Coast AQMD Rule 1130.1. District Rule 4607 

limits the VOC content of all screen printing inks and coatings to 400 grams per liter. 

Adhesives have a limit of 150 grams per liter and resists have a limit of 600 grams per 

liter. The limits are for the material as applied, less water and exempt compounds. The 

South Coast rule allows higher VOC content for coatings used in certain specialty 

markets. District Rule 4607 has a specific overall capture and control efficiency for 

VOC emission control systems as well as limiting total emissions. If an operator must 

meet both conditions, it is possible that the emissions from the process would be less 

than if the operator had used compliant coatings to meet the rule requirements. The 

South Coast AQMD rule does not have a specific minimum overall capture and control 

efficiency, although the rule does require 95% destruction of the vapors collected. 

D. South Coast AQMD Rule 1171 (Solvent Cleaning Operations) 

South Coast AQMD has a separate rule for all solvent cleaning. This rule applies to all 

persons who use solvent materials in solvent cleaning operations during the production, 

repair, maintenance, or servicing of parts, products, tools, machinery, equipment, or 

general work areas; all persons who store and dispose of these materials used in 

solvent cleaning operations; and all solvent suppliers who supply, sell, or offer for sale 

solvent cleaning materials for use in solvent cleaning operations. For this analysis, the 

focus will be on those cleaning operations performed by South Coast sources that 

would be subject to District Rule 4607 if they were located within the District’s 

boundaries. 
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In South Coast Rule 1171, the VOC content limits applicable to sources similar to 

District Rule 4607 depend on the equipment to be cleaned and range from 25 grams 

per liter to 100 grams per liter. In lieu of complying with the VOC content limits, 

operators may utilize an approved VOC emission control system in association with the 

solvent-cleaning operation. For graphic arts and screen printing, the collection portion 

of the control system must collect at least 70% of the emissions generated and the 

control portion of the system must reduce emissions fro the emission collection system 

by at least 95%. Solvents and cleaning cloths and paper towels should be stored in 

closed, non-absorbent, non-leaking containers. 

South Coast AQMD Rule 1171 does allow certain flexographic operations a slightly 

higher VOC content for cleaning materials compared to District Rule 4607. The VOC 

content limits, the control requirements, and the work practices in South Coast Rule 

1171 are essentially identical to District Rule 4607 for graphic arts operations because 

the solvent cleaning portion of Rule 4607 was recently amended to upgrade the rule to 

reflect best available control technology. 

E. Bay Area AQMD Regulation 8 Rule 4 (General Solvent and Surface Coating 

Operations) 

The purpose of this Rule is to limit emissions of VOCs from the use of solvents and 

surface coatings in any operation other than those specified by other rules of Regulation 

8. The provisions of this Rule apply to operations like model making, printed circuit 

board manufacturing and assembly, electrical and electronic component manufacturing, 

surface coating of test panels, training facilities where the application of coating is for 

training purposes, stencil coatings, low usage coating activities exempt from other 

Regulation 8 Rules, coatings specifically exempt from other Regulation 8 Rules or 

solvent usage not specified by other Regulation 8 Rules. Operations that are subject to 

the requirements of other rules in Regulation 8 are exempt from this rule. 

If an operation is subject to Regulation 8 Rule 4, the operator can comply by meeting 

one of the following requirements: 

o Emit no more than 5 tons VOC per year from any source; 

o Control emissions with an approved emission control device with an overall 

capture and control efficiency of 85%. If the control device is an incinerator, the 

VOC destruction efficiency must be at least 90%; or 

o The coating operation uses coating with VOC content of 420 grams per liter, as 

applied. 

To minimize solvent evaporative losses, the Bay Area rule requires work practices in 

addition to VOC content limits. Solvents used in the cleanup of spray equipment is 

limited to VOC content of 50 grams per liter unless the atomizing air for the equipment 

is turned off or a spray gun washer is used. Solvents used for surface preparation are 

limited to a VOC content of 50 grams per liter. An operator may forego the work 

practices or use higher VOC-content material if the emissions from the cleaning 
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operations are controlled by an approved emission control system with overall capture 

and control efficiency of 85%. 

Bay Area AQMD Regulation 8 Rule 4 is a rule for “other” coating sources. As such, it is 

difficult to compare the Bay Area AQMD rule directly with District Rule 4607. The Bay 

Area AQMD coating VOC content limit is higher than all coatings in District Rule 4607 

except metallic inks, matte finish inks, and screen-printing resists. The Bay Area AQMD 

rule’s overall capture and control efficiency is generally higher than sources are required 

to meet in current District Rule 4607. However, the sources that would be subject to 

Bay Area AQMD’s rule would be small sources and most likely meet the requirements 

of the rule through total emissions from the facility. District Rule 4607 does not exempt 

small facilities from the control requirements of the rule, therefore, District Rule 4607 

may be more stringent than Bay Area Regulation 8 Rule 4 for certain sources. 

F. Bay Area AQMD Regulation 8 Rule 12 (Paper, Fabric, and Film Coating) 

Bay Area AQMD Regulation 8 Rule 12 limits VOC emissions from the application of 

coatings and adhesives to paper, fabric or films. The rule does not apply to operations 

subject to Bay Area AQMD Regulation 8 Rule 20. The rule doesn’t apply to any coating 

line which emits less than 6.5 kg (14.3 pounds) per day. Coatings and adhesive are 

limited to a VOC content of less than 265 grams per liter of coating applied, excluding 

water. In lieu of meeting the VOC content limit, the operator may use an approved 

emission control system that reduces VOC emissions to less than 120 grams per liter of 

coating applied, excluding water. This equates to approximately 55% overall capture 

and control efficiency for operators choosing to utilize a VOC emission control system. 

The Bay Area rule does not have a specific VOC content limit for cleaning materials 

used for surface preparation and cleanup. Instead, there are work practices that limit 

VOC emissions in the storage and mixing of VOC-containing materials as well as during 

solvent cleaning operations. 

District Rule 4607 has the same VOC content limits for the coating and adhesive as the 

Bay Area rule. Compared to the Bay Area AQMD’s 55% overall control efficiency, 

current District Rule 4607 has a higher overall control efficiency of 90%. District Rule 

4607 also incorporates the same work practice as the Bay Area AQMD rule, as well as 

a few additional work practices related to cleaning with solvents. For example, the 

District rule includes allowing only certain application techniques for applying the 

cleaning solvent to minimize evaporations – the Bay Area AQMD does not. In addition 

to work practices, District Rule 4607 has specific VOC content limits for cleaning 

materials. An operator can choose to use high-VOC content material for cleaning if the 

operator has a VOC emission control system that controls emissions from the cleaning 

operation by at least 90%. 
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G. Bay Area AQMD Regulation 8 Rule 20 (Graphic Arts Printing and Coating 

Operations) 

The purpose of this Rule is to limit the VOC emissions from graphic arts operations and 

graphic arts lines. Any facility which emits less than 34 kilograms (175 pounds) of VOC 

in any month from graphic arts operations is exempt from the rule, except for recordkeeping. Laboratory and experimental operations are also exempt from control 

requirements. 

For flexography (flexo), lithography, gravure, and letterpress, the VOC content of 

coatings and web-splicing adhesive is limited to 300 grams per liter less water as 

applied. Other adhesives are limited to a VOC content limit of 150 grams per liter, less 

water as applied. For inks other than flexo ink on a porous substrate, the VOC content 

limit is 300 grams per liter less water and exempt solvents, as applied. Flexo ink 

applied to a porous substrate has a VOC content limit of 225 grams per liter (less water 

and exempt solvents). Fountain solution is limited to 8% VOC. Screen printing inks and 

coatings are limited to 400 grams per liter less water, as applied. Adhesives used in 

screen printing operations are limited to 150 grams per liter, less water, as applied. 

Solvents used for claning are limited to a VOC content of 25 grams per liter to 100 

grams per liter, depending on the printing technology and process. In addition to the 

cleaning product requirements, this rule also has work practices to minimize VOC 

emissions. 

In lieu of complying with the VOC content limits for materials, an operator may install 

and operate a VOC emission control system. The minimum overall capture and control 

efficiency is 75% on a mass basis. 

For most printing/coating operations, Bay Area AQMD Regulation 8 Rule 20 has VOC 

content limits that are identical to District Rule 4607. For one screen printing material – 

screen resists - the Bay Area AQMD rule is silent. District Rule 4607 has a VOC 

content limit of 600 grams per liter, less water and exempt compounds, as applied. For 

emission control systems, the Bay Area rule has a lower required control efficiency for 

certain printing technologies. 

The Bay Area AQMD rule and District Rule 4607 incorporate the same VOC content 

limits for cleaning solvents. District Rule 4607 also incorporates the same work practice 

as the Bay Area AQMD rule, as well as a few additional work practices related to 

cleaning with solvents. For example, the District rule includes allowing only certain 

application techniques for applying the cleaning solvent to minimize evaporations – the 

Bay Area AQMD does not. 

H. Sacramento Metropolitan AQMD Rule 450 (Graphic Arts Operations) 

Sac Metro AQMD Rule 450 applies to graphic arts operations and to any screen printing 

operation at any stationary source regardless of the substrate. The requirement of this 
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rule, including the VOC limits in Section 301.1 for adhesives, shall also apply to 

adhesives used by graphic arts operations unless exempt. The cleaning and storage 

requirements in Section 302 shall apply to all graphic arts operations at any stationary 

source including those exempt pursuant to Section 110 of this rule. The requirements of 

Sac Metro Rule 440 (Organic Solvents), does not apply to operations subject to this 

rule. 

The VOC content requirements for inks, coatings, and adhesives does not apply to any 

graphic arts operation at a stationary source which either has actual VOC emissions of 

less than or equal to 60 pounds per month from all graphic arts operations and cleaning 

materials; or receives a permit that limits the potential to emit, to not more than 175 

pounds of VOC per month from all graphic arts operations and cleaning materials. 

Sac Metro AQMD Rule 450 has the following exemptions: 

o Gravure printing operations. 

o Business and personal printers. 

o Prepress operations, including film photo processors and plate photo processors. 

o Aerosol adhesives used by screen printers if the adhesives comply with Sac 

Metro Rule 460 (Adhesives and Sealants) 

o Aerosol adhesives used in graphic arts operations provided that the total VOC 

emissions from the facility are less than 660 pounds per month 

VOC content limits for graphic arts operations that are not screen printing operations 

are 300 grams VOC per liter for coatings and inks and 150 grams per liter for 

adhesives. The VOC content limits are less water and less exempt compounds. The 

VOC content of fountain solution is limited to no greater than 80 grams per liter of 

material, or if a refrigerated chiller is used, no greater than 100 grams per liter of 

material. If the fountain solution has a density of 1,000 grams per liter, the 80 grams 

per liter limit represents about 8% by volume and the 100 grams per liter limit 

represents about 10% by volume. This rule also mandates a specific temperature for 

the chilled fountain solution. 

For solvent cleaning, Sac Metro AQMD limits composite partial pressure in addition to 

VOC content for certain cleaning activities and in lieu of VOC content for other cleaning 

activities. The range of VOC content is 72 to 810 grams per liter. Composite partial 

pressure ranges from 3 to 33 millimeters mercury at 20 degrees centigrade. To 

minimize solvent evaporation, operators are required to cover containers of VOCcontaining material and to place material in covered containers. Additionally, the total 

amount of solvent used for lithographic and letter press printing – other cleaning cannot 

exceed 15% of the total monthly usage of blanket wash cleaning and roller wash 

cleaning. 

In lieu of complying with the VOC content limits for printing materials or for cleaning 

operations, an operator may use an approved emission control system with capture 

efficiency of at least 70% and a control device efficiency of at least 95%. This translates 

to an overall capture and control efficiency of 67%. 
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A person cannot supply, sell, solicit, or offer for sale, any noncompliant material for use 

in graphic arts operations. The prohibition applies to any graphic arts material which will 

be applied at any physical location within the District. 

District Rule 4607 mirrors Sac Metro Rule 450 for the VOC content of non-screen 

printing inks, coatings, and adhesives. These VOC content limits apply to gravure 

printing operation, which the Sac Metro rule exempts. District rule limits all fountain 

solutions to a VOC content of 8%. The Sac Metro rule allows a higher VOC content 

limit for refrigerated/chilled fountain solution. Screen printing inks and coatings in the 

Sac Metro AQMD rule range from 300 to 800 grams per liter, as applied less water and 

exempt compounds. District Rule 4607 has a VOC content limit of 400 grams per liter 

for inks and coatings and 150 grams per liter for adhesives. Sac Metro rule has one 

screen printing coating that is lower than District Rule 4607 – web -ed wallpaper. 

District staff is not aware that such operations exist within the District’s boundaries. For 

one screen printing material – screen resists - the Sac Metro AQMD rule is silent – 

District Rule 4607 has a VOC content limit of 600 grams per liter, less water and exempt 

compounds, as applied for this material. 

Since the Sac Metro AQMD rule allows composite partial pressure as an alternative to 

VOC content for certain cleaning solvents, it is not possible to compare the solvent 

cleaning material limits directly. Low vapor pressure material may or may not be highVOC content. In general, however, District Rule 4607 has lower numeric limits for VOC 

content – composite vapor pressure is not used. For solvent cleaning, current District 

Rule 4607 has a VOC content limit range of 25 to 100 grams VOC per liter material 

beginning in January 2010. This range is lower than the numeric limits in the Sac Metro 

AQMD rule. District Rule 4607 also incorporates the same work practices as the Sac 

Metro AQMD rule to minimize solvent evaporation during cleaning operations. 

I. Ventura County APCD 74.3 (Paper, Fabric, and Film Coating Operations) 

The provisions of this rule apply to any application process involving the coating of 

paper, fabric or film. Operators have three ways to comply with the rule: 

o Use coating material, as applied, with less than 265 grams ROC per liter coating 

less water and exempt compounds. 

o Emissions from the operation are less than 120 grams per liter coating applied, 

less water and exempt compounds, on a 24-hour average basis. 

o Install and utilize an emission control system that reduces emissions by a 

combined capture and destruction efficiency of at least 90%. 

If the coating applied contains more than 1200 grams of ROC per liter of coating 

applied, less water and less exempt solvent, then, in addition to the emission control 

system, emissions are limited to 120 grams of ROC per liter of coating applied, less 

water and exempt solvent, using a rolling 24 hour average. 
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Solvent evaporation is minimized through requiring covered, non-leaking containers for 

solvent-containing materials – a work practice. Solvents used in clean-up are limited to 

200 grams ROC per liter material or the operator Install and utilize an emission control 

system that reduces emissions by a combined capture and destruction efficiency of at 

least 90%. 

Current District Rule 4607 VOC content limits for inks and coatings in paper and fabric 

are identical to the Ventura County APCD VOC content limits. Operators do not have 

the option of averaging over a 24-hour period to comply with Rule 4607. If an operator 

uses a VOC emission control system to comply with the rule limits, there is a specific 

overall capture and control efficiency of at least 86%. Since District Rule 4607 is 

undergoing amendment, the proposed efficiency will be increased to 90%, which 

matches the Ventura County APCD combined capture and destruction efficiency. 

For solvent cleaning, current District Rule 4607 has a VOC content limit range of 25 to 

100 grams VOC per liter material beginning in January 2010. This range is significantly 

lower than the 200 gram per liter limit in the Ventura County APCD rule. As with the 

Ventura County APCD rule, operators can use higher VOC content material for cleaning 

if the operation is within an approved VOC emission control system with an overall 

capture and control efficiency of at least 86%. This control efficiency will be increased 

to 90% as part of a rule amendment project. District Rule 4607 also incorporates the 

same work practice as the Ventura County APCD rule, as well as a few additional work 

practices related to cleaning with solvents designed to minimize solvent evaporation 

during cleaning. The public hearing to adopt the amendments to Rule 4607 is expected 

in December 2008. 

J. Ventura County APCD Rule 74.19 (Graphic Arts) 

Ventura County APCD rule applies to any person who applies any ink, coating, 

adhesive, fountain solution, or solvent containing Reactive Organic Compounds (ROC) 

as part of a graphic arts operation. The rule also applies to any person in Ventura 

County who manufactures any ink, coating, adhesive, fountain solution, or solvent 

containing VOC sold for use in a graphic arts operation in Ventura County. The ROC 

content limits of Ventura County APCD Rule 74.19 do not apply to any stationary source 

that emits less than 200 pounds of ROC per year from graphic arts operations. 

For sources subject to the Ventura County APCD rule requirements, inks and coatings 

are limited to a ROC content of 300 grams per liter and adhesives to 150 grams per liter 

– both limits are less water and exempt compounds. Flexographic inks on porous 

substrates have a ROC content limit of 225 grams per liter less water and exempt 

compounds. If the material contains less than 120 grams of solids per liter of material, 

the ink/coating/adhesive limits are the same, but determined as grams of ROC per liter 

of material – water and exempt compounds are not subtracted. 

The ROC content of fountain solution is limited to no greater than 80 grams per liter of 

material, or if a refrigerated chiller is used, no greater than 100 grams per liter of 
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material. If the fountain solution has a density of 1,000 grams per liter, the 80 grams 

per liter limit represents about 8% by volume and the 100 grams per liter limit 

represents about 10% by volume. 

For solvent cleaning, Ventura County APCD limits composite partial pressure in addition 

to ROC content for certain cleaning activities and in lieu of ROC content for other 

cleaning activities. The range of ROC content is 50 to 950 grams per liter. Composite 

partial pressure ranges from 3 to 33 millimeters mercury at 20 degrees centigrade. 

Operators are prohibited from using methylene chloride for cleaning purposes. 

Methylene chloride is usually considered an exempt compound. 

District Rule 4607 mirrors the Ventura County APCD rule for inks, coatings, and 

adhesives for graphic arts operations. Since the Ventura County APCD rule allows 

composite partial pressure as an alternative to VOC content for certain cleaning 

solvents, it is not possible to compare the solvent cleaning material limits directly. Low 

vapor pressure material may or may not be have high-VOC content. In general, 

however, District Rule 4607 has lower numeric limits for VOC content – composite 

vapor pressure is not used. For solvent cleaning, current District Rule 4607 has a VOC 

content limit range of 25 to 100 grams VOC per liter material beginning in January 2010. 

This range is lower than the numeric limits in the Ventura County APCD rule. As with 

the Ventura County APCD rule, operators can use higher VOC content material for 

cleaning if the operation is within an approved VOC emission control system with an 

overall capture and control efficiency of at least 86%. This control efficiency will be 

increased to 90% as part of a rule amendment project. District Rule 4607 also 

incorporates the same work practice as the Ventura County APCD rule, as well as a few 

additional work practices related to cleaning with solvents designed to minimize solvent 

evaporation during cleaning. The public hearing to adopt the amendments to Rule 4607 

is expected in December 2008. 

K. Ventura County APCD Rule 74.19-1 (Screen Printing Operations) 

Ventura County APCD Rule 74.19-1 applies to any person who uses any ink, coating, 

adhesive, resist, or solvent containing ROC (Reactive Organic Compounds) in a screen 

printing operation. The rule also applies to any person in the District who manufactures, 

specifies the use of, sells, or offers for sale any ink, coating, adhesive, resist, or solvent 

containing ROC for use in a screen printing operation in the Ventura County APCD. 

The ROC content limits of Ventura County AQCD Rule 74.19-1 do not apply to any 

stationary source that emits less than 200 pounds of ROC per year from screen printing 

operations. Emissions from aerosol products, cold cleaners, vapor degreasers, graphic 

arts operations used exclusively for research, classroom instruction in schools, 

laboratory analysis, or determination of product quality and commercial acceptance are 

not included in the exemption determination. 

In addition to the above exemption, screen printing operations used exclusively for 

research, classroom instruction in schools, laboratory analysis, or determination of 
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product quality and commercial acceptance are exempt, provided that total ROC 

emissions are less than 200 pounds per year. The production of electronic circuits is 

specifically exempt from the ROC limits of the rule. The adhesive ROC limit does not 

apply to aerosol platen adhesive if the aerosol platen adhesive usage is 150 ounces per 

month or less. 

Screen printing inks, coatings and adhesives are limited to a ROC content of 400 grams 

per liter; metallic inks and resists are limited to 600 grams per liter; and extreme 

performance inks and coatings are limited to 800 grams per liter; water slide decals and 

ceramic decals are limited to 800 grams per liter. These limits are less water and 

exempt compounds. In lieu of meeting the ROC limits, an operator may install and 

operate an emission control system with an overall efficiency of at least 75%. 

Additionally, all drying ovens must be vented to the control system and the incinerator 

must be continuously monitored. 

No one is allowed to sell distribute, or require any other person to use any ROCcontaining material subject to the provisions of this rule which, when thinned or reduced 

according to the manufacturer's recommendation for application and use, does not meet 

the applicable ROC limits required by this rule for the specific application, except if the 

person operates an approved emission control system or the facility emissions are less 

than 200 pounds of ROC per year. 

For solvent cleaning, Ventura County APCD limits composite partial pressure in addition 

to ROC content for certain cleaning activities and in lieu of ROC content for other 

cleaning activities. The range of ROC content is 200 to 1070 grams per liter. 

Composite partial pressure ranges from 5 to 25 millimeters mercury at 20 degrees 

centigrade. 

District Rule 4607 limits the VOC content of screen printing inks and coatings to 400 

grams per liter. Adhesives have a limit of 150 grams per liter and resists have a limit of 

600 grams per liter. The limits are for the material as applied, less water and exempt 

compounds. The Ventura County rule allows higher VOC content for coatings used in 

certain specialty markets. As with the Ventura County APCD rule, operators can use 

higher VOC content material for coating, of printing if the operation is within an 

approved VOC emission control system with an overall capture and control efficiency of 

at least 67%. This control efficiency will be increased to 75% as part of a rule 

amendment project. 

Since the Ventura County APCD rule allows composite partial pressure as an 

alternative to VOC content for certain cleaning solvents, it is not possible to compare 

the solvent cleaning material limits directly. Low vapor pressure material may or may 

not be high-VOC content. In general, however, District Rule 4607 has lower numeric 

limits for VOC content – composite vapor pressure is not used. For solvent cleaning, 

current District Rule 4607 has a VOC content limit range of 25 to 100 grams VOC per 

liter material beginning in January 2010. This range is lower than the numeric limits in 

the Ventura County APCD rule. District Rule 4607 also incorporates the same work 
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practices as the Ventura County APCD rule to minimize solvent evaporation during 

cleaning. Operators are also allowed to use high-VOC content material if the cleaning 

operation is controlled with a VOC emission control system. This allows operators 

operational flexibility without increasing VOC emissions. The Ventura County APCD 

rule is silent as to whether operators have this option. The public hearing to adopt the 

amendments to Rule 4607 is expected in December 2008. 

Conclusion

After careful evaluation of federal rules or regulations covering emissions from this 

source category as well as prohibitory rules in other California nonattainment areas, 

District staff concludes that District Rule 4607 satisfies RACT for graphic arts operations 

as well as for paper, film, foil and fabric. 
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Rule 4610 – Glass Coating Operations 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

VOC 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 

(Source: District 2007 Ozone Plan) 

District Rule 4610 Description

The purpose of this rule is to limit the emissions of volatile organic compounds (VOCs) 

from the coating of glass products. 

The following categories of operations are exempt from the rule requirements: (a) touchup and repair coatings; (b) stencil coatings applied on clear or transparent substrates; 

(c) manufacturer performance testing of coatings; (d) aerosol coating products. 

The rule requires that the VOC contents of coatings applied to glass shall not exceed 

the following limits: (a) single-component general coating - 2.3 lb/gallon; (b) dualcomponent general coating - 3.5 lb/gallon; (c) mirror backing applied by curtain coating 

- 4.2 lb/gallon; (d) mirror backing applied by roll coating - 3.6 lb/gallon; (e) optical 

coatings - 6.7 lb/gallon; (f) electricity-dissipating and shock-free coatings - 3.0 lb/gallon; 

and (g) metallic coatings - 3.5 lb/gallon. 

The rule restricts coating application methods to electrostatic application, curtain/flow 

coater, roll coater, dip coater, hand application methods, and high-volume, low-pressure 

(HVLP) spray. 

The rule also provides an option to use an emissions control device in lieu of complying 

with VOC content limits and coating application methods. Control devices used must 

have a capture efficiency of at least 90% and a destruction efficiency of at least 95%. 

Records of coating operations must be maintained and retained for at least five years. 

Operators opting to use an emissions control device must maintain records of 

parameters needed to demonstrate proper operation of the control device. 

How does District Rule 4610 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

There is no CTG for this category. 
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B. EPA – Alternative Control Technology (ACT) 

There is no ACT for this category. 

C. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS for this category. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There is no NESHAP or MACT for this category. 

How does District Rule 4610 compare to rules in other air districts?

District staff compared emission limits, optional control requirements, and work practice 

standards in District Rule 4610 to comparable requirements in rules from the following 

California nonattainment areas: 

• South Coast AQMD Rule 1145 (amended 12/3/2004) 

• Bay Area AQMD Regulation 8 Rule 4 (adopted 10/16/2002) 

• Sacramento Metro AQMD (no applicable rule) 

• Ventura County APCD (no applicable rule) 

A. South Coast AQMD Rule 1145 

 

The purpose of South Coast AQMD rule 1145, Plastic, Rubber, Leather, and Glass 

Coatings, is to reduce volatile organic compounds (VOC) emissions from the application 

of coatings to any plastic, rubber, leather, or glass products. 

The rule exempts the following categories of operations: (a) touch-up and repair 

coatings; (b) stencil coatings applied on clear or transparent substrates; (c) 

manufacturer performance testing of coatings; (d) aerosol coating products, (e) clear or 

translucent coatings, (f) any individual coating category used in volumes less than 50 

gallons in any one year, provided that the total usage of all such coatings does not 

exceed 200 gallons per year per facility, (g) mask coatings less than 0.5 millimeter thick 

(dried) if the area coated is less than 25 square inches, (h) mask coatings that are less 

than 0.5 millimeter thick (dried) and/or the area coated is more than 25 square inches, 

provided that a written petition that demonstrates compliant coatings are not available is 

submitted to and written approval is granted by the Executive Officer, (i) EMI/RFI 

shielding coatings, (j) Heparin-benzalkonium chloride (HBAC)-containing coatings 

applied to medical devices, provided that the total usage of all such coatings does not 

exceed 100 gallons per year, per facility, and (k) airbrush operations using 5 gallons or 

less per year are exempt from application method restrictions. 
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The rule stipulates that the VOC contents of coatings applied to glass shall not exceed 

the following limits: (a) single-component general coating – 1.0 lb/gallon; (b) dualcomponent general coating – 1.0 lb/gallon; (c) mirror backing applied by curtain coating 

- 4.2 lb/gallon; (d) mirror backing applied by roll coating - 2.6 lb/gallon; (e) optical 

coatings - 0.4 lb/gallon; (f) electricity-dissipating and shock-free coatings - 3.0 lb/gallon; 

and (g) metallic coatings - 3.5 lb/gallon. 

The rule restricts coating application methods to electrostatic application, curtain/flow 

coater, roll coater, dip coater, hand application methods, and high-volume, low-pressure 

(HVLP) spray. 

The rule also provides an option to use an emissions control device in lieu of complying 

with VOC content limits and coating application methods. Control devices used must 

have a capture efficiency of at least 90% and a destruction efficiency of at least 95%. 

The rule requires maintenance of daily or monthly coatings usage activities. Records 

must be retained for at least two years. 

South Coast AQMD Rule 1145 is more stringent than District Rule 4610 in the 

requirements for VOC contents of glass coatings. Whereas the two rules have similar 

VOC content limits for three categories of coatings (flow/curtain-coated mirror backing, 

electricity dissipating and metallic), South Coast AQMD Rule 1145 has more stringent 

VOC content limits for four categories (one- and two-component general coatings, 

rolled-on mirror backing, and optical). 

There is no significant difference between the two rules under the exemptions; 

application methods and alternative emissions control methods. South Coast AQMD 

Rule 1145 includes a longer list of exemptions, but this is probably only because it 

covers coatings for plastic, rubber, leather and glass while District Rule 4610 addresses 

only glass coatings. 

District Rule 4610 is more stringent in the record keeping requirement because it 

requires records to be retained for five years, while South Coast AQMD Rule 1145 

requires only a two-year retention period. 

With the exception of the VOC content limits, the two rules are only slightly different or 

similar in all comparison categories. South Coast AQMD Rule 1145 has more stringent 

VOC content limits, and is therefore more stringent than District Rule 4610 overall. 

B. Bay Area AQMD Regulation 8 Rule 4

 

The purpose of Bay Area AQMD Regulation 8 Rule 4, General Solvent and Surface 

Coating Operations, is to limit emissions of volatile organic compounds from the use of 

solvents and surface coatings in operations other than those covered by other rules of 
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Regulation 8. Since it is not covered by any other rule under Regulation 8, glass coating 

falls under rule 4. 

Exemptions are provided for aerosol can coatings. No other exemptions pertinent to 

glass coating are specifically listed. 

The rule provides three options for compliance: (a) limit total facility VOC emissions to 5 

tons per years; or (b) use a control device with a VOC destruction efficiency of at least 

90%, or (c): use coatings with a VOC limit of 3.5 lb/gallon. 

The rule requires records of coating activities to be maintained and retained for at least 

two years. 

As far as glass coating is concerned, Bay Area AQMD Regulation 8 Rule 4 provides two 

avenues of compliance that are less stringent than District Rule 4610: (a) facilities are 

provided an option to use any coatings, regardless of VOC content, as long as total 

annual VOC emissions are limited to 5 tons. Facilities of comparable size under District 

Rule 4610 would still have to comply with VOC content limits or use control devices. (b) 

facilities opting to use a control device only need to achieve a 90% control efficiency, 

compared to 95% required by District Rule 4610. 

The VOC content limit of 3.5 lb/gallon, which is the third compliance option provided by 

Bay Area AQMD Regulation 8 Rule 4, is an average value that is fairly comparable to 

the category-specific VOC limits of District Rule 4610. It is as stringent as two of the 

Rule 4610 categories, less stringent than another two, and more stringent than a further 

three categories. 

In addition, District Rule 4610 has a more stringent record keeping requirement 

because it requires records to be retained for five years, compared to the two-year 

retention period required by Bay Area AQMD Regulation 8 Rule 4. 

District Rule 4610 is therefore more stringent than Bay Area AQMD Regulation 8 Rule 

4. 

Conclusion

After evaluation of federal rules and regulations as well as prohibitory rules in other 

California nonattainment areas, District staff concludes that District Rule 4610 meets 

RACT for Glass Coating Operations. 

The rule is more stringent overall than the equivalent Bay Area AQMD rule, but not as 

stringent overall as the equivalent South Coast AQMD rule. However, since South 

Coast AQMD rules generally exceed RACT requirements, District Rule 4610 still meets 

RACT even though it is not as stringent as the corresponding South Coast AQMD rule. 
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Rule 4612 - Motor Vehicle and Mobile Equipment Coating Operations 

Emissions Inventory:

Tons per day - summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 0 0 0 0 0 0 0 0 

VOC 2.05 2.10 1.54 1.55 1.57 3.04 1.61 1.63 

(Source: District 2007 Ozone Plan) 

District Rule 4612 Description

District Rule 4612, recently amended on September 20, 2007, controls VOC emissions 

from motor vehicle and mobile equipment coating operations, and from organic solvent 

cleaning, storage and disposal associated with the coating operations. 

This source category includes operations that apply, supply, sell, offers for sale, or solicits 

the application of VOC-containing coatings used in the finishing or refinishing of Vehicles 

and Equipment, and their parts and components. This also includes the organic solvent 

cleaning, and the storage and disposal of all solvents and waste solvent materials 

associated with such coating operations. 

District Rule 4612 limits the VOC content limit of coatings used to coat motor vehicles 

and mobile equipment. In lieu of complying with VOC content limits, operators may 

operate an APCO-approved VOC emission control system. District Rule 4612 replaced 

District Rule 4602 on January 1, 2009. District Rule 4612 incorporates all of the 

elements of the California Air Resources Board’s (ARB’s) Suggested Control Measures 

(SCM) for this source category. 

How does District Rule 4612 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

1. EPA-450/2-76-028 1976/11 Control of Volatile Organic Emissions from Existing 

Stationary Sources - Volume I: Control Methods for Surface Coating Operations

The CTG applies to surface coating operations located in marginal, moderate, serious 

or severe ozone nonattainment areas that has the potential to emit greater than or equal 

to 25 tons/year of VOC, and equal to greater than 10 tons/year of VOC for extreme 

ozone nonattainment areas. This CTG will not be compared to District Rule 4612 since 

the source category (Motor Vehicle and Mobile Equipment Coating) is addressed in 

another CTG: EPA-450/2-77-008 1977/05 Control of Volatile Organic Emissions from 

Existing Stationary Sources – Volume II: Surface Coating of Cans, Coils, Paper, 

Fabrics, Automobiles, and Light-Duty Trucks (See discussion below). 
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2. EPA-450/2-77-008 1977/05 Control of Volatile Organic Emissions from Existing 

Stationary Sources - Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, 

Automobiles, and Light-Duty Trucks 

The CTG applies to motor vehicle surface coating operations located in marginal, 

moderate, serious or severe ozone nonattainment areas that has the potential to emit 

greater than or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of 

VOC for extreme ozone nonattainment areas. 

The table below identifies the CTG requirements and how Rule 4612 compares to the 

automobile and light-duty truck coating requirements. 

Coating Type CTG (lb/gal) 4612 (lb/gal) 

Prime 2.8 2.1 

Topcoat 4.2 2.1 

Final Repair Topcoat 5.5 2.1 

As shown in the table above, District Rule 4612 is more stringent than all CTG limits. 

3. EPA-453/R-08-006 2008/09 Control Techniques Guidelines for Automobile and 

Light-Duty Truck Assembly Coatings 

The CTG applies to vehicle assembly coating operations located in marginal, moderate, 

serious or severe ozone nonattainment areas that has the potential to emit greater than 

or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of VOC for 

extreme ozone nonattainment areas. There are no vehicle assembly plants in the 

District; therefore, this CTG will not be examined. 

B. EPA - Alternative Control Technology (ACT) 

EPA-453/R-94-017 1994/02 Alternative Control Techniques Document - Surface 

Coating of Automotive/Transportation and Business Machine Plastic Parts

The ACT applies to the coating of plastic parts for the automotive industry, business 

machines, and other miscellaneous plastic parts. The ACT identifies an automotive 

coating work practice standards, VOC content limits, application methods, and add-on 

control efficiencies based on California District rules as of 1994. Since SJVAPCD Rule 

4612 is at least as stringent overall compared to other Districts (see analysis below in 

Section III), a detailed evaluation of the ACT is not necessary. 

C. Standards of Performance for New Stationary Sources (NSPS) 

40 CFR 60 Subpart MM (Standards of Performance for Automobile and Light Dusty 

Truck Surface Coating Operations) applies to assembly plant coatings. 
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There are no vehicle assembly plants in the District; therefore, this NSPS will not be 

examined. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

NESHAPs and MACTs are requirements contained in 40 Code of Federal Regulations 

(CFR) Part 61 and 40 CFR Part 63. Since EPA has delegated the authority to 

implement NESHAP requirements to the District, NESHAPs and MACTs promulgated 

by EPA are usually incorporated by reference into District Rule 4002 (National Emission 

Standards for Hazardous Air Pollutants). It is important to mention that the District 

implements NESHAPs and MACTs by incorporating the emission standards as 

conditions of the Permits to Operate issued to affected sources. 

40 CFR 63 Subpart IIII (National Emission Standards for HAPs: Surface Coating of 

Automobiles and Light-Duty Trucks) 

The requirements in this subpart are not directly comparable to the District Rule 4612 

limits. The NESHAP HAP emission limits which are expressed in terms of % HAP, HAP 

emission concentration, and mass (kg) of HAP per mass (kg) of solids are not directly 

comparable to the coatings VOC limit which is expressed in terms of grams (or lb) of 

VOC per liter (or gallons) of coatings, less water and exempt compounds, as applied. In 

addition, some HAPs may be exempt VOCs, and some VOCs may be HAPs; therefore, 

there is no direct correlation between the NESHAP limits versus District Rule 4612 VOC 

limits. 

How does District Rule 4612 compare with state regulations? 

A. California Air Resources Board (CARB) Suggested Control Measures (SCM) 

1. SCM for Automotive Coatings 

The table below identifies the requirements of the SCM: 

Rule Comparisons 

g-VOC/L (lb-VOC/gal) 

Coating Category SCM SJ Valley 

(Rule 4612) 

Adhesion Promoter Plastic Parts 540 (4.5) 540 (4.5) 

Camouflage 340 (2.8) 

Clear Coating 250 (2.1) 250 (2.1) 

Color Coating 420 (3.5) 420 (3.5) 

Pretreatment 660 (5.5) 660 (5.5)

Precoat 660 (5.5) 

Primer 250 (2.1) 250 (2.1) 
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Primer Sealer 250 (2.1) 250 (2.1) 

Primer Surfacer 250 (2.1) 

Single Stage Coating (not primer or 

multicolor) 340 (2.8) 340 (2.8) 

Topcoat - General 250 (2.1)

Topcoat - Metallic/Iridescent 420 (3.5) 

Topcoat - Metallic/Iridescent (spot 

repair) 420 (3.5)

Topcoat - Multicolored 680 (5.7) 420 (3.5)

Topcoat - Multistage 340 (2.8) 

Topcoat - Multistage (spot repair) 340 (2.8) 

Water-Based Temporary Transit 250 (2.1) 

Temporary Protective Coating 60 (0.5) 60 (0.5) 

Truck Bed Liner 310 (2.6) 310 (2.6) 

Underbody Coating 430 (3.6) 430 (3.6) 

Uniform Finish Coating 540 (4.5) 540 (4.5) 

Other 250 (2.1) 250 (2.1) 

Application Methods SCM SJ Valley 

(Rule 4612) 

Transfer Efficiency Minimum 65% 65% 

Add-on Control Efficiency SCM SJ Valley 

(Rule 4612) 

Overall Control 85% by wt 

85% by wt and at least 

equiv to compliant coating 

emissions 

Solvents SCM SJ Valley 

(Rule 4612) 

Product Cleaning (General) 25 25 

Repair and Maintenance Cleaning 25 25 

Cleaning of Application Equipment 25 25 

As shown in the table above, the SCM does not contain any requirements more 

stringent than District Rule 4612. As such, District Rule 4612 is at least as 

stringent at the SCM. 
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How does District Rule 4612 compare to rules in other air districts?

District staff compared District Rule 4612 with the rules of other California ozone 

nonattainment air districts’ rules (listed below) auto coating operations. The results of 

the analysis are discussed below. 

• South Coast Air Quality Management District (SCAQMD) Rule 1151 - Motor Vehicle 

and Mobile Equipment Non-Assembly Line Coating Operations (Amended 

December 2, 2005) 

• Bay Area Air Quality Management District (BAAQMD) Regulation 8 Rule 45 - Motor 

Vehicle and Mobile Equipment Coating Operations (Amended January 6, 1999) 

• Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 459 - 

Automotive, Truck and Heavy Equipment Refinishing Operations) (Amended 

October 2, 1997) 

• Ventura County Air Pollution Control District (VCPCD) Rule 74.18 - Motor Vehicle 

and Mobile Equipment Coating Operations (Amended September 10, 1996) 

Rule Comparisons 

g-VOC/L (lb-VOC/gal) 

Coating Category 

Bay Area

(Rule 8-

45) 

South 

Coast 

(Rule 

1151) 

Sac Metro 

(Rule 459) 

Ventura 

(Rule 

74.18) 

SJ Valley

(Rule 

4612) 

Adhesion Promoter Plastic 

Parts 540 (4.5) 

Camouflage 420 (3.5) 420 (3.5) 420 (3.5) 340 (2.8) 

Clear Coating 250 (2.1) 

Color Coating 540 (4.5) 685 (5.7) 420 (3.5) 

Pretreatment 780 (6.5) 750 (6.5) 780 (6.5) 780 (6.5) 660 (5.5)

Precoat 580 (4.8) 600 (5.0) 660 (5.5) 

Primer 250 (2.1) 250 (2.1) 250 (2.1) 

Primer Sealer 340 (2.8) 340 (2.8) 420 (3.5) 340 (2.8) 250 (2.1) 

Primer Surfacer 250 (2.1) 250 (2.1) 250 (2.1) 250 (2.1) 

Single Stage Coating (not 

primer or multicolor) 340 (2.8) 

Topcoat - General 420 (3.5) 340 (2.8) 420 (3.5) 340 (2.8) 250 (2.1)

Topcoat - Metallic/Iridescent 520 (4.3) 340 (2.8) 520 (4.3) 520 (4.3) 420 (3.5) 

Topcoat - Metallic/Iridescent 

(spot repair) 420 (3.5) 420 (3.5)

Topcoat - Multicolored 540 (4.5) 685 (5.7) 420 (3.5)

Topcoat - Multistage 340 (2.8) 540 (4.5) 340 (2.8) 340 (2.8) 

Topcoat - Multistage (spot 

repair) 420 (3.5) 340 (2.8) 

Water-Based Temporary 

Transit 420 (3.5) 250 (2.1) 
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Temporary Protective Coating 60 (0.5) 60 (0.5) 60 (0.5) 

Truck Bed Liner 310 (2.6) 

Underbody Coating 540 (4.5) 430 (3.6) 

Uniform Finish Coating 540 (4.5) 

Other 250 (2.1) 

Application Methods 

Bay Area

(Rule 8-

45) 

South 

Coast 

(Rule 

1151) 

Sac Metro 

(Rule 459) 

Ventura 

(Rule 

74.18) 

SJ Valley

(Rule 

4612) 

LVLP Spray x 

Transfer Efficiency Minimum 65% 65% APCO/EPA 

approved 65% 65% 

Add-on Control 

Efficiency 

Bay Area

(Rule 8-

45) 

South 

Coast 

(Rule 

1151) 

Sac Metro 

(Rule 459) 

Ventura 

(Rule 

74.18) 

SJ Valley

(Rule 

4612) 

Control 85% 

Overall Control 

Equiv to 

compliant 

coating 

emissions

Equiv to 

compliant 

coating 

emissions

85% 85% by 

wt 

85% by 

wt and 

Equiv to 

compliant 

coating 

emissions

Solvents 

Bay Area

(Rule 8-

45) 

South 

Coast 

(Rule 

1171)* 

Sac Metro 

(Rule 459) 

Ventura 

(Rule 

74.18) 

SJ Valley

(Rule 

4612) 

Product Cleaning (General) 72 

(0.6) 25 72 (0.6) 200 25 

Repair and Maintenance 

Cleaning 25 72 

(0.6) 200 25 

Cleaning of Application 

Equipment 25 72 

(0.6) 200 25 

*Per Rule 1171 (Solvent Cleaning) 

As shown in the table above, SJVAPCD Rule 4612 is as stringent or more stringent 

than other District in all categories except for two categories (precoat and Topcoat - 

Metallic/Iridescent). Since the overwhelmingly majority of coating categories are as 

stringent or more stringent than other Districts, Overall SJVAPCD Rule 4612 is at least 

as stringent as Bay Area Rule 8-45, South Coast Rule 1151, Sac Metro Rule 459, and 

Ventura Rule 74.18. 
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Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4612 

satisfies RACT for motor vehicle and mobile equipment coating operations. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

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Rule 4621 – Gasoline Transfer Into Stationary Storage Containers, 

Delivery Vessels, and Bulk Plants 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOX 0.019 0.021 0.023 0.023 0.024 0.027 0.028 0.03 

VOC 3.4 3.6 3.7 3.8 4.1 4.2 4.4 4.5 

(Source: District 2007 Ozone Plan) 

The emission inventory shown is the combined inventory for District Rule 4621, 

Gasoline Transfer into Stationary Storage Containers, Delivery Vessels, and Bulk 

Plants, and Rule 4624, Transfer of Organic Liquid. 

District Rule 4621 Description

This rule includes all operations that transfer gasoline between delivery vessels and 

storage containers and loading racks that are used to load organic liquids with a TVP of 

1.5 psia or greater. The purpose of this rule is to limit VOC emissions from stationary 

storage containers, delivery vessels, and bulk plants. 

How does District Rule 4621 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

1. EPA-450/2-77-026 Guideline for Control of Hydrocarbons from Tank Truck 

Gasoline Loading Terminals 

This CTG is related to the control of volatile organic compounds (VOC) from tank truck 

terminals with daily throughputs of greater than 76,000 liters of gasoline. District Rule 

4621 applies to all operations that transfer gasoline between delivery vessels and 

storage containers and loading racks that are used to load organic liquids with a TVP of 

1.5 psia or greater. Since this CTG only applies to the loading of tank trucks, only the 

sections of District Rule 4621 that apply to tank truck loading will be evaluated. 

This CTG identifies RACT for the control of VOCs from tank truck gasoline loading 

terminals as having an emission limit of 80 mg-hydrocarbon/L-gasoline loaded. District 

Rule 4621 requires that the VOC emissions from the transfer of gasoline from a 

stationary storage tank to a gasoline tank truck shall be controlled by 95%. The CTG 

lists the emission factor for hydrocarbon emissions generated during submerged fill (top 

or bottom) gasoline loading operations is 600 mg/liter transferred. Therefore, District 

Rule 4621 emission limit can be calculated as 30 mg/liter (600 mg/liter * (1 – 0.95)). 
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Since this emission limit is lower than the one listed in the CTG as RACT, District Rule 

4621 satisfies RACT for this CTG. 

2. EPA-450/2-77-035 Guideline for Control of Volatile Organic Emissions from Bulk 

Gasoline Plants 

This CTG outlines the design of control devices to control vapors from the loading and 

unloading activities at a gasoline bulk plant. The CTG discusses the effective control of 

VOC emissions with the installation of submerged fill pipes and vapor control systems. 

District Rule 4621 requires that all bulk plants shall be equipped with an ARB certified 

vapor recovery system for the loading racks. In addition, District Rule 4621 also 

describes inspection procedures to verify that the operation is operating leak free. The 

requirements in District Rule 4621 are equivalent to the control technology discussed in 

this CTG. 

3. EPA-450/2-78-051 Guideline for Control of Volatile Organic Compound Leaks from 

Gasoline Tank Trucks and Vapor Collection Systems 

This guideline is related to the control of volatile organic compounds (VOC) from 

gasoline tank trucks and vapor collection systems at bulk terminals, bulk plants, and 

service stations. The intent of this guideline is to define leak tight conditions and related 

test procedures for vapor collection systems and tank trucks while loading and 

unloading at these facilities. Since this CTG only applies to the definition of a leak, only 

the definition of a leak from District Rule 4621 will be evaluated. In addition, the District 

does not regulate the emissions from gasoline tank trucks. 

The CTG requires that vapor collection systems during loading or unloading operations 

at service stations, bulk plants and bulk terminals, there shall be no reading greater than 

or equal to 100 percent of the lower explosive limit (LEL, measured as propane) at 2.5 

centimeters around the perimeter of a potential leak source as detected by a 

combustible gas detector. In addition, there are to be no avoidable visible leaks. 

District Rule 4621 requires that, for delivery vessels, leak emissions shall not exceed 

the dripping of VOC-containing liquid at a rate of more than three drops per minute, or a 

reading of greater than 100 percent of the lower explosive limit (21,000 ppm measured 

as equivalent propane). Both of the regulations limit leaks to equal to or lower than 100 

percent LEL, therefore these requirements are equivalent. 

The CTG also requires the vapor collection and vapor processing equipment must be 

designed and operated to prevent gauge pressure in the tank truck from exceeding 

4500 pascals (18 inches of water) and prevent vacuum from exceeding 1500 pascals (6 

inches of water). District Rule 4621 only addresses the transfer of gasoline into tank 

trucks from bulk plants. District Rule 4621 states that the loading rack vapor recovery 

system shall not create a back pressure in excess of the pressure limits of the delivery 

vessel certification leak test (18 inches water column). Since both of these regulations 

have the same back pressure limit these two regulations are equivalent. 
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Bulk terminal, bulk plant and service station owners or operators must keep records for 

two years indicating the last time a vapor collection facility passed the required leak 

testing. District Rule 4621 requires that bulk plants and loading racks keep records of 

all inspections and all actions conducted on any part of the storage container or loading 

racks shall be maintained in chronological order showing date of inspection, description 

and location of any equipment replaced, and a description of the problem which 

required repair. In addition, all bulk plants are required to maintain daily gasoline 

throughput records. District Rule 4621 also requires that all records required to 

demonstrate compliance with the requirements of this rule shall be retained on the 

premises for a minimum of five years. Therefore the recordkeeping requirements of 

District Rule 4621 are more stringent than the CTG. 

As demonstrated in the discussions above, District Rule 4621 is equivalent to or more 

stringent than the similar requirements form the CTG. 

B. EPA – Alternative Control Technology (ACT) 

1. EPA-450/R-75-102 Alternative Control Technology Document for Stage I Vapor 

Control Systems on Gasoline Service Stations 

This document outlines the design of Phase I vapor control systems for facilities that are 

required to install such systems. CARB now publishes Executive Orders which details 

the specific equipment needed for certain vapor recovery systems to meet certain 

Executive Orders. The ACT also states that EPA requires vapor control systems control 

90% of the vapors from the Phase I side of a gasoline dispensing operation. Currently 

District Rule 4621 requires 98% vapor control from the Phase I vapor control system for 

underground tanks. 

C. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS for this source category. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There is no NESHAP for this source category. 

How does District Rule 4621 compare to rules in other air districts?

District staff compared VOC limits, optional control requirements, and work practice 

standards in District Rule 4621 to comparable requirements in rules from the following 

California nonattainment areas: 

• South Coast AQMD Rule 461, as amended March 2008 

• Bay Area AQMD Regulation 8 Rule 7, as adopted November 2002 
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• Bay Area AQMD Regulation 8 Rule 39, as adopted June 1994 

• Sacramento Metro AQMD Rule 448, as amended February 1995 

• Ventura County APCD Rule 70, as amended July 2004 

A. South Coast AQMD Rule 461 

South Coast AQMD Rule 461 (Gasoline Transfer and Dispensing) applies to the 

transfer of gasoline from any tank truck, trailer, or railroad tank car into any stationary 

storage tank or mobile fueler (Phase I), and from any stationary storage tank or mobile 

fueler into any mobile fueler or motor vehicle fuel tank (Phase II). District Rule 4621 

only applies to storage containers located at bulk plants with capacities greater than 250 

gallons and less than 19,800 gallons; to other stationary storage containers with 

capacities greater than 250 gallons; and to those storage containers that are not subject 

to the control requirements of Rule 4623 (Storage of Organic Liquids) Section 5.0. The 

rule also applies to gasoline delivery vessels. Since District Rule 4621 only applies to 

the Phase I side of gasoline transferring, District Rule 4621 will only be compared to the 

gasoline Phase I requirements of SCAQMD Rule 461. 

SCAQMD Rule 461 requires underground storage tanks to be equipped with a "CARB 

certified" enhanced vapor recovery system having a minimum volumetric efficiency of 

98% and aboveground storage tanks to be equipped with a "CARB certified” vapor 

recovery system having a minimum volumetric efficiency of 95%. The rule also states 

that the vapor recovery systems are required to be maintained and operated according 

to the manufacturer's specifications and the applicable CARB Executive Orders. District 

Rule 4621 contains the same vapor recovery requirements for underground and 

aboveground tanks. 

SCAQMD Rule 461 requires mobile fueler tanks to be equipped with a “CARB certified” 

vapor recovery system having a minimum volumetric efficiency of 95% and to 

maintained and operated the vapor recovery system according to the manufacturer’s 

specifications and the applicable CARB Executive Orders. 

B. Bay Area AQMD Regulation 8 Rule 7 

Bay Area AQMD Regulation 8 Rule 7 (Gasoline Dispensing Facilities) applies to both 

the Phase I and Phase II side of gasoline dispensing facilities. Since District Rule 4621 

only applies to the Phase I side of gasoline transferring, District Rule 4621 will only be 

compared to the gasoline Phase I requirements of Bay Area AQMD Regulation 8 Rule 

7. 

BAAQMD Reg 8 Rule 7 exempts storage tanks with capacities less than 250 gallons, 

storage tanks with capacities less than 550 gallons that are used primarily for the fueling 

of implements of husbandry and that have a submerged fill pipe, and storage tanks 

installed before January 1, 1999 where the APCO determines that Phase I vapor 

recovery is not feasible. District Rule 4621 contains the same exemptions based on the 

storage tanks capacities, but also exempts specific types of storage tanks that were in 
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operation prior to July 1, 1975. Therefore, the applicability of these two rules can be 

considered equivalent. 

BAAQMD Reg 8 Rule 7 requires gasoline storage tanks to be equipped with a CARB 

certified Phase I vapor recovery system. This vapor recovery system is required to be 

maintained and operated according to the manufacturer's specifications and the 

applicable CARB Executive Order. In addition, this rule states that no person shall 

install or modify a Phase I vapor recovery system unless the system vapor recovery rate 

is 98% or the highest vapor recovery rate specified by CARB if the highest rate is less 

than 98%. District Rule 4621 contains the same vapor recovery requirements for 

gasoline storage tanks therefore the vapor recovery requirements of these rules are 

equivalent. 

BAAQMD Reg 8 Rule 7 and District Rule 4621 have the same monitoring and testing 

requirements, however BAAQMD Reg 8 Rule 7 only requires the facility to maintain 

records for 2 years while District Rule 4621 requires that records be kept for 5 years. 

 

C. Bay Area AQMD Regulation 8 Rule 39 

Bay Area AQMD Regulation 8 Rule 39 (Gasoline Bulk Plant and Gasoline Delivery 

Vehicles) applies to gasoline transfer operations at gasoline bulk plants and delivery 

vehicles. Since BAAQMD Regulation 8 Rule 39 only applies to bulk plants and delivery 

vessels, only the bulk plant and delivery vessel requirements District Rule 4621 will be 

compared to the requirements of BAAQMD Regulation 8 Rule 39. 

BAAQMD Regulation 8 Rule 39 states that a person shall not load or permit the loading 

of gasoline into or out of a gasoline bulk plant unless a CARB certified vapor recovery 

system is properly connected and used. In addition, BAAQMD Regulation 8 Rule 39 

states that the loading rack vapor recovery system shall be maintained and operated in 

a manner that prevents gauge pressure in the delivery tank from exceeding 46cm (18 

in.) of water column during product loading. District Rule 4621 contains the same vapor 

recovery requirements for bulk plants; therefore the bulk plant vapor recovery 

requirements of these rules are equivalent. 

BAAQMD Regulation 8 Rule 39 states the following requirements for delivery vessels: 

• A person shall not operate, or allow the operation of, a gasoline delivery vehicle 

unless valid State of California decals, as required by Section 41962 of the 

Health and Safety Code which attest to the vapor integrity of the tank, are 

displayed. 

• Any gasoline delivery vehicle loading at a facility subject to the requirements of 

Section 8-33-302 shall be equipped with and use a vapor recovery system. 

• A person shall not purge gasoline vapor from the tank of a delivery vehicle to the 

atmosphere. 
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District Rule 4621 contains the same vapor recovery requirements for delivery vessels; 

therefore the delivery vessel vapor recovery requirements of these rules are equivalent. 

D. Sacramento Metro AQMD Rule 448 

Sacramento Metro AQMD Rule 448 (Gasoline Transfer Into Stationary Source 

Containers) applies to operations were gasoline is transferred to stationary storage 

containers. Since Sacramento Metro AQMD Rule 448 only applies to transferring of 

gasoline to stationary storage tanks, only these requirements from District Rule 4621 

will be compared to the requirements of Sacramento Metro AQMD Rule 448. Both rules 

also do not apply to tanks with capacities less than 250 gallons equipped with a 

submerged fill pipe. 

Sacramento Metro AQMD Rule 448 requires gasoline storage tanks to be equipped with 

a CARB certified vapor recovery system. This vapor recovery system is required to be 

maintained and operated according to the manufacturer's specifications and the 

applicable CARB Executive Order. In addition, this rule states that the vapor recovery 

system shall prevent emission to the atmosphere of at least 95%, by weight, of the 

gasoline vapors displaced from the storage container during the transfer of gasoline into 

the container. District Rule 4621 requires the vapor recovery system to have a 

minimum volumetric control efficiency of 98%. Therefore the vapor recovery 

requirements of District Rule 4621 are more stringent than that of Sacramento Metro 

AQMD Rule 448. 

Sacramento Metro AQMD Rule 448 requires that delivery vessels shall be maintained 

leak free and a vapor tight. In addition, this rule also prohibits any person from purging 

gasoline vapors, gases, or hydrocarbon vapors from a delivery vessel to the 

atmosphere. District Rule 4621 has the same requirements for delivery vessels; 

therefore the delivery vessel requirements for both rules are equivalent. 

District Rule 4621 requires the same monitoring and testing requirements as 

Sacramento Metro AQMD Rule 448. 

E. Ventura County APCD Rule 70 

Ventura County APCD Rule 70 (Storage and Transfer of Gasoline) applies to operations 

were gasoline is transferred and to storage operations with gasoline containers less 

than 40,000 gallons. Since District Rule 4621 only applies to the Phase I side of 

gasoline transferring. Both rules have exemptions in place for storage tanks with 

capacities of 250 gallons or less, however Ventura County APCD contains other 

exemptions in excess of what District Rule 4621 exempts. Therefore District Rule 4621 

is applicable to more types of operations. District Rule 4621 will only be compared to 

the gasoline Phase I requirements of Ventura County APCD Rule 70. 

Ventura County APCD Rule 70 requires gasoline storage tanks to be equipped with a 

CARB certified vapor recovery system. This vapor recovery system is required to be 
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maintained and operated according to the manufacturer's specifications and the 

applicable CARB Executive Order. In addition, this rule states that the vapor recovery 

system shall prevent emission to the atmosphere of at least 95% of the gasoline vapors 

displaced from the storage container during the transfer of gasoline into the container. 

District Rule 4621 requires the vapor recovery system to have a minimum volumetric 

control efficiency of 98%. For bulk plants, both Ventura County APCD Rule 70 and 

District Rule 4621 require that the loading racks are equipped with an ARB certified 

vapor recovery system. Therefore the vapor recovery requirements of District Rule 

4621 are more stringent than that of Ventura County APCD Rule 70. 

Ventura County APCD Rule 70 requires that delivery vessels shall only load and unload 

at facilities with CARB certified vapor recovery systems. In addition, both rules have the 

same requirements when opening the hatch to perform a visual inspection. District Rule 

4621 has the same requirements for delivery vessels; therefore the delivery vessel 

requirements for both rules are equivalent. 

Ventura County APCD Rule 70 and District Rule 4621 have the same monitoring and 

testing requirements, however Ventura County APCD Rule 70 only requires the facility 

to maintain records for 2 years while District Rule 4621 requires that records be kept for 

5 years. 

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4621 

satisfies RACT for gasoline transfer into stationary storage containers, delivery vessels, 

and bulk plants. 
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Rule 4622 – Gasoline Transfer into Motor Vehicle Fuel Tanks 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

VOC 2.7 2.8 2.9 3.0 3.3 3.4 3.6 3.6 

(Source: District 2007 Ozone Plan) 

District Rule 4622 Description

Rule 4622, recently amended on December 20, 2007, limits VOC emissions from the 

transfer of gasoline into motor vehicle fuel tanks. The main rule requirement is that 

gasoline dispensing units used to transfer gasoline from a stationary source to a motor 

vehicle tank must be equipped with a ARB certified Phase II vapor recovery system. 

On May 30, 2007 EPA took direct final action to approve revisions to the San Joaquin 

Valley Unified Air Pollution Control District portion of the California State Implementation 

Plan. These revisions included approval of District Rule 4622. EPA, in evaluating and 

approving Rule 4622 included the following: 

“We believe these rules are consistent with the relevant policy and guidance 

regarding enforceability, RACT, BACM, and SIP relaxations.” (CFR Volume 72, 

Number 103) 

Since Rule 4622 was recently approved by EPA as meeting RACT requirements, the 

District did not pursue a detailed RACT analysis. 

How does District Rule 4622 compare with federal rules and regulations?

The District did not conduct a detailed analysis of federal rules and regulations for Rule 

4622. 

How does District Rule 4622 compare to rules in other air districts?

The District did not conduct a detailed comparison to rules in other air districts for Rule 

4622. 

Conclusion

District staff concludes that District Rule 4622 satisfies RACT for the transfer of gasoline 

into motor vehicle fuel tanks. 
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Rule 4623 – Storage of Organic Liquids 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

VOC 0.107 0.109 0.109 0.109 0.11 0.12 0.12 0.107 

(Source: District 2007 Ozone Plan) 

District Rule 4623 Description

District Rule 4623, recently amended on May 19, 2005, regulates VOC emissions from 

tanks that store organic liquids if the tank capacity is 1,100 or greater and the true vapor 

pressure (TVP) of the stored liquid is 0.5 psia or greater. Current VOC controls require 

pressure-vacuum relief valves, internal floating roof tanks, external floating roof tanks, 

fixed roof tanks with vapor recovery system of at least 95% control efficiency, or 

pressure vessels. Specific control requirements vary depending on the tank capacity 

and TVP of the stored liquid. Different tank control requirements are specified for tanks 

operated by small producers or by non-small producers. Leak detection and repair 

(LDAR) provisions include periodic inspection and repair of leaking components within a 

specified time frame. The component leak standard is 10,000 ppmv. 

On May 30, 2007 EPA took direct final action to approve revisions to the San Joaquin 

Valley Unified Air Pollution Control District portion of the California State Implementation 

Plan. These revisions included approval of District Rule 4623. EPA, in evaluating and 

approving Rule 4623 included the following: 

“We believe these rules are consistent with the relevant policy and guidance 

regarding enforceability, RACT, BACM, and SIP relaxations.” (CFR Volume 72, 

Number 103) 

Since Rule 4623 was recently approved by EPA as meeting RACT requirements, the 

District did not pursue a detailed RACT analysis. 

How does District Rule 4623 compare with federal rules and regulations?

The District did not conduct a detailed analysis of federal rules and regulations for Rule 

4623. 

How does District Rule 4623 compare to rules in other air districts?

The District did not conduct a detailed comparison to rules in other air districts for Rule 

4623. 
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Conclusion

District staff concludes that District Rule 4623 satisfies RACT for Storage of Organic 

Liquids. 
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Rule 4624 – Transfer of Organic Liquid 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 0.019 0.021 0.023 0.023 0.024 0.027 0.028 0.03 

VOC 3.4 3.6 3.7 3.8 4.1 4.2 4.4 4.5 

The emission inventory shown is the combined inventory for District Rule 4621, 

Gasoline Transfer into Stationary Storage Containers, Delivery Vessels, and Bulk 

Plants, and Rule 4624, Transfer of Organic Liquid. 

District Rule 4624 Description

The purpose of this rule is to limit VOC emissions from the transfer of organic liquids, 

which are liquids that contain VOCs and have a True Vapor Pressure (TVP) of 1.5 psia 

or greater at the storage container’s maximum organic liquid storage temperature. 

The rule exempts the following categories: (a) transfer of less than 4,000 gallons of 

organic liquids per day; (b) gasoline stations – which are covered by District rules 4621 

and 4622; (c) transfer operations using vacuum trucks; (d) equipment or components 

subject to District rules 4409 (Components at Light Crude Oil Production Facilities, 

Natural Gas Production Facilities, and Natural Gas Processing Facilities), 4455 

(Components at Petroleum Refineries, Gas Liquids Processing Facilities, and Chemical 

Plants), or 4623 (Storage of Organic Liquids) are exempt from leak inspection 

requirements of Rule 4624, and (e) bottom loading is not required for facilities handling 

only liquefied petroleum gas.

Facilities transferring 20,000 gallons or more per day of organic liquid must comply with 

a VOC emission limit of 0.08 lb per 1,000 gallons, use bottom loading, and route VOC 

vapors to a vapor collection and control system, a fixed roof container, a floating roof 

container, a pressure vessel, or other closed VOC emission control system.

Facilities transferring less than 20,000 gallons per day of organic liquid must capture at 

least 95% of VOC vapors displaced during loading, use bottom loading, and route VOC 

vapors to a vapor collection and control system, a fixed roof container, a floating roof 

container, a pressure vessel, or other closed VOC emission control system. 

Pressure in the delivery tank being loaded must be maintained within the range of 18 

inches water column pressure and six (6) inches water column vacuum. Delivery tanks 

which previously contained organic liquids shall be filled only at transfer facilities that 

are compliant with the vapor capture requirements. Transfer racks and vapor collection 

equipment shall have no leaks and no excess organic liquid drainage at disconnections. 

New top loading facilities or the expansions of any existing one are prohibited.
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Quarterly inspection for leaks is required. A facility may apply to reduce inspection 

frequency to annual after passing five quarterly inspections. Leaking equipment must be 

repaired or taken out of service within 72 hours. 

In addition to an initial source test, VOC control systems must be source tested every 5 

years. 

Record keeping is required for organic liquid daily throughput and TVP for facilities 

exempt based on throughput or TVP, daily throughput and leak inspection records for 

affected facilities. Vacuum truck operators claiming exemption must submit, on a onetime basis, records showing number of vacuum trucks in operation, capacity of each 

vacuum truck storage container, average monthly throughput per vehicle, type of 

organic liquid transferred, and VOC capture and control equipment utilized. 

Records must be retained for a minimum of five years. 

How does District Rule 4624 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals. 

This CTG applies to facilities with a throughput of more than 20,000 gallons per day. 

The CTG states that the recommended loading terminal emission limit that can be 

achieved through the application of reasonably available control technology (RACT) is 

0.64 lb VOC per 1,000 gallons of gasoline loaded. 

District Rule 4624 is more stringent than this CTG because it requires a VOC emission 

limit of 0.08 lb per 1,000 gallons for facilities with a throughput of 20,000 gallons or 

more, compared to the CTG’s recommended limit of 0.64 lb per 1,000 gallons. 

B. EPA – Alternative Control Technology (ACT) 

There is no ACT for this source category. 

C. Standards of Performance for New Stationary Sources (NSPS) 

40 CFR 60 Subpart XX, Standards of Performance for Bulk Gasoline Terminals 

This NSPS applies to facilities with a throughput of more than 19,984 gallons per day 

(75,700 liters per day), and requires the use of a vapor collection system with VOC 

emissions to the atmosphere not exceeding 0.28 lb/1,000 gallons (35 milligrams/ liter). 

The VOC emission limit for vapor collection systems at existing (pre-December 17, 

1980) facilities is 0.64 lb/1,000 gallons (80 milligrams/liter). The vapor collection system 

shall be designed to prevent vapors collected at one loading rack from passing to 
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another loading rack, and only vapor-tight gasoline tank trucks shall be loaded. The 

operator shall obtain the vapor tightness documentation for trucks to be loaded. Tank 

numbers are to be recorded during loading and subsequently cross-checked with filed 

vapor tightness documentation. If the cross-checking reveals that a non-vapor tight tank 

was loaded, the operator must notify the tank owner and ensure that the tank is not 

reloaded at that facility until vapor tightness documentation is obtained. 

The NSPS also requires that the vapor collection and liquid loading equipment is 

designed and operated to prevent gauge pressure in the delivery tank from exceeding 

4,500 Pascals (450 mm of water) during product loading. Monthly inspection for leaks is 

required. 

Records must be maintained for tank truck vapor tightness documentation, leak 

inspections, and component additions or replacements. Record must be retained for at 

least two years. 

District Rule 4624 is more stringent than 40 CFR 60 Subpart XX because it applies to 

loading racks at all terminals, whereas 40 CFR 60 Subpart XX applies only to racks at 

facilities with a throughput exceeding 19,984 gallons per day. 

District Rule 4624 is more stringent than 40 CFR 60 Subpart XX because it requires a 

VOC emission limit of 0.08 lb/1,000 gallons, whereas 40 CFR 60 Subpart XX allows the 

much lower limits of 0.28 lb/1,000 gallons for new facilities and 0.64 lb/1,000 gallons for 

existing facilities. 

There are no significant differences between District Rule 4624 and 40 CFR 60 Subpart 

XX for source testing, monitoring and reporting requirements. 

District Rule 4624 is more stringent under this category because it requires records to 

be retained for at least 5 years, whereas 40 CFR 60 Subpart XX requires only 2 years 

for record retention. 

The preceding comparison demonstrates that District Rule 4624 is more stringent than 

40 CFR 60 Subpart XX. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

40 CFR 63 Subpart EEEE, Organic Liquids Distribution (Non-Gasoline) 

This NESHAP applies to various equipment and components used in organic liquids 

distribution, including loading racks. 

The NESHAP requires the that vapors displaced during loading (1) be routed through a 

closed vent system into any combination of control devices achieving at least 98 weightpercent HAP reduction, or a reduction to an exhaust concentration less than or equal to 
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20 ppmv (control devices must meet applicable testing, monitoring and operating 

standards depending on type of device); (2) be routed into fuel gas systems or back into 

a process; or (3) captured in a vapor balancing system that routes organic HAP vapors 

to the storage tank from which the liquid being loaded originated or to another storage 

tank connected to a common header. 

The requirements of District Rule 4624 and 40 CFR 63 Subpart EEEE are similar as far 

as the collection and disposal of vapors displaced during organic liquid loading is 

concerned. However, it is possible to compare destruction efficiencies of the control 

equipment directly, because District Rule 4624 addresses only VOC (requiring a 

destruction efficiency of 95%), while 40 CFR 63 Subpart EEEE addresses HAPs 

(requiring a destruction efficiency of 98%). 

In addition, the District implements 40 CFR 63 Subpart EEEE by reference under District Rule 4002. 

How does District Rule 4624 compare to rules in other air districts?

District staff compared emission limits, optional control requirements, and work practice 

standards in District Rule 4624 to comparable requirements in rules from the following 

California nonattainment areas: 

• South Coast AQMD Rule 462 (amended 5/14/1999) 

• South Coast AQMD Rule 1142 (adopted 7/19/1991) 

• Bay Area AQMD Regulation 8 Rule 6 (amended 2/2/1994) 

• Bay Area AQMD Regulation 8 Rule 33 (amended 6/1/1994) 

• Bay Area AQMD Regulation 8 Rule 39 (amended 6/1/1994) 

• Ventura County APCD Rule 70 (revised 11/11/2003) 

• Ventura County APCD Rule 71.3 (revised 6/16/1992) 

• Sacramento Metro AQMD Rule 447 (revised 4/2/1998) 

A. South Coast AQMD Rule 462 

 

The purpose of South Coast AQMD Rule 462 is to control emissions of volatile organic 

compounds (VOC) from facilities that load organic liquids with a vapor pressure of 1.5 

psia. The rule provides an exemption from the vapor recovery system and associated 

continuous monitoring system for facilities that vent loading vapors to a flare or 

combustion device. 

The rule requires loading of organic liquids at facilities with a throughput of 20,000 

gallons or more to be done only using a CARB vapor recovery or vapor disposal 

system, or equivalent system approved by the air District. The vapor recovery/disposal 

system shall be equipped with a continuous monitoring system, and must reduce the 

emissions of VOCs to 0.08 lb/1,000 gallons of organic liquid transferred. Only bottom 

loading is to be used, and there shall be no overfills or leaks. The backpressure in the 
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vapor recovery and/or disposal system shall not exceed 18 inches of water column 

pressure. 

For facilities with a throughput of less than 20,000 gallons, the vapor recovery/disposal 

system must reduce VOC emissions by at least 90%. Only bottom loading is to be used, 

and there shall be no overfills or leaks. The backpressure in the vapor recovery and/or 

disposal system shall not exceed 18 inches of water column pressure. 

For facilities with a throughput of less than 4,000 gallons per day and less than 500,000 

gallons per year no vapor recovery/disposal system is required. Only bottom loading is 

to be used, and there shall be no overfills or leaks 

Uncontrolled switch loading is prohibited except only at those facilities with a throughput 

of less than 4,000 gallons/day and less than 500,000 gallons/yr. 

Monthly leak inspection is required if the inspection is to be done by sight, sounds and 

smell. If an organic vapor analyzer is used, the inspection may be done quarterly. 

Required records include (1) daily and year-to-date throughput records (2) inspection 

records. Records are required to be retained for two years. 

South Coast AQMD Rule 462 is slightly more stringent under this category. Whereas 

District Rule 4624 has no requirements at all for facilities with a throughput of less than 

4,000 gallons a day (equivalent to an annual throughput of around 1,460,000 gallons), 

South Coast AQMD Rule 462 imposes vapor recovery requirements on such facilities if 

they exceed 500,000 gallons per year. South Coast Rule 462 also requires bottom 

loading for facilities that are below 4,000 gallons per day and 500,000 gallons per year 

in throughput. 

Both rules have similar requirements for facilities with organic liquid throughputs of 

20,000 gallons per day or more. For facilities between 4,000 and 20,000 gallons per 

day in throughput, District Rule 4624 is more stringent because it requires the vapor 

recovery system for such facilities to reduce VOC emissions by at least 95%, whereas 

South Coast AQMD Rule 462 requires a 90% reduction. For facilities with less than 

4,000 gallons per day in throughput, South Coast AQMD Rule 462 is more stringent 

because it requires vapor recovery and/or bottom loading, depending on annual 

throughput, whereas District Rule 4624 has no requirements. 

South Coast AQMD Rule 462 is more stringent for source testing and monitoring 

because it requires more frequent inspections (monthly for sight/smell/sound method, 

and quarterly for analyzer). District Rule 4624 requires quarterly inspection and has a 

provision for reducing the frequency further to annual inspection. 

In addition, South Coast AQMD Rule 462 is more stringent under monitoring because it 

requires the installation and use of a continuous monitoring system for the vapor 

recovery system. 
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There is no significant difference between the two rules for reporting. District Rule 4624 

is more stringent for recordkeeping because it requires records to be retained for at 

least 5 years, whereas South Coast AQMD Rule 462 has a two-year record retention 

requirement. 

South Coast AQMD Rule 462’s requirement of a continuous monitoring system for 

vapor recovery systems represents a standard that is more stringent than District Rule 

4624. A cost effectiveness analysis is required to determine if such a requirement 

should be incorporated into District Rule 4624. However, there is no data that can be 

used to determine the emission reductions attributable to a continuous monitoring 

system. It is therefore recommended that the continuous monitoring requirement is 

considered under the context of a rule amendment or rule making process which allows 

for detailed studies to determine factors such as emission reductions, feasibility, 

economic and socio-economic costs. 

B. South Coast AQMD Rule 1142 

South Coast AQMD Rule 1142 applies to the loading of organic liquids into marine 

vessels, among other operations. The rule requires emissions of VOCs to be limited to 

0.05 lb/1,000 gallons (2 lb/1,000 barrels) of liquid loaded into a marine tank vessel; or 

the emissions of VOCs to be reduced by at least 95 percent by weight from uncontrolled 

conditions. All equipment is required to be leak-free. Records of organic liquid loading 

events are required to be retained for at least two years. 

As far as applicability is concerned, District Rule 4624 is a much more comprehensive 

rule because it applies to all organic liquid loading events. On the other hand, South 

Coast AQMD Rule 1142 is much narrower in scope because it applies only to the 

loading of marine vessels. 

As far as exemptions are concerned, South Coast AQMD Rule 1142 is more stringent 

because it does not offer any exemptions, whereas District Rule 4624 has a throughput 

exemption for facilities transferring less than 4,000 gallons of liquid per day, as well as 

other fairly insignificant exemptions. 

District Rule 4624 is more stringent than South Coast AQMD Rule 1142 under this 

category. Rule 4624 has two emission control requirements: (1) reduction of loading 

VOC emissions by 95% for facilities with a throughput of less than 20,000 gallons per 

day, and (2) a stricter limit of 0.08 lb/1,000 gallons for facilities with a throughput of 

20,000 gallons per day or more. On the other hand, South Coast AQMD Rule 1142 

gives all facilities a choice between a limit of 0.05 lb VOC/1,000 gallons and reduction of 

VOC emissions by 95%. It is reasonable to assume that, given a choice, facilities will 

take the less stringent requirement of 95% emissions reduction, hence the South Coast 

Rule will result in less overall emissions control in comparison to District Rule 4624. 
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Source Testing and Monitoring: 

There is no significant difference between the two rules under this category. 

Reporting: 

There is no significant difference between the two rules under this category. 

Record Keeping: 

District Rule 4624 is more stringent under this category because it requires records to 

be retained for at least 5 years, whereas South Coast AQMD Rule 1142 requires only 

two years of record retention. 

The preceding comparison demonstrates that, taking all the comparison categories into 

consideration, District Rule 4624 is more stringent than South Coast AQMD Rule 1142. 

C. Bay Area AQMD Regulation 8 Rule 6 

 

The purpose of Bay Area AQMD Regulation 8 Rule 6, Terminals and Bulk Plants, is to 

limit emissions of organic compounds from transfer operations at non-gasoline organic 

liquid bulk terminals and bulk plants. 

The rule provides the following exemptions: (a) liquids with a TVP less then 0.5 psi; (b) 

facility-wide annual organic liquid (with TVP of at least 1.5 psia) throughput of 600,000 

gallons or less; (c) spills resulting from maintenance and repair; (d) liquefied gases such 

as LPG. 

The rule require loading of organic liquids to be done only using a vapor loss control 

system which limits VOC vapor emissions into the atmosphere to 0.17 lb/1,000 gallons 

for bulk terminals and 0.35 lb/1,000 gallons for bulk plants. Submerged fill pipe or 

bottom loading is required for transferring organic liquid into delivery vehicles or 

transportable containers. The rule requires the vehicles loaded with organic liquid shall 

be equipped to allow proper connection to the vapor balance system or vapor loss 

control system and shall be maintained to be vapor tight, leak, free, and in good working 

order. 

Required records include (1) true vapor pressure of each organic liquid and organic 

liquid mixture (2) monthly throughput records. Records are required to be retained for 

two years. 

District Rule 4624 is compared to Bay Area AQMD Regulation 8 Rule 6 under the 

following categories: 
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Applicability/Exemption: 

The applicability is the same for both rules. San Joaquin Valley APCD has one rule 

(4624) that applies to loading/transfer operations regardless of the type of facility doing 

the loading/transfer , whereas Bay Area AQMD applies the loading/transfer 

requirements through three different facility-specific rules. 

District Rule 4624 is less stringent in the throughput-based exemption because it allow 

an exemption up to 4,000 gallons a day (1,460,000 gallons per year), whereas Bay Area 

AQMD Regulation 8 Rule 6 allows only 600,000 gallons per year. 

There is no difference in the TVP exemptions since requirements for both rules 

generally apply to liquid with a TVP of at least 1.5 psia. 

Requirements: 

District Rule 4624 is more stringent than Bay Area AQMD Regulation 8 Rule 6 because 

it requires a VOC emission limit of 0.08 lb/1,000 gallon, whereas Bay Area AQMD 

Regulation 8 Rule 6 requires a VOC emission limit of 0.17 lb/1,000 gallon. 

Source Testing and Monitoring: 

There is no significant difference between the two rules under this category. 

Reporting: 

There is no significant difference between the two rules under this category. 

Record Keeping: 

District Rule 4624 is more stringent under this category because it requires records to 

be retained for at least 5 years, whereas Bay Area AQMD Regulation 8 Rule 6 has a 

two-year record retention requirement. 

The preceding comparison demonstrates that, taking all the comparison categories into 

consideration, District Rule 4624 is more stringent than Bay Area AQMD Regulation 8 

Rule 6. Although District Rule 4624’s throughput exemption is only half as stringent, its 

VOC emission, which is a much more critical aspect of the regulation, is twice as 

stringent as the corresponding Bay Area AQMD Regulation 8 Rule 6 limit. 

D. Bay Area AQMD Regulation 8 Rule 33

 

The purpose of Bay Area AQMD Regulation 8 Rule 33, Gasoline Bulk Terminals and 

Gasoline Delivery Vehicles, is to limit emissions of organic compounds from transfer 

operations at gasoline bulk terminals and delivery vehicles. 
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The rule provides the following exemptions: (a) delivery vehicles delivering exclusively 

to small tanks (< 550 gallons) or tanks for which vapor recovery is not feasible; (b) spills 

resulting from maintenance and repair. 

The rule requires loading of gasoline to be done only using a vapor recovery system 

which limits VOC vapor emissions into the atmosphere to 0.08 lb/1,000 gallons. Bottom 

loading is required for transferring gasoline into delivery vehicles. All gasoline transfer 

equipment shall be maintained leak-free, vapor tight and in good working condition. The 

vapor recovery system shall be operated and maintained to prevent pressure in the tank 

from exceeding 18” water column during loading. 

District Rule 4624 is compared to Bay Area AQMD Regulation 8 Rule 33 under the 

following categories: 

Applicability/Exemption: 

The applicability is the same for both rules. San Joaquin Valley APCD has one rule 

(4624) that applies to loading/transfer operations regardless of the type of facility doing 

the loading/transfer, whereas Bay Area AQMD applies the loading/transfer requirements 

through three different facility-specific rules. 

Exemptions are fairly comparable between the two rules. The main exemption provided 

by District Rule 4624 is the throughput exemption for facilities transferring less than 

4,000 gallons of liquid per day, whereas the main exemption offered by Bay Area 

AQMD Regulation 8 Rule 33 is loading of delivery vehicles that serve small tanks or 

tanks without vapor recovery. 

Requirements: 

There is no significant difference between the two rules under this category. 

Source Testing and Monitoring: 

There is no significant difference between the two rules under this category. 

Reporting: 

There is no significant difference between the two rules under this category. 

Record Keeping: 

District Rule 4624 is more stringent under this category because it requires records to 

be retained for at least 5 years, whereas Bay Area AQMD Regulation 8 Rule 33 has no 

record retention requirement. 

The preceding comparison demonstrates that, taking all the comparison categories into 

consideration, District Rule 4624 is as stringent as Bay Area AQMD Regulation 8 Rule 33. 

Both rules offer fairly comparable exemptions, and require the use of a vapor recovery 

system with a VOC emission limit of 0.08 lb/1,000 gallons and bottom loading. 
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E. Bay Area AQMD Regulation 8 Rule 39 

 

The purpose of Bay Area AQMD Regulation 8 Rule 39, Gasoline Bulk Plants and 

Gasoline Delivery Vehicles, is to limit emissions of organic compounds from transfer 

operations at gasoline bulk plants and delivery vehicles. 

The rule provides the following exemptions: (a) delivery vehicles delivering exclusively 

to small tanks (< 550 gallons) or tanks for which vapor recovery is not feasible; (b) spills 

resulting from maintenance and repair. 

The rule requires loading of gasoline to be done only using a vapor recovery system 

which limits VOC vapor emissions into the atmosphere to 0.50 lb/1,000 gallons. All 

gasoline transfer equipment shall be maintained leak-free, vapor tight and in good 

working condition. The vapor recovery system shall be operated and maintained to 

prevent pressure in the tank from exceeding 18” water column during loading. 

District Rule 4624 is compared to Bay Area AQMD Regulation 8 Rule 39 under the 

following categories: 

Applicability/Exemption: 

The applicability is the same for both rules. San Joaquin Valley APCD has one rule 

(4624) that applies to loading/transfer operations regardless of the type of facility doing 

the loading/transfer, whereas Bay Area AQMD applies the loading/transfer requirements 

through three different facility-specific rules. 

Exemptions are fairly comparable between the two rules. The main exemption provided 

by District Rule 4624 is the throughput exemption for facilities transferring less than 

4,000 gallons of liquid per day, whereas the main exemption offered by Bay Area 

AQMD Regulation 8 Rule 39 is loading of delivery vehicles that serve small tanks or 

tanks without vapor recovery. 

Requirements: 

District 4624 is more stringent under this category because it requires a vapor recovery 

system with a VOC emission limit of 0.08 lb/1,000 gallons, whereas Bay Area AQMD 

Regulation 8 Rule 39 allows VOC emissions up to 0.50 lb/1,000 gallons from the vapor 

recovery system. Rule 4624 also requires bottom loading, whereas Bay Area AQMD 

Regulation 8 Rule 39 does not. 

Source Testing and Monitoring: 

There is no significant difference between the two rules under this category. 
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Reporting: 

There is no significant difference between the two rules under this category. 

Record Keeping: 

District Rule 4624 is more stringent under this category because it requires records to 

be retained for at least 5 years, whereas Bay Area AQMD Regulation 8 Rule 39 has no 

record retention requirement. 

The preceding comparison demonstrates that, taking all the comparison categories into 

consideration, District Rule 4624 is more stringent than Bay Area AQMD Regulation 8 

Rule 39. Both rules offer fairly comparable exemptions, but Rule 4624 has a more 

stringent VOC emission limit of 0.08 lb/1,000 gallons and requires bottom loading. 

F. Sacramento Metro AQMD Rule 447 

Sacramento Metro AQMD Rule 447, Organic Liquid Loading, is applicable to the loading 

of organic liquids into any tank truck, trailer, or railroad tank car from a bulk plant or a 

bulk terminal. 

The rule provides an exemption for organic liquids with a vapor pressure of less than 

0.5 psia. 

The rule requires emissions to be limited to 0.08 lb VOC/1,000 gallons for organic liquid 

bulk terminals and 0.6 lb VOC/1,000 gallons for bulk plants. The system of achieving 

the emission limits is not specified. However, the rule further states that for gasoline 

loading a CARB-certified vapor recovery system must be used. Loading equipment 

must be maintained leak-free. 

 

Records required include inspection records and any testing results. Records are 

required to be retained for at least three years. 

District Rule 4624 is compared to Sacramento Metro AQMD Rule 447 under the 

following categories: 

Applicability/Exemption: 

There is no significant difference between the two rules under this category. 

Requirements: 

District 4624 is more stringent under this category because it requires a vapor recovery 

system with a VOC emission limit of 0.08 lb/1,000 gallons (or 95% control efficiency for 

facilities with less than 20,000 gallons throughput) for all loading operations, whereas 
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Sacramento Metro AQMD Rule 447 allows emission as high as 0.6 lb VOC/1,000 

gallons for loading operations at bulk plants. 

Source Testing and Monitoring: 

There is no significant difference between the two rules under this category. 

Reporting: 

There is no significant difference between the two rules under this category. 

Record Keeping: 

District Rule 4624 is more stringent under this category because it requires records to 

be retained for at least 5 years, whereas Sacramento Metro AQMD Rule 447 requires a 

record retention period of only 3 years. 

The preceding comparison demonstrates that, taking all the comparison categories into 

consideration, District Rule 4624 is more stringent than Sacramento Metro AQMD Rule 

447. 

 

G. Ventura County APCD Rule 70 

Ventura County APCD Rule 70, Storage and Transfer of Gasoline, is applicable to the 

storage and transfer of gasoline. 

The rule provides several exemptions for: (a) gasoline bulk plants where the average 

daily gasoline throughput has not exceeded 4,000 gallons on a thirty day rolling average 

and the gasoline throughput has not exceeded 200,000 gallons on a twelve month 

rolling average; (b) gasoline bulk plants that load exclusively to gasoline delivery 

vessels that service only storage containers that are not required to be equipped with 

Phase I vapor recovery systems; 

The rule requires the transfer of gasoline at bulk plants to be done only using a vapor 

recovery system that prevents 90 percent of the displaced vapors from being released 

into the atmosphere, and has a maximum emissions factor of 0.84 lbs of hydrocarbon 

emitted per 1000 gallons of throughput. For transfers at gasoline terminals, the vapor 

recovery system shall have a VOC emission limit of 0.08 lb/1,000 gallons, and only 

bottom loading shall be used. Switch-loading at bulk plants or terminals must be done 

only with the use of a vapor recovery system. Vapor recovery equipment shall be 

maintained leak-free and in good working order. 

Records required include throughput records and delivery destination records needed to 

substantiate gasoline loading vapor recovery exemption; and vapor recovery system 

maintenance records. 
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Records are required to be retained for up to two years. 

District Rule 4624 is compared to Ventura County APCD Rule 70 under the following 

categories: 

Applicability/Exemption: 

The applicability is the same for both rules. San Joaquin Valley APCD has one rule 

(4624) that applies to loading/transfer operations regardless of the type of facility doing 

the loading/transfer, whereas Ventura County APCD applies the loading/transfer 

requirements through two different facility-specific rules. 

Exemptions are fairly comparable between the two rules. The main exemption provided 

by District Rule 4624 is the throughput exemption for facilities transferring less than 

4,000 gallons of liquid per day, whereas Ventura County APCD Rule 70 provides a 

throughput exemption and also an exemption for gasoline loads destined for vapor 

recovery-exempt tanks. Ventura County APCD Rule 70’s exemption is stricter (4,000 

gallons per month and 200,000 gallons per year. 

Requirements: 

District 4624 is more stringent under this category because it requires a vapor recovery 

system with a VOC emission limit of 0.08 lb/1,000 gallons, or 95% control efficiency 

depending on facility throughput, whereas Ventura County APCD Rule 70 allows VOC 

emissions up to 0.84 lb/1,000 gallons (or 90% control efficiency) for bulk plant gasoline 

transfer vapor recovery systems. Rule 4624 also requires bottom loading, whereas 

Ventura County APCD Rule 70 does not require bottom loading for bulk plants. 

Source Testing and Monitoring: 

There is no significant difference between the two rules under this category. 

Reporting: 

There is no significant difference between the two rules under this category. 

Record Keeping: 

District Rule 4624 is more stringent under this category because it requires records to 

be retained for at least 5 years, whereas Ventura County APCD Rule 70 requires a 

record retention period of only 2 years. 

The preceding comparison demonstrates that, taking all the comparison categories into 

consideration, District Rule 4624 is more stringent than Ventura County APCD Rule 70. 

Both rules offer fairly comparable exemptions, but Rule 4624 has a more stringent VOC 

emission limit of 0.08 lb/1,000 gallons for liquid transfer vapor recovery systems, and 

also requires bottom loading. 
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H. Ventura County APCD Rule 71.3 

Ventura County APCD Rule 71.3, Transfer of Reactive Organic Compound Liquids, is 

applicable to equipment used to transfer reactive organic compound (ROC) liquids with 

a Modified Reid Vapor Pressure (MRVP) greater than or equal to 0.5 psia. 

The rule provides several exemptions for: (a) organic liquid with a modified Reid Vapor 

Pressure of less than 0.5 psia; (b) transfer, production or separation of crude oil; (c) 

tank marker calibration activities. 

The rule requires the use of submerged fill pipe or bottom loading for transfer of organic 

liquids. For facilities with a throughput of 20,000 gallons per day or 150,000 gallons per 

year, a vapor recovery system must be used during liquid transfer and collected vapors 

condensed and sent into a gas pipeline of treated in a vapor treatment system capable 

of a 90% destruction efficiency. An overfill protection device is also required during 

loading. The loading equipment shall be leak-free and the vapor recovery system shall 

be operated and maintained so that it does not cause the pressure in any delivery 

vessel to exceed 18 inches water gauge or the vacuum to exceed 6 inches water 

gauge. 

The rule requires operators to annually monitor one complete loading operation for 

leaks and for proper operation of the loading equipment and delivery vessel vapor 

recovery and overfill protection systems, and notify the APCD within 72 hours if any 

problems were detected. 

Records required include inspection records, throughput and vapor pressure records 

needed to substantiate exemptions; and vacuum truck loading records. 

Records are required to be retained for at least two years. 

District Rule 4624 is compared to Ventura County APCD Rule 71.3 under the following 

categories: 

Applicability/Exemption: 

The applicability is the same for both rules. San Joaquin Valley APCD has one rule 

(4624) that applies to loading/transfer operations regardless of the type of facility doing 

the loading/transfer, whereas Ventura County APCD applies the loading/transfer 

requirements through two different facility-specific rules. 

District Rule 4624 is more stringent in the exemptions provided because it exempts only 

facilities transferring less than 4,000 gallons of liquid per day, whereas Ventura County 

APCD Rule 71.3 basically exempts (by not requiring a vapor recovery system) loading 

operations where the throughput is less than 20,000 gallons per day. 
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Requirements: 

District 4624 is more stringent under this category because it requires a vapor recovery 

system with a VOC emission limit of 0.08 lb/1,000 gallons, or 95% control efficiency 

depending on facility throughput, whereas Ventura County APCD Rule 71.3 requires 

only a 90% control efficiency for the vapor recovery system. 

Source Testing and Monitoring: 

There is no significant difference between the two rules under this category. 

Reporting: 

There is no significant difference between the two rules under this category. 

Record Keeping: 

District Rule 4624 is more stringent under this category because it requires records to 

be retained for at least 5 years, whereas Ventura County APCD Rule 71.3 requires a 

record retention period of only 2 years. 

The preceding comparison demonstrates that, taking all the comparison categories into 

consideration, District Rule 4624 is more stringent than Ventura County APCD Rule 

71.3. 

Conclusion

After evaluation of federal rules and regulations as well as prohibitory rules in other 

California nonattainment areas, District staff concludes that District Rule 4624 satisfies 

RACT for Transfer of Organic Liquid. 
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Rule 4625 – Wastewater Separators 

Emissions Inventory:

 Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

VOC 0.17 0.17 0.17 0.17 0.17 0.17 0.17 0.19 

(Source: District 2007 Ozone Plan) 

District Rule Description

Rule 4625, amended on December 17, 1992, applies to wastewater separators. The 

rule does not apply to the separation of crude oil and water prior to custody transfer. 

The rule prohibits the use of any compartment of any vessel or device operated for the 

recovery of oil or tar from effluent water, from equipment which processes, refines, 

stores, or handles petroleum or coal tar products unless such compartments are 

equipped with one of the following: (1) a solid cover with all openings sealed and totally 

enclosing the liquid contents of the compartment; (2) a floating pontoon or double deck 

type cover with closure seals that meet specific requirements of the rule; or (3) a vapor 

recovery system with a combined collection and control efficiency of at least 90%. 

Control devices must be under District permit. Any gauging and sampling device in the 

compartment cover must be equipped with a cover or lid, which must be closed at all 

times except when the device is in actual use. Although not specifically indicated in Rule 

4625, components that are used in refinery wastewater separator operations are also 

subject the leak standards, inspection and repair provisions specified in Rule 4455 

(Components at Petroleum Refineries, Gas Liquids Processing Facilities, and Chemical 

Plants). 

How does District Rule 4625 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

EPA-450/2-77-025 (Control of Refinery Vacuum Producing Systems, Water Separators 

and Process Unit Turnarounds), October 1977, indicates that RACT for wastewater 

separators requires control of VOC emissions by covering the forebays and separator 

sections to minimize the amount of oily water exposure to the atmosphere. The 

requirements include a solid cover with all openings sealed totally enclosing the 

compartment liquid contents; or a floating pontoon or double deck type cover, equipped 

with closure seals to enclose the space between the cover’s edge and compartment 

wall. Rule 4625 control requirements are basically the same as the CTG. 

EPA also published a Draft CTG (EPA-453/D-93-056) dated September 1992 for control 

of VOC emissions from industrial wastewater. EPA has not yet finalized the draft CTG. 

In April 1994, EPA published an ACT document: Air Emissions from Industrial 
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Wastewater. The ACT consists of cover memo with option tables and a draft CTG. 

Since the draft CTG has not been finalized by EPA, District staff believes that it would 

not be appropriate to consider it for RACT determinations. 

B. EPA – Alternative Control Techniques (ACT) Document 

As discussed above, in April 1994, EPA published an ACT document: Air Emissions 

from Industrial Wastewater. The ACT consists of cover memo with option tables and a 

draft CTG. Since the draft CTG has not been finalized by EPA, District staff believes 

that it would not be appropriate to consider it for RACT determinations. 

C. Standards of Performance for New Stationary Sources (NSPS) 

40 CFR 60 Subpart QQQ (Standards of Performance for VOC Emissions from 

Petroleum Refinery Wastewater Systems), also known as a New Source Performance 

Standard (NSPS) applies to petroleum refineries for which construction, modification, or 

reconstruction is commenced after May 4 1987. The NSPS requires a fixed roof that 

completely covers oil water separator tanks, slop oil tanks, storage vessels, or other 

auxiliary equipment with no separation between the roof and wall including certain 

requirements that are basically similar to Rule 4625. As an alternative to operating a 

fixed roof cover, the NSPS allows an operator to operate a floating roof cover provided it 

meets certain requirements specified in the NSPS. Rule 4625 seal gap requirement 

(i.e., gap between the seal and the separator wall) is more stringent than specified in 

the NSPS. It should be noted that any tank or vessel could be subject to the VOC 

emission control requirements of Rule 4623 (Storage of Organic Liquids) depending on 

the tank size and the TVP of the organic liquid. Rule 4623 includes a design and 

operational requirements for floating roof tanks. Overall, Rule 4625 is as stringent as 

the NSPS. There are only six facilities that operate a total of eight permitted oil/water 

separators in the District. Seven of the eight wastewater separators are located in 

petroleum refineries which are subject to the NSPS requirements by permit conditions. 

One is a liquid waste management company (non-refinery) wastewater separator so it is 

not subject to the NSPS. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

40 CFR 63 Subpart VV (National Emission Standards for Oil-Water Separators and 

Organic-Water Separators) requires a fixed roof or a floating roof to control emissions 

from wastewater separators. The design and operational requirements for a fixed roof 

are essentially similar to Rule 4625. The allowable gap between the primary seal and 

the separator wall perimeter is 3.8 cm (1.469 inch) and for secondary seal the gap 

allowance is 1.3 cm (0.5 inch). The gap allowances are greater than 0.125 inch gap 

allowed by Rule 4625. Based on the above discussion, District staff believes that is as 

stringent as the NESHAP/MACT standards. 
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How does District Rule 4625 compare to rules in other air districts?

District staff reviewed other nonattainment California air districts’ rules (South Coast Air 

Quality Management District (SCAQMD), Bay Area Air Quality Management District 

(BAAQMD), Sacramento Air Quality Management District (SMAQMD) and Ventura 

County Air Pollution Control District (VCAPCD) that control the VOC emissions from 

wastewater separators as discussed below. 

A. SCAQMD Rule 1176 (VOC Emissions from Wastewater Systems), amended 

September 13, 1996 

SCAQMD Rule 1176 requires either a fixed roof cover equipped with a closed vent 

system vented to a control device, or a floating roof cover, with seals, which meets 

certain specific design and operational requirements. Wastewater separators with fixed 

roof covers are not required to be equipped with closed vent system if the hatches on 

covers are kept closed and free of gaps except when opened for active inspection, 

maintenance, sampling, or repair. This requirement is essentially as stringent as Rule 

4625 requirement for fixed roof cover requiring all openings be sealed, and any gauging 

and sampling device in the cover be equipped with a cover or lid which must be in a 

closed position at all times except when the device is in actual use. The seal gap 

requirements of Rule 1176 (i.e., gap between the separator wall and the seal does not 

exceed 1/8 inch for a cumulative length of 97% of the perimeter the separator, and no 

gap between the wall and the seal must exceed 1⁄2 inch) are similar to Rule 4625. 

District staff believes that the VOC control requirements of Rule 4625 are equivalent to 

SCAQMD Rule 1176. 

B. BAAQMD Regulation 8 Rule 8 (Organic Compounds – Wastewater Collection and 

Separation Systems), amended September 15, 2004 

BAAQMD Regulation 8 Rule 8 requires fixed roof covers or a floating roof covers on 

wastewater separators and/or forebays that meet specific design and operational 

requirements. Rule 8 fixed roof cover requires that no gap greater than 0.32 cm (0.125 

inch) to occur in the roof or between the roof and the wall. In comparison Rule 4625 

does not allow any gap on the roof or between the roof and wall, except for breathing 

vents as are structurally necessary. 

In lieu of a fixed cover, BAAQMD Regulation 8, Rule 8 allows the operation of a floating 

pontoon or double deck vapor-tight cover that must rest entirely on the liquid surface, 

and consists of a primary seal and secondary seal. Rule 8 specifies that no gap 

between the wall and the primary seal should not exceed 1.5 inch; no continuous gap 

greater than 0.125 inch should exceed 10% of the perimeter of the separator; the 

cumulative length of all primary seal gaps exceeding 0.5 inch should be not more than 

40 percent of the perimeter. For secondary seal, the gap between the wall and the 

secondary and wiper seals should not exceed 0.06 inch; the cumulative length of all 

secondary and wiper seal gaps exceeding 0.02 inch should not be more than 5% of the 

perimeter of the separator. 
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In comparison, Rule 4625 requires a floating pontoon or double deck type cover with 

primary and secondary seals installed and maintained so that gaps between the 

compartment wall and seal should not exceed 1/8 inch (0.125 inch) for an accumulative 

length of 97% of the perimeter of the tank, and should not exceed 1⁄2 inch for a 

cumulative length of the remaining 3% of the perimeter of the tank. No gap between the 

compartment wall and the seal shall exceed 1⁄2 inch. Rule 4625 is more stringent than 

BAAQMD Regulation 8, Rule 8 for primary seal (i.e., 0.125 inch for 97 percent versus 

0.125 for 90 percent of the perimeter of the tank). The difference in secondary seal 

gap between Rule 4625 and Rule 8 (i.e., 0.125 inch versus 0.06 inch for secondary seal 

gap) is relatively small such that the overall VOC emissions reduction is not significantly 

affected. It is important to note that there are no wastewater separators with a floating 

roof permitted for operation in the District. 

C. VCAPCD Rule 74.8 (Refinery Vacuum Producing Systems, Wastewater Separators 

and Process Turnarounds), amended July 5, 1983 

VCAPCD Rule 74.8 prohibits the use of any distribution header or compartment of a 

wastewater separator unless the header or compartment is equipped with a solid cover 

with all openings sealed totally enclosing the compartment liquid contents except for 

breathing vents as are structurally necessary, or equipped with a floating cover which 

extends to within 0.125 inches of the wall of the compartment or header at all points on 

the perimeter of the cover except for over a cumulative length of no more than 3 percent 

of the perimeter; for over 3 percent of the perimeter, the cover should extend to within 

0.5 inches of the wall. 

In comparison, Rule 4625 requires a floating pontoon or double deck type cover with 

primary and secondary seals installed and maintained so that gaps between the 

compartment wall and seal should not exceed 1/8 inch (0.125 inch) for an accumulative 

length of 97% of the perimeter of the tank, and should not exceed 1⁄2 inch for a 

cumulative length of the remaining 3% of the perimeter of the tank. No gap between the 

compartment wall and the seal shall exceed 1⁄2 inch. Based on the above discussion, 

District staff believes that the VOC control requirements of Rule 4625 are equivalent to 

VCAPCD Rule 74.8. 

D. SMAQMD has no rule for wastewater separators. 

Conclusion

District staff concludes that District Rule 4625 satisfies RACT for Wastewater 

Separators. 
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Rule 4641 (Cutback, Slow Cure, and Emulsified Asphalt, Paving and 

Maintenance Operations) 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 0 0 0 0 0 0 0 0

VOC 2.3 2.3 2.3 2.3 2.4 2.4 2.4 2.7

(Source: District 2007 Ozone Plan) 

District Rule 4641 Description

District Rule 4641 applies to the manufacturing and use of cutback asphalt, slow cure 

asphalt, and emulsified asphalt for paving and maintenance operations. The rule does 

not apply to the manufacturing of cutback asphalt or emulsified asphalt where such 

materials are for shipment and use outside the District. The rule prohibits manufacture 

for sale or use in the District for penetrating prime coat, tack coat, dust palliative, or 

other paving and maintenance operations any rapid cure cutback asphalt, medium cure 

asphalt, slow cure asphalt containing more than 0.5 % organic compounds which 

evaporate at 500OF or lower, and emulsified asphalt containing more than 3% by 

volume organic compounds which evaporate at 500OF. Manufacturers of cutback, slow 

cure, or emulsified asphalt for dust palliative or other road paving and maintenance 

operations are required to keep daily records showing the types and amount of organiccompounds containing asphalt produced and the destination of such products. Users of 

such asphalt must also keep records of the types and amount of asphalt received, and 

the amounts used. 

District Rule 4641 does not apply to the manufacture of cutback asphalt or emulsified 

asphalt in the manufacturing of paving materials where such materials are for shipment 

and use outside the District. The use of medium cure asphalt is allowed where the 

National Weather Service official forecast of the high temperature for the 24 hour period 

following application is below 500

F. 

How does District Rule 4641 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

EPA-450-2-77-037 (Control of Volatile Organic Compounds from Use of Cutback 

Asphalt) 

This CTG establishes the recommended standards to control of VOC emissions from 

paving asphalts liquefied by petroleum distillates. Liquefied asphalt is generally referred 

to as cutback asphalt. The VOC content of cutback asphalt ranges from 20 to 50 

percent by volume. VOC emissions occur as the cutback asphalt evaporates. The CTG 
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indicates that the control technique for reducing VOC emissions from the cutback 

asphalt for paving application is to substitute an emulsifying agent or water for the 

petroleum distillates. Emulsified asphalt consist of asphalt suspended in water (98%) 

containing emulsifier (2%). “Federal RACT for cutback asphalt is defined in terms of 

substitution of emulsified asphalt for cutback asphalt, rather than in terms of emission 

limit.”14 The substitution of emulsified asphalt reduces VOC emissions by 0.78 tons per 

ton of slow cured asphalt, 0.209 tons per ton of medium cured asphalt, and 0.204 tons 

per ton of rapid cure asphalt. The CTG does not indicate any specific VOC content 

limits for cutback asphalt and emulsified asphalt. 

Rule 4641 prohibits manufacture for sale or use in the District for penetrating prime 

coat, tack coat, dust palliative, or other paving and maintenance operations any rapid 

cure cutback asphalt, medium cure asphalt, slow cure asphalt containing more than 0.5 

% organic compounds which evaporate at 500OF or lower, and emulsified asphalt 

containing more than 3% by volume organic compounds which evaporate at 500OF. 

Based on the above discussion, District staff deems that District Rule 4641 is as 

stringent as the CTG. 

In response to April 1, 2009 EPA comments recommending the District explain why 

Rule 4641 exempts the use of medium cured asphalt when the ambient temperature is 

less than 500

F, District staff has included the following information: 

• The exemption for medium cured asphalt during colder ambient temperatures 

which occurs during winter (non-ozone) season is similar to EPA’s Blue Book on 

Cutback and Emulsified Asphalt recommended seasonal exemptions (i.e., 

outside of the ozone season) as opposed to temperature forecasting (e.g., 

applied when <500

F). 

• During colder ambient temperature, VOCs do not evaporate rapidly especially 

from medium cured asphalt that is limited by Rule 4641 to no more than 5% 

organic compounds that evaporate at 500OF. 

• Road construction and road repairs using asphalt are very minimal during the 

colder winter months, except for emergency road repairs. In addition, during 

winter months the San Joaquin Valley experiences the majority of rainy season 

and asphalt will not properly cure or harden when there is moisture on the 

surfaces or areas where asphalt is applied. 

• District staff agrees with SCAQMD’s Technical Assessment for SCAQMD Rule 

1108 (Cutback Asphalt), dated June 2008 that other states (Maine, Missouri, 

New York, Pennsylvania, and Rhode Island) who have adopted rules on cutback 

asphalt that prohibit their use during ozone season, but provided specific 

exemptions for applications they are actually used (e.g., prime coats, stockpiled 

material for pothole and road patching, dust pallatives, etc.) completely negates 

 

14 EPA-453/R-95-010 (Beyond Volatile Organic Compound – Reasonably Available Control Technology – Control 

TechnIques Guidelines Requirements) 
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the seasonal restriction. As such, Rule 4641 exemption for medium cured 

asphalt during colder ambient temperatures is more stringent than the seasonal 

exemption recommended by the EPA Blue Book, and therefore meets RACT. 

B. EPA – Alternative Control Techniques (ACT) Document 

District staff’s review of the EPA ACT list indicates that there is no ACT for cutback 

asphalt, slow cure asphalt, or emulsified asphalt. 

C. Standards of Performance for New Stationary Sources (NSPS) 

40 CFR 60 (Standards of Performance for New Sources) does not specify any NSPS for 

cutback asphalt, slow cure asphalt, and emulsified asphalt. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

40 CFR 61 (NESHAP) and 40 CFR (NESHAP for Source Categories) do no specify any 

NESHAP or MACT for cutback asphalt, slow cure asphalt, and emulsified asphalt. 

How does District Rule 4641 compare to rules in other air districts?

District staff compared emission limits, optional control requirements, and work practice 

standards in District Rule 4641 to comparable requirements in rules from the following 

California nonattainment areas: 

• South Coast AQMD Rule 1108 (Cutback Asphalt) amended February 1, 1985 

• South Coast Air Quality Management District (SCAQMD) Rule 1108.1 (Emulsified 

Asphalt) amended November 4, 1983 

• Bay Area Air Quality Management District (BAAQMD) Regulation 8 Rule 15 

(Emulsified and Liquid Asphalts) amended June 1, 1994 

• Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 453 

(Cutback and Emulsified Asphalt Paving Materials) amended August 31, 1982 

• Ventura County Air Pollution Control District (VCAPCD) Rule 74.4 (Cutback Asphalt) 

amended July 5, 1983 

A. South Coast Air Quality Management District (SCAQMD) Rule 1108 

(Cutback Asphalt) 

SCAQMD Rule 1108 prohibits the sale or offer for sale for use in the South Coast any 

cutback asphalt containing more than 0.5% by volume organic compounds which 

evaporate at 2600

C (5000F) or lower. The rule does not apply to the use of cutback 

asphalt that is subject to other SCAQMD Regulation XI, or specifically exempted in such 

rules. There are no specific recordkeeping requirements in SCAQMD Rule 1108. 
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The organic compounds limit of cutback asphalt in SCAQMD Rule 1108 is the same as 

the limit for slow cure asphalt in District Rule 4641. Unlike District Rule 4641, SCAQMD 

Rule 1108 allows the use of cutback asphalt (rapid cure, medium cure, and slow cure) if 

the organic content is no more than 0.5% by volume organic compounds which 

evaporate at 2600

C (5000F) or lower. District Rule 4641 only allows use of medium 

asphalt where the National Weather Service official forecast of the high temperature for 

the 24 hour period following application is below 500

F. Based on the above discussion, 

District staff deems that District Rule 4641 is more stringent than SCAQMD Rule 1108. 

B. South Coast Air Quality Management District (SCAQMD) Rule 1108.1 

(Emulsified Asphalt) 

SCAQMD Rule 1108.1 prohibits the sale, offer for sale for use, or use within the air 

district, any emulsified asphalt containing more than 3% by volume organic compounds 

which evaporate at 2600

C (5000F) or lower. The rule does not apply to the use of 

emulsified asphalt that is subject to other SCAQMD Regulation XI, or specifically 

exempted in such rules. There are no specific recordkeeping requirements in SCAQMD 

Rule 1108. 

District rule 4641 is as stringent as SCAQMD Rule 1108.1 because organic compounds 

content limit for emulsified asphalt are the same. 

C. Bay Area Air Quality Management District (BAAQMD) Regulation 8 Rule 15 

(Emulsified and Liquid Asphalts) 

BAAQMD Regulation 8 Rule 15 limits the emissions of volatile organic compounds 

caused by the use of emulsified and liquid asphalt in paving materials and paving and 

maintenance operations. It prohibits the manufacture, offer for sale, or sell a liquid 

asphalt which will be applied at any physical location within BAAQMD. The rule 

contains monitoring and recordkeeping requirements. The rule prohibits use of the 

following asphalt in paving material or in paving and maintenance operations: 

• Rapid cure asphalt 

• Medium cured asphalt (except during cool weather (National Weather Service 

Forecasts atmospheric temperature for the 24 hour period following application 

will not exceed 100

C (500F). 

• Emulsified asphalt containing petroleum solvents in excess of 3% by volume. 

• Slow cure asphalt (road oil) which contains more than 0.5% by volume petroleum 

solvents which boil at less than 2600

C (5000F). 

 

BAAQMD Regulation 8 Rule 15 prohibitions and organic compound limits for cutback 

asphalt (rapid cure, medium cure, and slow cure) and emulsified asphalt are the same 

as District Rule 4641. BAAQMD Regulation 8 Rule 15 that allows the use of medium 

cure asphalt during cold weather condition is the same as the exemption in District Rule 

4641. Based on the above discussion, District staff deems that District Rule 4641 is as 

stringent as BAAQMD Regulation 8 Rule 15. 
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D. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 

453 (Cutback and Emulsified Asphalt Paving Materials) 

SMAQMD Rule 453 limits the emissions of VOC from the use of cutback and emulsified 

asphalt in paving materials, paving and maintenance operations. The rule prohibits the 

manufacture for sale or use in Sacramento Metropolitan air district for paving, road 

construction or road maintenance any rapid cure or medium cure cutback asphalt; slow 

cure cutback asphalt containing organic compounds which evaporate at 2600

C (5000F) 

or lower; and emulsified asphalt (slow cure, medium cure, and rapid cure) containing 

more than 3% organic compounds which evaporate at 2600C (5000F). 

SMAQMD Rule 453 does not apply to use of cutback (rapid cure and medium cure) and 

emulsified asphalt in the manufacturing of paving materials if such materials are for 

immediate shipment and eventual use outside of the County of Sacramento, California. 

The rule does not apply to the use of medium cure cutback asphalt as a penetrating 

prime coat until such time that as the APCO determines that a suitable substitute 

material is available. 

SMAQMD Rule 453 prohibition on the use of rapid and medium cure asphalt is the 

same as District 4641, except that District Rule 4641 specifies that slow cure asphalt 

must not have more than 0.5% organic compounds which evaporate at 5000

F or lower 

while SMAQMD Rule 453 only specifies that slow cure asphalt must not contain organic 

compounds that evaporate at 5000F or lower. In addition, SMAQMD exempts the use of 

medium cure cutback asphalt as penetrating prime coat within their air district until a 

suitable substitute material becomes available while District Rule 4641 exempts use of 

medium cure asphalt only when the weather temperature for the 24 hour period 

following application is predicted below 500

F. Based on the above discussion, District 

staff deems that District Rule 4641 is more stringent than SMAQMD Rule 453

E. Ventura County Air Pollution Control District (VCAPCD) Rule 74.4 (Cutback 

Asphalt) 

VCAPCD Rule 74.4 prohibits the manufacture, sale, or offer for sale, use or application 

of rapid cure cutback asphalt for highway or street paving or maintenance, except if it is 

to be used as a penetrating prime coat or where the National Weather Service official 

forecast of the high temperature for the 24 hour period following application is below 

500

F (100C). In the South Zone, VCAPCD Rule 74.4 prohibits the use or application of 

emulsified asphalt containing more than 3% by volume petroleum solvents (diluents) or 

cutback asphalt for highway or street paving maintenance. The rule prohibits the use of 

road oils (slow cure asphalt) containing more than 0.5% organic compounds which boil 

at less than 5000

F for highway or street paving or maintenance applications. VCAPCD 

Rule 74.4 prohibits manufacture, sale, or offer for sale cutback asphalt for use or 

application within Ventura County. VCAPCD Rule 74.4 does not have any 

recordkeeping requirements. 
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Both VCAPCD Rule 74.4 and District Rule 4641 prohibits the use of rapid cure cutback 

asphalt, emulsified asphalt containing more than 3% by volume petroleum solvents, 

slow cure asphalt that contains more than 0.5% organic compounds which boil at less 

than 5000

F for highway or street paving or maintenance applications. District Rule 4641 

allows the use of medium cure asphalt only if the official weather forecast of the high 

temperature for the 24 hour period following application is below 500F (100C), but 

VCAPCD Rule 74.4 allows the use or application of cutback asphalt if it is to be used as 

a penetrating prime coat or where the weather forecast is below 500

F (100C) the 24 

hour period following application. District Rule 4641 has recordkeeping requirements 

while VCAPCD Rule 74.4 has none. Based on the above discussion District staff 

deems District Rule 4641 is more stringent than VCAPCD Rule 74.4. 

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4641 

satisfies RACT for cutback and emulsified asphalt. 
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Rule 4642 – Solid Waste Disposal Sites 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

VOC 1.6 1.7 1.8 1.8 1.9 1.9 2.0 2.1 

(Source: District 2007 Ozone Plan) 

District Rule 4642 Description

The purpose of this rule is to reduce volatile organic compound (VOC) emissions from 

solid waste disposal sites. The rule applies to any solid waste disposal site which has a 

gas collection system and/or control device in operation, or undergoing maintenance or 

repair. The rule exempts active disposal areas in a landfill, landfills which are subject to 

the requirements of 40 CFR 60 Subpart WWW (Standards of Performance for Municipal 

Solid Waste Landfills), or Subpart Cc (Emission Guidelines and Compliance Times for 

Municipal Solid Waste Landfills), and hazardous waste disposal sites. Temporary 

exemption is also provided during maintenance of the landfill gas collection system 

and/or control device.

The rule requires that the landfill gas collection system be operated in such a manner 

that landfill surface VOC concentrations shall not exceed 1,000 ppmv at any point. The 

rule requires landfill gas to be treated with a control device that achieves a VOC 

destruction efficiency of at least 98 percent by weight, or reduces the VOC 

concentration to 20 ppmv or less (measured as Methane) corrected to 3 percent 

oxygen. For facilities which received Authorities to Construction prior to the rule 

adoption date (July 20, 1995), the rule requires the control device to achieve a VOC 

destruction efficiency of at least 90 percent, or reduce the VOC concentration to 30 

ppmv. 

The rule also requires that whenever buried solid waste is brought to the surface during 

the installation or preparation of wells, trenches, piping, or other equipment or when 

landfill solid waste is excavated or moved, the operator shall cover the excavated solid 

waste using fresh soil, plastic sheeting, or vapor retarding foam as necessary in order to 

prevent odorous emissions and to minimize the release of landfill gas. 

The rule allows the control system to be shut down for up to 144 hours per year for 

maintenance. 

Initial source testing is required to demonstrate the destruction efficiency of the landfill 

gas control system. Annual source testing is also required to measure landfill surface 

VOC concentrations. 

Records are required to be retained for a period of 5 years.
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How does District Rule 4642 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

There is no CTG for this source category. 

B. EPA – Alternative Control Technology (ACT) 

There is no ACT for this source category. 

C. Standards of Performance for New Stationary Sources (NSPS) 

1. 40 CFR 60 Subpart Cc - Emission Guidelines and Compliance Times for Municipal 

Solid Waste Landfills. 

This NSPS applies to landfills that were in existence prior to May 30, 1991. The NSPS 

requires the control of landfill emissions from landfills that have accepted waste at any 

time since November 8, 1987 or have additional design capacity available for future 

waste deposition; have a design capacity greater than or equal to 2.5 million 

megagrams and 2.5 million cubic meters; and have a nonmethane organic compound 

emission rate of 50 megagrams per year or more. Landfills meeting these conditions are 

required to install a landfill gas collection and control system meeting the specifications 

of 40 CFR 60.752(b)(2)(ii), which are summarized below: 

• Collection systems shall be designed to handle the maximum expected gas flow rate 

from the entire area of the landfill; collect gas from each area, cell, or group of cells 

in the landfill in which the initial solid waste has been placed for a period of 5 years 

or more if active (2 years or more if closed or at final grade); collect gas at a 

sufficient extraction rate; and be designed to minimize off-site migration of 

subsurface gas. In addition, passive collection systems must also be installed with 

liners on the bottom and all sides in all areas in which gas is to be collected. 

• Collected landfill gas shall be treated by one of the following methods: 

(1) an open flare designed and operated in accordance with 40 CFR 60.18. 

(2) a control system designed and operated to reduce NMOC by 98 weight-percent, 

or, when an enclosed combustion device is used for control, to either reduce 

NMOC by 98 weight percent or reduce the outlet NMOC concentration to less 

than 20 parts per million by volume, dry basis as hexane at 3 percent oxygen. 

(3) a treatment system that processes the collected gas for subsequent sale or use. 

The gas collection system must be operated in such a manner that the methane 
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concentration on the landfill surface does not exceed 500 ppmv. 

The control system must be operated at all times when gas is routed to it. In the event 

the control system is inoperable, the gas mover system shall be shut down and all 

valves in the collection and control system contributing to venting of the gas to the 

atmosphere shall be closed within one hour. 

Landfills below the capacities specified by the NSPS are required to perform initial 

design capacity and annual emissions calculations to demonstrate continued 

exemption. 

An initial source test is required to demonstrate the destruction efficiency of the control 

system. 

For the purpose of demonstrating whether the gas collection system flow rate is 

sufficient, the owner or operator shall measure gauge pressure in the gas collection 

header at each individual well. 

For the purpose of identifying whether excess air infiltration into the landfill is occurring, 

the owner or operator shall monitor each well monthly for temperature and nitrogen or 

oxygen. 

The owner or operator shall monitor surface concentrations of methane on a quarterly 

basis using an organic vapor analyzer, flame ionization detector, or other portable 

monitor. 

The owner or operator shall implement a program to monitor for cover integrity and 

implement cover repairs as necessary on a monthly basis. 

District Rule 4642 is compared to 40 CFR 60 Subpart Cc under the following categories: 

Applicability/Exemptions: 

40 CFR Subpart Cc applies to landfills that were constructed or modified prior to May 

30, 1991. Control of landfill emissions at each landfill that meets the following 

conditions is required by Subpart Cc: (a) The landfill has accepted waste at any time 

since November 8, 1987, or has additional design capacity available for future waste 

deposition; (b) The landfill has a design capacity greater than or equal to 2.5 

millionmegagrams and 2.5 million cubic meters. The landfill may calculate design 

capacity in either megagrams or cubic meters with the same exemption values; (c) The 

landfill has a NMOC emission rate of 50 megagrams per year or more. Subpart Cc 

requires operators of landfills with a design capacity less than 2.5 million megagrams by 

mass or 2.5 million cubic meters, by volume, to submit an initial design capacity report. 

For landfills with a design capacity equal to or greater than 2.5 million megagrams and 

2.5 million cubic meters, operators are required to calculate the non-methane organic 

compounds (NMOC) using the prescribed methodology. If the calculated NMOC 
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emission rate is less than 50 megagrams per year, the operator must submit an annual 

report and then keep recalculating the emission rate annually until such time as the 

emission rate is equal to or greater than 50 megagrams per year. If the NMOC 

emission rate, upon recalculation, is equal to or greater than 50 megagrams per year, 

the operator must install a collection and control system that complies with the 

requirements specified in Subpart Cc. Compliance schedules are also specified in 

Subpart Cc. 

In comparison with 40 CFR 60 Subpart Cc, Rule 4642 applies to landfills which have a 

gas collection and control device regardless of the design capacity and the date that the 

landfill was constructed or modified. It is important to mention that when Rule 4642 was 

adopted in July 1995, District staff took into consideration that in order to prevent 

excessive methane accumulation (i.e., 1.25% by volume in air) within any portion of any 

on-site structure and in on-site structures and more than 5% by volume in air at the 

disposal site facility boundary, Title 27 of the California Code of Regulations (CCR) 

requires the operation of a gas collection and control system. Landfills subject to CCR 

Title 27 are also required to comply with the requirements for explosive gas control, gas 

monitoring and control, perimeter monitoring well construction, structure monitoring, 

parameter monitoring, monitoring frequency, reporting and control of excessive gas 

concentration, and other requirements. Therefore, to avoid duplication or overlapping of 

state regulatory requirements, Rule 4642 was adopted so it applies to landfills that have 

gas collection and control system with the assumption that landfills that are permitted by 

the state Integrated Waste Management Resources are already rigorously regulated by 

CCR Title 27. Likewise, the exemption for landfills subject to Subparts Cc or WWW are 

intended to avoid duplication or overlapping of regulatory requirements imposed by 

federal and District regulations. Rule 4642 exempts hazardous disposal sites because 

they are already subject to more stringent District operating permit requirements than 

specified in the rule. 

Under Rule 4642, any landfill surface emissions exceeding 1,000 ppmv (measured as 

methane by a portable hydrocarbon analyzer) at any point in the landfill would 

necessitate the installation and operation of a District approved gas collection and 

control system. Based on the above discussion, District staff believes that Rule 4642 

applicability is slightly more stringent than Subpart Cc applicability. 

Requirements: 

District staff believes that Rule 4642 is as stringent as 40 CFR 60 Subpart Cc under the 

following requirements: 

As stated above, Rule 4642 applies to landfills that have a gas collection and control 

system regardless of the design capacity and the date the landfill was constructed or 

modified compared to Subpart Cc which applies only to landfills having a specified a 

design capacity and specific construct or modification date. Although District Rule 4642 

does not require design capacity calculation and annual emissions calculation for 
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landfills that do not have collection and control devices, District staff expects that 

landfills which an excessive surface emissions exceeding 1,000 ppmv would 

necessitate the operation of a gas collection and control system to lower the emissions 

below the threshold. 

Although District Rule 4642 requires a much lower destruction efficiency of 90% (or 

reduction of VOC concentrations to 30 ppmv) for control systems that were permitted 

prior to July 20, 1995, in comparison with 98% control system or 20 ppmv VOC outlet 

concentration required by Subpart Cc, it should be noted that, in general, VOC control 

devices such as flares, thermal oxidizer, combustion devices (engines, turbines, boilers) 

that have a high combustion temperature and longer residence times actually achieves 

at least 98% VOC destruction efficiency. A review of the District Permit database 

indicated that landfills with a gas collection and control system are actually required to 

operate at least 98% destruction efficiency or reduce the VOC concentration to 20 ppmv 

or less, as a condition of the operating permit. Therefore, Rule 4642 is as stringent as 

Subpart Cc control device efficiency. 

District Rule 4642 requires that a gas collection and control system be operated in such 

a manner that the surface emissions testing of the landfill does not exceed 1,000 ppmv 

(measured as methane) at any point on the surface of the landfill or along the gas 

transfer path. Surface emission testing should be performed with by holding the 

portable hydrocarbon detector probe within three inches of the surface of the landfill and 

further specifies the wind speed whereby surface emission testing should be 

terminated. In comparison, Subpart Cc referenced the operational standards specified 

in Subpart WWW that must be met for landfills that exceed the applicability threshold for 

operating a collection and control system. Subpart WWW specified that the collection 

system must be operated so that the concentration is less than 500 ppmv (measured as 

methane above background) with the detector probe placed within 5 to 10 centimeters 

of the ground. Based on District Compliance Division staff’s experience, leak 

measurements taken at a greater distance from the surface of potential leak source 

tend to result in lower emission concentration level due to ambient air dilution compared 

to higher concentration readings taken very close to the leak surface. For this reason, 

District staff believes that Rule 4642 emission threshold of 1,000 ppmv measured within 

3 inches of the landfill surface is at least as stringent as Subpart CC’s 500 ppmv 

measured at 5 to 10 centimeters from the landfill surface. In addition, Subpart Cc does 

not specify any wind velocity for terminating testing but Rule 4642 requires termination 

of surface emissions testing when the average wind speed exceeds five miles per hour 

because excessive wind velocity affects the result of emissions testing. Based on the 

above discussion, District staff believes that Rule 4642 surface emission threshold is 

more stringent than Subpart Cc. 

District Rule 4642 allows for shutdown of the gas collection and control system for 

maintenance purposes provided the District is notified at least 24 hours before 

performing any maintenance work, that the emissions of landfill gas into the atmosphere 

is minimized during shutdown, and that the gas collection and control system should not 

be shutdown for more than 144 cumulative hours in any calendar year. In comparison, 
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Subpart Cc allows deviation from emission standards during periods of start-up, 

shutdown, or malfunction provided the duration does not exceed 5 days for collection 

system and one hour for treatment or control devices. District staff believes that Rule 

4642 limited duration for such maintenance allowance on an annual basis is as stringent 

as provided by Subpart Cc which does not have any limitation on the frequency of startup, shutdown, or malfunction. 

Source Testing: 

There is no significant difference between District Rule 4642 and 40 CFR 60 Subpart Cc 

under this category. 

Monitoring: 

40 CFR 60 Subpart Cc in monitoring requirements. District Rule 4642 does not require 

collection header pressure monitoring, monthly well temperature/Nitrogen/Oxygen 

monitoring, or cover integrity monitoring. Such monitoring requirements appears to be 

directed at ensuring that the elevated parameters do not cause fires (excess air 

infiltration) or significantly inhibit anaerobic decomposition by killing methanogens. In 

comparison, Rule 4642 requires an operator to submit an Emission Control Plan which 

includes, among other things, an engineering evaluation of the expected landfill gas 

generation rate and design specifications which demonstrate that the gas collection 

system will meet the requirements of the rule, description of techniques used to ensure 

that excess vacuum and gas withdrawal resulting in air intrusion into the landfill are 

minimized. Although Rule 4642 does not have identical monitoring requirements, 

District staff believes that the Emission Control Plan requirements are accomplish 

similar concerns for which the above-mentioned parametric monitoring required by 

Subpart Cc. 

Record Keeping: 

There is no significant difference between District Rule 4642 and 40 CFR 60 Subpart Cc 

under this category. 

Based on the above discussion, District staff believes that overall Rule 4642 is as 

stringent as 40 CFR 40 Subpart Cc. 

2. 40 CFR 60 Subpart WWW - Standards of Performance for Municipal Solid Waste 

Landfills. 

This NSPS applies to solid waste landfills that commenced construction, reconstruction 

or modification on or after May 30, 1991. All requirements are similar to those discussed 

under 40 CFR 60 Subpart Cc. 

The District implements 40 CFR 60 Subpart WWW by reference under District Rule 

4001, New Source Performance Standards. A comparison between District Rule 4642 
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and 40 CFR 60 Subpart WWW is therefore not required since there is no overlap 

between sources covered by Rule 4642 (landfills in existence prior to May 30, 1991) 

and those covered by 40 CFR 60 Subpart WWW (landfills constructed or modified on or 

after May 30, 1991). 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There is no NESHAP that could apply to solid waste disposal sites. 

There is one MACT standard that applies to solids waste disposal sites – 40 CFR 63 

Subpart AAAA National Emission Standards for Hazardous Air Pollutants from 

Municipal Solid Waste Landfills. This MACT only requires that affected sources comply 

with the requirements of the NSPS. No different standard that could define an 

applicable RACT for solid waste disposal sites is provided, hence no analysis is 

required. 

How does District Rule 4642 compare to rules in other air districts?

District staff compared emission limits, optional control requirements, and work practice 

standards in District Rule 4642 to comparable requirements in rules from the following 

California nonattainment areas: 

• South Coast AQMD Rule 1150 (adopted 10/15/1982) 

• South Coast AQMD Rule 1150.1 (amended 3/17/2000) 

• Bay Area AQMD Regulation 8 Rule 34 (amended 6/15/2005) 

• Ventura County APCD Rule 74-17-1 (revised 2/9/1999) 

• Sacramento Metro AQMD Rule 485 (amended 7/23/1998) 

A. South Coast AQMD Rule 1150 

South Coast AQMD Rule 1150 (Excavation of Landfill Sites) requires the submission of 

an Excavation Management Plan primarily to prevent nuisance conditions. Although this 

rule does not have a specific standard for VOC emissions, the mitigation measures 

required for the prevention of nuisance conditions also reduce VOC emissions. The rule 

states that mitigation measures such as gas collection and disposal, baling, 

encapsulation, covering of the material, chemical neutralizing, or other measures 

approved by the Executive Officer may be required. 

District Rule 4642 is compared to South Coast AQMD Rule 1150 under the following 

categories: 
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Applicability/Exemption: 

District Rule 4642 is less stringent than South Coast AQMD Rule 1150 because it 

applies only to landfills that were in existence prior to May 30, 1991 and have collection 

and control systems, whereas South Coast AQMD Rule 1150 applies to all landfills. 

Requirements: 

There is no significant difference in requirements between District Rule 4642 and South 

Coast AQMD Rule 1150. Both rules require mitigation measures such as covering using 

fresh soil, plastic sheeting, or vapor retarding foam as necessary in order to prevent 

odorous emissions that may cause a public nuisance. 

Source Testing, Monitoring and Record Keeping: 

There are no source testing, monitoring or record keeping requirements associated with 

landfill excavations. 

B. SCAQMD Rule 1150.1 

South Coast AQMD Rule 1150.1 (Control of Gaseous Emissions From Municipal Solid 

Waste Landfills) requires the installation of a collection and control system capable of 

reducing VOC emissions by at least 98 percent by weight or reducing the outlet VOC 

concentration to less than 20 parts per million by volume (ppmv), dry basis as hexane at 

3 percent oxygen. The rule also requires landfill boundary probes and a limit of 5% by 

volume (50,000 ppmv) for subsurface refuse boundary VOC concentrations. The rule 

has two limits for landfill surface emissions: (1) 50 ppmv (as determined by portable 

integrated bag sampler and lab analysis) for any one 50,000 square foot landfill grid and 

(2) 500 ppmv (as determined by instantaneous monitoring using FID probe) at any 

location on the landfill. The rule has six main monitoring requirements: (1) annual 

source testing of landfill gas control system (2) monthly sampling and analysis of landfill 

gas entering control system (3) monthly sampling and lab analysis for each 50,000 

square foot grid of landfill (4) quarterly instantaneous FID probe sampling for any spot 

on landfill surface (5) monthly boundary ambient air sampling and (6) monthly 

subsurface boundary probes sampling. 

District Rule 4642 is compared to South Coast AQMD Rule 1150.1 under the following 

categories: 

Applicability/Exemption: 

District Rule 4642 applies to landfills that have a gas collection and control system 

regardless of whether the landfills are active or inactive status and date the landfills 

have received waste. Rule 4642 exempts landfills that are subject to 40 CFR 60 

Subpart Cc and Subpart WWW and hazardous waste disposal sites. It is important to 

mention that when Rule 4642 was adopted in July 1995, District staff took into 
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consideration that in order to prevent excessive methane accumulation (i.e., 1.25% by 

volume in air) within any portion of any on-site structure and in on-site structures and 

more than 5% by volume in air at the disposal site facility boundary, Title 27 of the 

California Code of Regulations (CCR) requires the operation of a gas collection and 

control system. Landfills subject to CCR Title 27 are also required to comply with the 

requirements for explosive gas control, gas monitoring and control, perimeter monitoring 

well construction, structure monitoring, parameter monitoring, monitoring frequency, 

reporting and control of excessive gas concentration, and other requirements. 

Therefore, to avoid duplication or overlapping of state regulatory requirements, Rule 

4642 was adopted so it applies to landfills that have gas collection and control system 

with the assumption that landfills that are permitted by the state Integrated Waste 

Management Resources are already rigorously regulated by CCR Title 27. Likewise, 

the exemption for landfills that are subject to Subparts Cc or WWW are intended to 

avoid duplication or overlapping of regulatory requirements imposed by federal and 

District regulations. Rule 4642 exempts hazardous disposal sites because they are 

already subject to more stringent District operating permit requirements than specified in 

the rule. Rule 4642 exempts hazardous disposal sites because they are already subject 

to more stringent District operating permit requirements than specified in the rule. 

SCAQMD Rule 1150.1 applies to active and inactive landfills. Rule 1150.1 defines 

active landfills as landfills that have received waste on and after November 8, 1987. 

Inactive landfills are those where wastes had been disposed of before November 8, 

1987. Rule 1150.1 exempts landfills that operates a collection system such that the 

total organic compounds (TOC), measured as methane, do not exceed 5% by volume 

subsurface boundary sampling probes, and does not exceed 50 ppmv as determined by 

integrated samples taken on a numbered 50,000 square foot landfill grids, and does not 

exceed 500 ppmv above background by instantaneous monitoring at any location on the 

landfill. The rule also exempts landfills that emit less than 55 tons per year of 

nonmethane organic compounds and those that are in compliance with SCAQMD 

Nuisance Rule 402. 

Based on the above discussion, District staff believes that the applicability and 

exemptions of District Rule 4642 are as stringent as SCAQMD rule 1150.1 

Requirements: 

District Rule 4642 allows a VOC destruction efficiency of 90% (or a VOC reduction to 30 

ppmv or less) for landfill gas control equipment permitted before July 20, 1995, and a 

destruction efficiency of at least 98% (or a VOC reduction to 20 ppmv or less) for all 

other permitted control equipment . SCAQMD Rule 1150.1 requires a destruction 

efficiency of 98% (or reduction to 20 ppmv) for all landfill gas control systems. 

As discussed above, although District Rule 4642 does not have any requirements for 

subsurface landfill boundary VOC limits, District staff relied on the premise that landfills 

operating in the San Joaquin Valley air basin are already required to comply with CCR 

Title 27 which, among other requirements, include subsurface and boundary monitoring, 

recordkeeping, and reporting for specified landfill gas emissions. SCAQMD Rule 1150.1 
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requires the use of subsurface landfill boundary sampling probes and a subsurface 

landfill boundary VOC limit of 5% by volume. 

District Rule 4642 requires a landfill surface VOC emission concentration limit of 1,000 

ppmv or less, whereas South Coast AQMD Rule 1150.1 requires the higher limits of 50 

ppmv measure by integrated sample on any 50,000 square foot grid and 500 ppmv 

instantaneous sample taken at any point on the landfill surface. 

District Rule 4642 does not specifically have any requirement for the cessation 

atmospheric venting of landfill gas when the control system is inoperable, whereas 

South Coast AQMD Rule 1150.1 requires that when the treatment or control system is 

inoperable the gas conveying system and all valves in the collection, treatment and 

control system contributing to venting of the gas to the atmosphere shall be shut down 

within one hour. However, District rule 4642 has specific requirements that the gas 

collection and control system be operated in a manner which maximizes the amount of 

landfill gas extracted while preventing overdraw causing fires or damage to the 

collection system as well as minimizing emissions of landfill gas during maintenance, 

start-up, or shutdown. 

Source Testing and Monitoring: 

District Rule 4642 does not require any source testing of monitoring of subsurface 

landfill boundary emissions, whereas South Coast AQMD Rule 1150.1 requires monthly 

sampling and lab analysis of subsurface landfill boundary emissions. However, it is 

important to mention that District staff relied on the premise that landfills operating in the 

San Joaquin Valley air basin are already required to comply with CCR Title 27 which, 

among other requirements, include subsurface and boundary monitoring, 

recordkeeping, and reporting for specified landfill gas emissions. Such requirements 

are not included in Rule 4642 to avoid duplication of state regulatory requirements. 

District Rule 4642 requires semi-annual (annual after two successful tests) FID probe 

sampling of landfill surface emissions, whereas South Coast AQMD Rule 1150.1 

requires monthly integrated sampling and lab analysis for the 50,000 square foot grid 

VOC limit of 50 ppmv, and quarterly instantaneous probe sampling for the overall landfill 

surface limit of 500 ppmv without any specific reference to the wind speed. Although 

Rule 4642 has a 1,000 ppmv surface emission limit, it is important to mention that such 

readings are required to be taken when the average wind speed does not exceed 5 

miles per hour or the instantaneous wind speed does not exceed 10 miles per hour. 

District Rule 4642 does not require landfill gas or ambient air testing/monitoring, 

whereas South Coast AQMD Rule 1150.1 requires monthly sampling and lab analysis 

for both landfill gas and ambient air. 

Record Keeping: 

The is no significant difference between the two rules under this category. Both rules 

require record maintenance for a period of 5 years. 
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Based on the above discussion, District staff believes that overall District Rule 4642 is 

as stringent as SCAQMD Rule 1150.1. 

analysis is required to determine whether the stricter requirements of South Coast 

AQMD Rule 1150.1 should be incorporated into District Rule 4642 for RACT purposes. 

A cost effectiveness and feasibility analysis is required to determine whether the stricter 

requirements of 40 CFR Subpart Cc should be incorporated into District Rule 4642 for 

RACT purposes. 

Because of the extent of the differences between District Rule 4642 and South Coast 

AQMD Rule 1150.1, it is preferable that the required analysis be conducted under the 

context of a rule amendment process. 

C. Bay Area AQMD Regulation 8 Rule 34 

Bay Area AQMD (BAAQMD) Regulation 8 Rule 34 (Solid Waste Disposal Sites) applies 

to Methane and VOC emissions from solid waste disposal sites. 

The rule exempts old and inactive landfills (those that stopped accepting solid waste 

before November 8, 1987) and small landfills (those with an in in-place tonnage of less 

than 907,194 megagrams (1,000,000 tons) of decomposable solid waste, and a 

maximum design capacity of less than 2.5 million megagrams (2,755,000 tons) or less 

than 2.5 million cubic meters; or emit less than 50 megagrams of VOC per year). 

Control requirements do not apply during systems shutdowns, as long as shutdowns do 

not exceed 240 hours per year, and emissions into the atmosphere are minimized. 

Requirements are also no applicable during well raising, system component repairs and 

other construction activities. 

The rule requires the use of a landfill gas collection and control system that reduces 

VOCs by 98 percent by weight, or reduces VOCs to less than 120 ppmv at the outlet, 

and limits component leaks to 1,000 ppmv. Landfill surface VOC concentrations are 

limited to 500 ppmv. The rule requires each gas wellhead to operate under vacuum, and 

provides specifications for wellhead temperature, nitrogen and oxygen levels. 

Exempt landfills are required to submit design capacity and emission rate reports to 

demonstrate their exemption status. 

Required monitoring requirements include annual source testing for the control system, 

quarterly testing for collection equipment leaks, monthly well-head monitoring, quarterly 

monitoring of landfill surface emissions, continuous temperature monitoring for flares, 

gas flow meter for inlet into control device and monthly monitoring of landfill surface 

cover integrity. 

District Rule 4642 is compared to BAAQMD Regulation 8 Rule 34 under the following 

categories: 
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Applicability/Exemption: 

District Rule 4642 is more stringent than BAAQMD Regulation 8 Rule 34 because Rule 

4642 applies to landfills which have a gas collection and control system regardless of 

the age and design capacity of the landfill, whereas Rule 34 applies only to landfills that 

accepted waste after November 8, 1987. In addition, Rule 34 contains numerous 

landfill exemptions (e.g., inactive or closed landfills, small design capacity landfills, low 

emission landfills, permanent shutdown of collection and control system, etc.), whereas 

Rule 4642 only exempts landfills subject to 40 CFR 60 Subparts Cc and WWW or 

hazardous waste landfills as previously discussed above. 

Requirements: 

District Rule 4642 requires a landfill surface emission limit of 1,000 ppmv, measured, as 

methane, with a portable hydrocarbon analyzer with the detector probe within 3 inches 

of the surface, whereas BAAQMD Rule 34 requires a 500 ppmv above background. 

Rule 34 defines background as ambient concentration of total organic compounds 

determined at least 3 meters upwind of the source to be inspected, whereas District 

Compliance generally considers background as a distance of 2 meters upwind of the 

source of the leak. In addition, Rule 4642 surface emission measurement is taken 

within 3 inches of the landfill surface while Rule 35 emission limit does not include any 

specific distance measurement. Based on District Compliance staff’s field experience, 

leak measurements based on greater background distance and instrument probe tip 

distance from the leak surface are less stringent even though the leak limit is 500 ppmv 

when compared to 1,000 ppmv measured at a lesser background distance and closer 

distance from leak surface. 

BAAQMD Rule 34 an emission control system which reduces the amount of NMOC by 

at least 98% or emit less than 120 ppmv (corrected to 3% oxygen) of NMOC at the 

outlet. In contrast, District Rule 4642 is more stringent because the control efficiency is 

98% control efficiency or a VOC concentration reduction of 20 ppmv or less. 

Source Testing and Monitoring: 

District Rule 4642 requires semi-annual (annual after two successful tests) FID probe 

sampling of landfill surface emissions, whereas Bay Area AQMD Regulation 8 Rule 34 

requires quarterly sampling. 

Bay Area AQMD Regulation 8 Rule 34 requires quarterly testing for equipment leaks. 

District Rule 4642 requires semiannual surface emission testing which includes leak 

measurements along the gas transfer path of the gas and collection system. Leak 

measurement of the gas transfer path (which also includes any components and 

equipment) is deemed equivalent to Rule 34 equipment leak testing requirement. 

District Rule 4642 does not require landfill surface cover monitoring, whereas Bay Area 

AQMD Regulation 8 Rule 34 requires monthly monitoring of surface cover integrity. 
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However, Rule 4642 surface emission testing is adequate such that any crack or 

degradation in the integrity of the surface cover that results to a emission level 

exceeding the threshold would need to be repaired/replaced so as to lower the leak to 

below the threshold. 

District Rule 4642 does not require well-head monitoring, whereas Bay Area AQMD 

Regulation 8 Rule 34 requires monthly well-head monitoring. However, it is important to 

mention that in developing Rule 4642, District staff relied on the premise that landfills 

operating in the San Joaquin Valley air basin are already required to comply with CCR 

Title 27 which, among other requirements, include subsurface and boundary monitoring, 

monitoring well construction and monitoring frequency, recordkeeping, and reporting for 

specified landfill gas emissions. Such requirements are not included in Rule 4642 to 

avoid duplication of state regulatory requirements. 

Record Keeping: 

The is no significant difference between the two rules under this category. Both rules 

require record maintenance for a period of 5 years. 

Based on the above discussion, District staff believes that District Rule 4642 is as 

stringent as BAAQMD regulation 8 Rule 34. 

D. Ventura County APCD Rule 74-17-1 

Ventura County APCD Rule 74-17-1 (Municipal Solid Waste Landfills) applies to landfills 

that were in existence prior to May 30, 1991. 

The rule requires affected landfill with a design capacity equal to or greater than 2.5 

million megagrams and 2.5 million cubic meters, and a NMOC emission rate of 50 

megagrams per year, or more than 500,000 tons of degradable waste in place, to comply 

with 40 CFR 60 Subpart WWW. 

In addition, the rule requires that NOx emissions from flares used as landfill gas control 

devices shall not exceed 0.06 lb/MMBtu of heat input. 

Applicable source testing, monitoring and record keeping requirements those from 40 CFR 

60 Subpart WWW. 

District Rule 4642 is compared to Ventura County APCD (VCAPCD) Rule 74-17-1 

under the following categories: 

Applicability/Exemption: 

District Rule 4642 is more stringent than VCAPCD Rule 74-17-1 because Rule 4642

applies to landfills which have a gas collection and control system regardless of the age 

and design capacity of the landfill, whereas Rule 74-17-1 applies to landfills that were in 

existence prior to May 30, 1991 and landfills that have accepted waste since November 
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8, 1987 or has additional design capacity available for future waste deposition. Similar 

to Rule 4642, Rule 74-17-1 also exempts landfills subject to 40 CFR 60 Subpart WWW. 

Requirements: 

VOC requirements for VCAPCD Rule 74-17-1 are similar to 40 CFR 60 Subpart WWW 

requirements. Since a comparison between District Rule 4642 and 40 CFR 60 Subpart 

WWW has already been conducted, additional analysis is not necessary. However, it 

should be noted that Subpart WWW does not specify the frequency of conducting 

landfill surface emission testing, whereas District Rule 4642 requires semiannual 

testing. 

District Rule 4642 allows for shutdown of the gas collection and control system for 

maintenance purposes provided the District is notified at least 24 hours before 

performing any maintenance work, that the emissions of landfill gas into the atmosphere 

is minimized during shutdown, and that the gas collection and control system should not 

be shutdown for more than 144 cumulative hours in any calendar year. In comparison, 

Subpart WWW allows deviation from emission standards during periods of start-up, 

shutdown, or malfunction provided the duration does not exceed 5 days for collection 

system and one hour for treatment or control devices. District staff believes that Rule 

4642 limited duration for such maintenance allowance on an annual basis is as stringent 

as provided by Subpart WWW which does not have any limitation on the frequency of 

start-up, shutdown, or malfunction. 

District Rule 4642 does not have any NOx emission limits for flares used as control 

devices, whereas VCAPCD Rule 74-17-1 has a NOx emission limit of 0.06 lb/MMBtu for 

landfill gas control flares. However, District staff’s review of the Permit database, 

indicates that permitted flares operated in landfills have NOX limits similar to Rule 74-

17-1. 

Source Testing, Monitoring and Record Keeping: 

Applicable source testing and monitoring requirements for VCAPCD Rule 74-17-1 are 

those for 40 CFR 60 Subpart WWW. A comparison between District Rule 4642 and 40 

CFR 60 Subpart WWW has already been conducted, hence additional analysis is not 

necessary 

Based on the above discussion, District staff believes that overall Rule 4642 is more 

stringent than VCAPCD Rule 74-17-1 

E. Sacramento Metro AQMD Rule 485 

The purpose of this rule is to implement the requirements of 40 CFR 60 Subpart Cc. A 

comparison between District Rule 4642 and 40 CFR 60 Subpart Cc has already been 

conducted, hence additional analysis is not required. 
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Conclusion

After evaluation of federal rules and regulations as well as prohibitory rules in other 

California nonattainment areas, District staff concludes that District Rule 4642 meets 

RACT for Municipal Waste Disposal Sites. 
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Rule 4651 – Soil Decontamination Operations 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

VOC 0.11 0.11 0.12 0.12 0.14 0.14 0.15 0.75 

(Source: District 2007 Ozone Plan) 

District Rule 4651 Description

The purpose of this rule is to reduce volatile organic compound (VOC) emissions from 

soil that has been contaminated with a VOC-containing liquid. This source category 

includes all activities involving the remediation of contaminated soils. Soil contamination 

from organic material occurs due to leaking storage and handling systems, operating 

losses, and accidental spills. 

The rule exempts the following categories: (a) excavation, handling, transportation, and 

decontamination of less than one (1) cubic yard of contaminated soil per occurrence; (b) 

operations related to the accidental spillage of up to 42 gallons of VOC-containing liquid 

per occurrence; (c) contaminated soil exposed for the sole purpose of sampling; and (d) 

soil contaminated solely by a known VOC-containing liquid or a petroleum liquid that 

has an initial boiling point of 302°F or higher. 

The rule requires a written notice to be provided to the APCO, except for emergency 

excavations, prior to commencement of excavation of possibly contaminated soil. A 

notice must also be provided within 48 hours of detection of contaminated soil and a 

written verification of completion of the excavation must be provided within 30 days of 

the completion.

The rule requires VOC monitoring every 15 minutes during excavation of contaminated 

soils, except during emergency excavations. Contaminated soil shall be sprayed with 

water or vapor suppressant and covered with plastic sheeting or a 6-inch layer of 

uncontaminated soil. Piles of contaminated soil must be covered if they have been 

inactive for more than one hour. For emergency excavations, contaminated soil must be 

covered within 24 hours. Stockpiles of contaminated soil must be inspected every 24 

hours (except when operators are not on-site for more than 24 hours) to ensure integrity 

of the covering. Contaminated soil must be decontaminated, recycled, or disposed of in 

an approved facility within 30 days. 

The rule requires that soils contaminated with a VOC concentration of 1,000 ppm or 

greater shall be sprayed with water or vapor suppressant and placed in sealed 

containers or transported to a treatment facility within 30 minutes after excavation. 

Contaminated soil must be covered during transportation. VOC emissions from in onsite decontamination of contaminated soil shall be controlled by a VOC collection and 
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control device with a VOC destruction or removal efficiency of at least 95%. The rule 

prohibits aeration of contaminated soil. 

Decontaminated soil must be monitored for VOC concentrations before proper disposal 

or return to decontamination process, depending on the VOC readings. Lab analysis of 

VOC concentrations is required for decontaminated soil that is to be treated as 

uncontaminated. 

Record keeping is required for VOC monitoring readings during excavations, daily 

inspection of contaminated soil cover, VOC concentration readings for decontaminated 

soil, and chain of custody for transportation and transfer of contaminated soil. 

How does District Rule 4651 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

There is no CTG for this source category. 

B. EPA – Alternative Control Technology (ACT) 

There is no ACT for this source category. 

C. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS for this source category. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There is no NESHAP or MACT for this source category. 

How does District Rule 4651 compare to rules in other air districts?

District staff compared emission limits, optional control requirements, and work practice 

standards in District Rule 4651 to comparable requirements in rules from the following 

California nonattainment areas: 

• South Coast AQMD Rules 1166 (amended 5/11/2001) 

• Bay Area AQMD Regulation 8 Rule 40 (amended 6/15/2005) 

• Sacramento Metro AQMD (no applicable rule) 

• Ventura County APCD Rule 74-29 (revised 4/8/2008) 
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A. South Coast AQMD Rule 1166 

South Coast AQMD Rule 1166 (Volatile Organic Compound Emissions from 

Decontamination of Soil) applies to the emission of Volatile Organic Compounds (VOC) 

from excavating, grading, handling and treating VOC-contaminated soil as a result of 

leakage from storage or transfer operations, accidental spillage, or other deposition.

The following categories are exempt: (a) excavation, handling, and treating of less than 

one (1) cubic yard of contaminated soil; (b) removal of soil for sampling purposes; (c) 

accidental spillage of 5 gallons or less of VOC-containing material; and (d) emergency 

excavations.

The rule requires monitoring for VOC contamination every 15 minutes during 

excavation, and contaminated soil to be sprayed with water and/or approved vapor 

suppressant and covered with plastic sheeting. A daily visual inspection of all covered 

VOC contaminated soil stockpiles is required to ensure the integrity of the covering. The 

contaminated soil must be treated or removed from an excavation or grading site within 

30 days. 

The rule requires that soil contaminated with a VOC concentration measuring more than 

1000 ppm be sprayed with water or vapor suppressant and placed in sealed containers 

or loaded into covered trucks for transportation offsite within 15 minutes. The rule 

requires that the treatment of contaminated soil shall be done using control equipment 

meeting Best Available Control Technology. The rule prohibits spreading, grading or 

screening of VOC-contaminated soil. Trucks transporting contaminated soil are required 

to be loaded and covered in a manner that prevents spillage, and cleaned off before 

leaving the loading site. 

Facilities planning to excavate possibly contaminated soil must first submit a mitigation 

plan for approval by the APCO, and notify the APCO 24 hours before excavation. The 

APCO must also be notified within 24 hours of the detection of contaminated soil. 

Record keeping is required for VOC monitoring readings during excavations, calibration 

records for monitoring equipment, daily inspection of contaminated soil cover, 

identification and business addresses of the generators, transporters and 

storage/treatment facilities for contaminated soil. 

District Rule 4651 is compared to South Coast AQMD Rule 1166 under the following 

categories: 

Applicability/Exemption: 

District Rule 4651 is less stringent than South Coast AQMD Rule 1166 because it 

exempts accidental spillages up to 42 gallons of VOC containing material, whereas 

South Coast AQMD Rule 1166 exempts only 5 gallons. 
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District Rule 4651 is more stringent than South Coast AQMD Rule 1166 because it 

requires emergency excavations to follow the same treatment and decontamination 

procedures as regular excavations, whereas South Coast AQMD has no requirements 

for emergency excavations other than notification of the APCO. 

Requirements: 

There are no significant differences between District Rule 4651 and South Coast AQMD 

Rule 1166 under this category. District Rule 4651 allows a maximum of 30 minutes to 

contain or truck off soils with a VOC reading of 1,000 ppm, whereas South Coast AQMD 

Rule 1166 allows a maximum of 15 minutes. In both cases, this requirement conveys 

the urgency with which the contaminated soil must be removed to a treatment facility, 

but it is unlikely that there will be any difference in total emissions when the overall 

excavation, transportation and treatment process is considered. 

Source Testing and Monitoring: 

There are no significant differences between District Rule 4651 and South Coast AQMD 

Rule 1166 under this category. The following minor differences are noted: 

• District Rule 4651 provides an exemption from daily monitoring for contaminated soil 

cover integrity when operators are not on-site for more than 24 hours, whereas 

South Coast AQMD Rule 1166 does not provide such an exemption. Cover 

monitoring applies only to soil with low contamination (since soil high contamination 

must be sealed in containers or trucked off in less than an hour). It is therefore 

unlikely will make a significant difference in emissions from such soil. 

• District Rule 4651 requires VOC monitoring of decontaminated soil to determine 

whether it is safe to dispose of or must be further treated. South Coast AQMD Rule 

1166 does no state this requirement explicitly, but the requirement is implied in the 

definition of contaminated soil. 

Reporting: 

South Coast AQMD Rule 1166 is more stringent under this category because it requires 

submittal of a detailed excavation plan, in addition to notification of the APCO prior to 

commencement of excavation. District Rule 4651 does not require an excavation plan, 

but some of the information required to be included in the pre-excavation notification is 

similar to information required by South Coast AQMD Rule 1166’s excavation plan. 

Further, District Rule 4651 requires submittal of a completion of excavation report. 

Record Keeping: 

District Rule 4651 is more stringent under this category because it requires records to 

be retained for at least 5 years, whereas South Coast AQMD Rule 1166 requires only 2 

years for record retention. 

The preceding comparison demonstrates that District Rule 4651 is just as stringent as 

South Coast AQMD Rule 1166. The most significant difference between the rules is in 
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the exemptions category as discussed above. While District Rule 4651 has a very lax 

exemption for accidental spillage, South Coast AQMD Rule 1166 has an equally lax 

exemption for emergency excavations. Differences under the requirements, source 

testing and monitoring, reporting and record keeping categories are generally minor and 

not likely to affect overall emissions control effectiveness for either rule. 

B. Bay Area AQMD Regulation 8 Rule 40 

The purpose of Bay Area AQMD Regulation 8 Rule 40 is to limit the emission of organic 

compounds from soil that has been contaminated by organic chemical or petroleum 

chemical leaks or spills and to control emissions from underground storage tanks during 

removal or replacement. 

The rule provides the following exemptions: (a) contaminated soil exposed only for 

sampling purposes; (b) soil contaminated with a non-volatile hydrocarbon with an initial 

boiling point of 302 o

F or higher; (c) excavation of contaminated not exceeding 1 cubic 

yard, or not exceeding 8 cubic yards if organic content does not exceed 500 ppmw; (d) 

soil contaminated by accidental spillage of five gallons or less of liquid organic 

compounds. 

The rule requires that contaminated soil shall be kept visibly moist by water spray, 

treated with a vapor suppressant, or covered with continuous heavy duty plastic 

sheeting or other covering to minimize emissions of organic compounds to the 

atmosphere. Inactive piles of contaminated soil must be covered within one hour. 

The rule requires that contaminated soils loaded into trucks or trailers for off site 

disposal or treatment shall be covered with continuous heavy duty plastic sheeting or 

other covering. The rule requires that within 45 days of excavation (or within 90 days for 

soil of organic content less than 500 ppmw), contaminated soil shall be backfilled and 

covered with at least 6 inches of uncontaminated soil, removed from the site, or treated 

to remove the contamination. 

Treatment of contaminated soil shall be subject to all applicable District Rules and 

Regulations. Aeration of contaminated soil is prohibited. 

A written notice of intention to excavate must be submitted 5 days prior to start of 

excavation. For emergency excavation, notice is required only as soon as possible, but 

still before the excavation, and must be followed by written verification no later than 30 

days after the excavation. For pipeline repair excavations, notice is required no later 

than 30 days after the excavation. 

Sampling and VOC content analysis is required to demonstrate any exemptions 

claimed. 

District Rule 4651 is compared to Bay Area AQMD Regulation 8 Rule 40 under the 

following categories: 
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Applicability/Exemption: 

District Rule 4651 is less stringent than Bay Area AQMD Regulation 8 Rule 40 because 

it exempts accidental spillages up to 42 gallons of VOC containing material, whereas 

Bay Area AQMD Regulation 8 Rule 40 exempts only 5 gallons. 

District Rule 4651 is more stringent than Bay Area AQMD Regulation 8 Rule 40 

because its small excavation exemption is limited to only one cubic yard of 

contaminated soil, whereas Bay Area AQMD Regulation 8 Rule 40 provides an 

exemption for up to eight cubic yards. 

Requirements: 

There are no significant differences between District Rule 4651 and Bay Area AQMD 

Regulation 8 Rule 40 under this category. The following minor difference is noted: 

• District Rule 4651 is more stringent than Bay Area AQMD Regulation 8 Rule 40 

because it requires treatment or disposal of contaminated soil to be done within 30 

days, whereas Bay Area AQMD Regulation 8 Rule 40 allows 45 days for soil above 

500 ppm in VOC concentration and 90 days for soil with less than 500 ppm VOC. 

• District Rule 4651 is more stringent than Bay Area AQMD Regulation 8 Rule 40 

because it requires soil with 1,000 ppm or more of VOC to be sealed in containers or 

trucked off to an approved treatment/disposal facility within 30 minutes of 

excavation, whereas Bay Area AQMD Regulation 8 Rule 40 has no such 

requirement. 

Source Testing and Monitoring: 

District Rule 4651 is more stringent than Bay Area AQMD Regulation 8 Rule 40 

because it requires monitoring of soil for VOC concentration every 15 minutes during 

excavation, whereas Bay Area AQMD Regulation 8 Rule 40 has no such requirement. 

Reporting: 

There are no notable differences between the two rules under this category. 

Record Keeping: 

District Rule 4651 is more stringent under this category because it requires records to 

be retained for at least 5 years, whereas Bay Area AQMD Regulation 8 Rule 40 has no 

requirement for the retention of records. 

The preceding comparison demonstrates that District Rule 4651 is more stringent than 

Bay Area AQMD Regulation 8 Rule 40. Under the applicability/exemptions category, 

District Rule 4651 has a very lax exemption for accidental spillage, but Bay Area AQMD 

Regulation 8 Rule 40 has an equally lax exemption for small excavations. As discussed 
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above, District Rule 4651 is stricter than Bay Area AQMD Regulation 8 Rule 40 under 

the requirements, monitoring and record keeping categories. 

C. Ventura County APCD Rule 74-29 

Ventura County APCD Rule 74-29 (Soil Decontamination Operations) is applicable to 

soils that contain gasoline, diesel fuel, or jet fuel. 

The rule provides several exemptions for: (a) contamination due to leaking storage 

tanks used in an agricultural operations; (b) soil moving, loading or transport activities 

performed for the sole purpose of complying with local, state, or federal laws; (c) soil 

excavation or handling occurring as a result of an emergency; (d) soil aeration involving 

less than 1 cubic yard; (e) contamination due to a spill or release of less than five (5) 

gallons of VOC-containing liquid; (f) contaminated soil used as daily cover at permitted 

Class III Solid Waste Disposal Sites. 

The rule prohibits aeration of soil emitting VOC concentrations of more than 50 ppmv. 

Vapor extraction, bioremediation or bioventing of soils with a VOC concentration 

exceeding 100 ppm are also prohibited. The rule requires monitoring for VOC 

contamination every 15 minutes during excavation of potentially contaminated soil and 

that all exposed contaminated soil surfaces shall be moistened with water or treated 

with a vapor suppressant or covered with continuous heavy duty plastic sheeting. 

Decontamination treatment or removal of soil from excavation site must begin within 30 

days. Treatment must be conducted in compliance with all applicable District rules. 

Measures such as covering and not overloading are required to prevent spillage during 

transportation. 

Records required include dates that soil was disturbed and the quantity of soil disturbed 

on each date, reasons for excavation or grading, cause of VOC soil contamination and 

history of the site, description of tanks or piping associated with the soil contamination, 

description of mitigation measures employed for dust, odors and ROC emissions, 

details of treatment and/or disposal of ROC contaminated soil, description of monitoring 

equipment and techniques, and facility layout maps. 

Records are required to be retained for up to two years. 

District Rule 4651 is compared to Ventura County APCD Rule 74-29 under the following 

categories: 

Applicability/Exemption: 

District Rule 4651 is more stringent than Ventura County APCD Rule 74-29 because it 

has fewer exemptions. The exemptions provided by Ventura County APCD Rule 74-29, 

including exemptions for contamination due to tanks used in agricultural operations and 

the use of contaminated soil as landfill cover, are likely to result in larger quantities of 

emissions in comparison to the exemptions provided by District Rule 4651. 
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Requirements: 

District Rule 4651 is more stringent than Ventura County APCD Rule 74-29 because it 

requires soil with 1,000 ppm or more of VOC to be sealed in containers or trucked off to 

an approved treatment/disposal facility within 30 minutes of excavation, whereas 

Ventura County APCD Rule 74-29 has no such requirement. 

Source Testing and Monitoring: 

District Rule 4651 is more stringent than Ventura County APCD Rule 74-29 because it 

requires monitoring of soil for VOC concentration every 15 minutes during excavation, 

whereas Ventura County APCD Rule 74-29 has no such requirement. 

Reporting: 

Ventura County APCD Rule 74-29 is more stringent than District Rule 4651 under this 

category because it requires more detailed information about each excavation to be 

recorded. 

Record Keeping: 

District Rule 4651 is more stringent under this category because it requires records to 

be retained for at least 5 years, whereas Ventura County APCD Rule 74-29 requires 

only two years of record retention. 

The preceding comparison demonstrates that District Rule 4651 is more stringent than 

Ventura County APCD Rule 74-29, since it has stricter requirements under all 

categories discussed above, except for reporting. It is also unlikely that reporting has 

any significant effect on the rule’s emission control effectiveness. 

Conclusion

After evaluation of federal rules and regulations as well as prohibitory rules in other 

California nonattainment areas, District staff concludes that District Rule 4651 satisfies 

RACT for Soil Decontamination Operations. 
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Rule 4652 - Coatings and Ink Manufacturing 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 0 0 0 0 0 0 0 0

VOC 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 

(Source: District 2007 Ozone Plan) 

District Rule 4652 Description

District Rule 4652, last amended on December 17, 1992, limits VOC emissions from 

coating and ink manufacturing operations. 

District Rule 4652 specifies equipment design and operational procedures for processes 

associated with the manufacture of coatings or inks. The rule requires that portable 

mixing vats be covered, and includes lid configuration requirements. Stationary mixing 

vats are to be covered and grinding mills must have fully enclosed screens. For 

cleaning portable and stationary vats, as well as for cleaning high-speed dispersion 

mills, grinding mills, and roller mills, APCO-approved cleaning methods are required.

How does District Rule 4652 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

There is no EPA CTG guidance document for coating and ink manufacturing. 

B. EPA - Alternative Control Technology (ACT) 

There is no EPA ACT guidance document for coating and ink manufacturing. 

C. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS guidance document for coating and ink manufacturing. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

NESHAPs and MACTs are requirements contained in 40 Code of Federal Regulations 

(CFR) Part 61 and 40 CFR Part 63. Since EPA has delegated the authority to 

implement NESHAP requirements to the District, NESHAPs and MACTs promulgated 

by EPA are usually incorporated by reference into District Rule 4002 (National Emission 

Standards for Hazardous Air Pollutants). It is important to mention that the District 
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implements NESHAPs and MACTs by incorporating the emission standards as 

conditions of the Permits to Operate issued to affected sources. 

40 CFR 63 Subpart HHHHH - National Emission Standards for Hazardous Air 

Pollutants: Miscellaneous Coating Manufacturing 

This NESHAP contains some of the work practice standards in Rule 4652, in addition to 

HAP vapor pressure reduction requirements. The NESHAP vapor pressure 

requirements are not directly comparable to the work practice standards in Rule 4652. 

In addition, some HAPs may be exempt VOCs, and some VOCs may be HAPs; 

therefore, there is no direct correlation between the NESHAP requirements versus 

District Rule 4652 VOC requirements. 

How does District Rule 4652 compare to rules in other air districts?

District staff compared District Rule 4652 to the rules of other California ozone 

nonattainment air districts’ rules for coating and ink manufacturing operations. The 

results of the analysis are discussed below. 

A. South Coast Air Quality Management District (SCAQMD) Rule 1141.1 - Coatings and Ink 

Manufacturing (Amended November 17, 2000) 

SCAQMD Rule 1141.1 applies to coating and ink manufacturing. The table below 

identifies where the rules differ. Categories not discussed means the two rules have the 

same requirement. 

Category Bay Area SJ Valley More Stringent 

for Category 

Throughput Exemption 500 gal/day or 

11,000 gal/mo 50 gal/day SJ Valley

As shown in the table above, SJVAPCD Rule 4652 is more stringent than SCAQMD 

Rule 1141.1. 

B. Bay Area Air Quality Management District (BAAQMD) Regulation 8 Rule 35 - 

Coating, Ink, and Adhesive Manufacturing (June 15, 1994) 

BAAQMD Regulation 8 Rule 35 applies to coating and ink manufacturing. The table 

below identifies key category comparisons for the rules. Categories not discussed 

means the two rules have the same requirement. 

Category Bay Area SJ Valley More Stringent 

for Category 

Exemptions 
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Waterbased Coatings and/or Paste 

Inks Not Exempt Exempt Bay Area

Low VOC Coatings/Inks Exempt Not Exempt SJ Valley 

Vats less than 12 gal Not Exempt Exempt Bay Area 

Produce less than 50 gal/day Not Exempt Exempt Bay Area 

Requirements

Stationary Mixing Vats 

Limit 15 lbVOC/day or 

80% control 

Covers, except 

to add/sample 

ingredients 

Bay Area 

Equipment Cleaning 

200 g/l, closed 

system, or 80% 

control 

Minimize 

emissions and 

APCOapproved 

(per Rule 4661: 

833 lb-VOC/mo 

or 90% control) 

SJ Valley 

As shown in the table above, there are several categories that the rules differ in 

stringency. However, the difference in overall emissions reductions on a mass basis is 

insignificant since the emissions inventory for this category is small and there are only 

four facilities in the SJVAPCD subject to this rule, none of which are Major Sources. 

Overall, SJVAPCD Rule 4652 is considered equivalent to BAAQMD Reg 8 Rule 35. 

C. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 

464 (Organic Chemical Manufacturing Operations) amended September 25, 

2008 

SMAQMD Rule 464 applies to organic chemical manufacturing operations. Per Rule 

464, organic chemicals can include coatings. The table below identifies key category 

comparisons for the rules. Categories not discussed means the two rules have the 

same requirement. 
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Category Sac Metro SJ Valley 

More 

Stringent 

for 

Category 

Exemptions 

Waterbased Coatings and/or Paste 

Inks Not Exempt Exempt Sac Metro

Vats less than 12 gal Not Exempt Exempt Sac Metro 

Produce less than 50 gal/day Not Exempt Exempt Sac Metro 

Facility less than 15 lb-VOC/day Exempt Not Exempt SJ Valley 

Process tank less than 15 lbVOC/day Exempt Not Exempt SJ Valley 

Requirements/Standards

Process Tanks/Mixing Vats 

Limit 15 lbVOC/day or 

90% control 

Covers, except to 

add/sample 

ingredients 

Sac Metro 

Equipment Cleaning 25 g/l (2009), or 

90% control 

Minimize emissions 

and APCOapproved 

(per Rule 4661: 833 

lb-VOC/mo or 90% 

control) 

Equivalent 

As shown in the table above, there are several categories that the rules differ in 

stringency. However, the difference in overall emissions reductions on a mass basis is 

insignificant since the emissions inventory for this category is small and there are only 

four facilities in the SJVAPCD subject to this rule, none of which are Major Sources. 

Overall, SJVAPCD Rule 4652 is considered equivalent to SMAQMD Rule 464. 

 F. Ventura County Air Pollution Control District (VCAPCD) 

 No rule for coating and/or ink manufacturing facilities. 

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4652 

satisfies RACT for coating and ink manufacturing operations. 
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Rule 4653 - Adhesives 

Emissions Inventory: 

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 0 0 0 0 0 0 0 0 

VOC 3.2 3.3 3.5 3.6 3.9 4.1 4.3 4.9 

(Source: District 2007 Ozone Plan) 

I. District Rule 4653 Description: 

District Rule 4653, recently amended on September 20, 2007, sets VOC content limits 

for adhesives. In lieu of adhering to the VOC limits, owners/operators may use VOC 

control devices with a control efficiency of at least 85%, by mass. Adhesives used in 

laboratories, sold for specific limited uses, sold in quantities no more than 8 ounces, or 

used in quantities of no more than 20 gallons per year are exempt. VOC emissions are 

over 80% controlled, compared to uncontrolled emissions. 

II. How does District Rule 4653 compare with federal rules and regulations? 

A. EPA – Control Technique Guidelines (CTG) 

The CTG EPA-453/R-08-005 2008/09 (Control Techniques Guidelines for 

Miscellaneous Industrial Adhesives) applies to industrial adhesives applications located 

in marginal, moderate, serious or severe ozone nonattainment areas that has the 

potential to emit greater than or equal to 25 tons/year of VOC, and equal to greater than 

10 tons/year of VOC for extreme ozone nonattainment areas. 

This CTG, dated September 2008, will be evaluated by the District for inclusion into 

District rules within one year. 

B. EPA - Alternative Control Technology (ACT) 

There is no EPA ACT guidance document for adhesives. 

C. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS document for adhesives. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There is no NESHAPs/MACT document for adhesives. 
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III. How does District Rule 4653 compare to rules in other air districts?

District staff compared District Rule 4653 with the rules of other California ozone 

nonattainment air districts’ rules (listed below) for adhesives operations. The results of 

the analysis are discussed below. 

E. South Coast Air Quality Management District (SCAQMD) Rule 1168 - Adhesive 

and Sealant Applications (Amended January 7, 2005) 

F. Bay Area Air Quality Management District (BAAQMD) Regulation 8 Rule 51 - 

Adhesive and Sealant Products (Amended July 17, 2002) 

G. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 460 - 

Adhesives and Sealants (Amended November 30, 2000) 

H. Ventura County Air Pollution Control District (VCPCD) Rule 74.20 - Adhesives 

and Sealants (Amended January 1, 2005) 

The table below identifies the category comparisons for the rules. Categories not 

shown means all of the rules have the same requirement. 

General Adhesive Application 

Processes 

Bay 

Area 

(Rule 

8-51) 

South 

Coast 

(Rule 

1168) 

Sac 

Metro 

(Rule 

460) 

Ventura 

(Rule 

74.20) 

SJ 

Valley 

(Rule 

4653) 

Fiberglass 80 200 200 

Flexible vinyl 250 250 

Flexible vinyl toother substrate 250 

Other Substrates 250 250 250 250 

Plastic Foams 120 50 120 120 

Porous Material 120 120 120 

Porous Material (except wood and plastic 

foam) 150 

Porous Material (except wood) 50 

Rubber 250 250 250 

Wood 30 30 30 30 

Specialty Adhesive Application 

Processes 

Bay 

Area 

(Rule 

8-51) 

South 

Coast 

(Rule 

1168) 

Sac 

Metro 

(Rule 

460) 

Ventura 

(Rule 

74.20) 

SJ 

Valley 

(Rule 

4653) 

ABSWelding 400 325 400 400 400 

Carpet Pad Installation 50 

Cellulosic plastic welding (except ethyl 

cellulose) 100 
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Ceramic Tile Installation 130 65 130 130 130 

Computer Diskette Manufacturing 850 350 850 

Contact Adhesive Special 250 250 

Contact Adhesive Specialty Substrate 250 200 

Contact Adhesive 80 250 200 250 

Cove Base Installation 150 50 150 150 

Dry Wall and Panel Installation 50 

Floor covering installation (except 

ceramic tile) 150 

Immersible Product Manufacturing 650 

Indoor Carpet Adhesives 50 

Indoor Floor Covering Installation 150 150 

Metal to Urethane/Rubber Molding or 

Casting Adhesive 250 

Multipurpose Architectural (except cove 

base installation) 200 

Multipurpose Construction 200 70 200 200 

Non membrane Roof Installation/Repair 300 300 300 

Other Plastic Cement Welding Adhesive 450 450 

Other Plastic Welding 500 500 

Outdoor Floor Covering Installation 350 150 250 

Perimeter Bonded Sheet Vinyl Flooring 

Installation 660 660 660 

Plastic Cement Welding 250 

Rubber Floor Installation 60 

Rubber Vulcanization Bonding 850 850 

Sheet rubber lining installation adhesive 850 

Single- Ply Roof Material 

Installation/Repair 250 250 

Single Ply Roof Membrane 

Installation/Repair Adhesive 250 250 250 
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Staple and Nail Manufacturing 640 

Structural Wood Member Adhesive 140 

Styrene-acrylonitrile welding adhesive 100 

Subfloor Installation 50 

Thin Metal Laminating 780 780 

Tire Retread 100 100 100 100 

Top and Trim Installation 540 250 

Traffic Marking Tape Adhesive 150 

VCT and Asphalt Tile Installation 50 

Water proof Resorcinol Glue 170 170 170 

Wood Flooring Installation 100 

Adhesive Primer Application 

Processes 

Bay 

Area 

(Rule 

8-51) 

South 

Coast 

(Rule 

1168) 

Sac 

Metro 

(Rule 

460) 

Ventura 

(Rule 

74.20) 

SJ 

Valley 

(Rule 

4653) 

Automotive Glass 700 700 700 

Plastic Cement Welding 650 400 650 650 

Single Ply Roof Membrane 250 250 

Traffic Marking Tape 150 150 250 

Other 250 

Included 

Above 

250 250 

Application Methods 

Bay 

Area 

(Rule 

8-51) 

South 

Coast 

(Rule 

1168) 

Sac 

Metro 

(Rule 

460) 

Ventura 

(Rule 

74.20) 

SJ 

Valley 

(Rule 

4653) 

Aerosol Cans x 

Air Atomized (for contact adhesives) x 

Airless Spray, Air Assisted Airless Spray, 

Air Atomized Spray (for contact 

adhesives) 

 x 

Airless Spray, Air Assisted Airless Spray, 

Air Atomized Spray (for viscosity 200 cp 

or greater) 

 x 
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Brush or Roll Coat x x x 

Dip Coat x x x 

Electro deposition x x x 

Electrostatic Spray x x x 

Flow Coat x x x 

Hand Application x x x 

HVLP Spray x x x 

LVLP Spray x x 

Other, Transfer Efficiency Minimum 65% 65% 

Add-on Control Efficiency 

Bay 

Area 

(Rule 

8-51) 

South 

Coast 

(Rule 

1168) 

Sac 

Metro 

(Rule 

460) 

Ventura 

(Rule 

74.20) 

SJ 

Valley 

(Rule 

4653) 

Capture 90% by 

wt 

Control 95% by 

wt 

Overall Control 80% 85% by 

wt 

85% by 

wt 

Solvents 

Bay 

Area 

(Rule 

8-51) 

South 

Coast 

(Rule 

1171)* 

Sac 

Metro 

(Rule 

460) 

Ventura 

(Rule 

74.20) 

SJ 

Valley 

(Rule 

4653) 

Product Cleaning (General) 25 70 70 25 

Surface Prep Prior to Rubber 

Vulcanization 850 

Repair and Maintenance Cleaning 25 70 70 25 

Cleaning of Application Equipment 25 70 if not 

enclosed 70 25 

*Per Rule 1171 (Solvent Cleaning) 

As shown in the table above, SJVAPCD Rule 4653 varies in stringency when compared 

to other Districts’ adhesive requirements, and in some categories is less stringent. 
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Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that Rule 4653 will be reevaluated for RACT purposes upon the next amendment to rule (see Table 4-3), 

already scheduled for revision under the current ozone plan. 
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Rule 4661 - Organic Solvents 

Emissions Inventory: 

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 0 0 0 0 0 0 0 0

VOC 4.294 4.295 4.296 4.297 4.295 4.295 4.295 4.296

(Source: District 2007 Ozone Plan) 

I. District Rule 4661 Description: 

District Rule 4661, recently amended on September 20, 2007, controls VOC emissions 

from organic solvents. District Rule 4661 has a facility solvent VOC emission limit of 833 

lb/month or a VOC capture and control system with efficiencies of 90% and 95% 

respectively.

II. How does District Rule 4661 compare with federal rules and regulations? 

A. EPA – Control Technique Guidelines (CTG) 

 

1. The CTG EPA-450/2-77-022 1977/11 (Control of Volatile Organic Emissions from 

Solvent Metal Cleaning) applies to degreasing operations located in marginal, 

moderate, serious or severe ozone nonattainment areas that has the potential to 

emit greater than or equal to 25 tons/year of VOC, and equal to greater than 10 

tons/year of VOC for extreme ozone nonattainment areas. Degreasing 

operations are covered under District Rule 4662 (Organic Solvent Degreasing 

Operations). As such, this CTG is addressed within the RACT analysis for Rule 

4662. 

2. The CTG EPA-453/R-06-001 2006/09 (Control Techniques Guidelines for 

Industrial Cleaning Solvents) applies to solvent cleaning operations located in 

marginal, moderate, serious or severe ozone nonattainment areas that has the 

potential to emit greater than or equal to 25 tons/year of VOC, and equal to 

greater than 10 tons/year of VOC for extreme ozone nonattainment areas. 

The CTG requirement is a solvent VOC content limit of 50 g/L or an overall VOC 

control efficiency of 85%. District Rule 4661 has a solvent VOC limit of 833 

lb/month or an overall VOC control efficiency requirement greater than 90%. As 

such, Rule 4661 is more stringent than this CTG. 

B. EPA - Alternative Control Technology (ACT) 

1. The ACT EPA-450/3-89-030 1989/08 (Alternative Control Technology 

Document – Halogenated Solvent Cleaners) applies to cleaning machines 

that use halogenated solvents. The halogenated solvents listed in the ACT 
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that EPA is concerned about are methylene chloride, trichloroethylene, 

perchloroethylene (tetrachloroethylene), CFC-113 (1,1,2-trichloro-1,2,2-

Trifluoroethane), and methyl chloroform (1,1,1-trichloroethane). 

Rule 4661, Section 4.4 exempts halogenated hydrocarbons from the rule. 

However, the District addresses HAPs via rule 4102 (Nuisance) along with a 

Health Risk Assessment-Emissions modeling process, in addition to District 

7000 series toxic rules. 

2. The ACT EPA-453/R-94-015 1994/02 (Alternative Control Techniques 

Document – Industrial Cleaning Solvents) applies to industrial cleaning with 

organic solvents. The ACT focuses on suggested solvent accounting and 

management practices. District Rule 4661 has a facility solvent VOC 

emission limit of 833 lb/month or an overall VOC control efficiency 

requirement greater than 90%. As such, Rule 4661 is more stringent than 

this ACT for VOCs. 

C. Standards of Performance for New Stationary Sources (NSPS) – There are no 

NSPS regulations that apply to solvents. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

NESHAPs and MACTs are requirements contained in 40 Code of Federal 

Regulations (CFR) Part 61 and 40 CFR Part 63. Since EPA has delegated the 

authority to implement NESHAP requirements to the District, NESHAPs and 

MACTs promulgated by EPA are usually incorporated by reference into District 

Rule 4002 (National Emission Standards for Hazardous Air Pollutants). It is 

important to mention that the District implements NESHAPs and MACTs by 

incorporating the emission standards as conditions of the Permits to Operate 

issued to affected sources. 

1. 40 CFR 63 Subpart T (National Emission Standards for HAPs: 

Halogenated Solvent Cleaning) 

Subpart T applies to cleaning machines that use any of the following 

halogenated solvents: methylene chloride, trichloroethylene, 

perchloroethylene (tetrachloroethylene), methyl chloroform (1,1,1-

trichloroethane), carbon tetrachloride, and chloroform. 

Rule 4661, Section 4.4 exempts halogenated hydrocarbons from the rule. 

However, the District addresses HAPs via rule 4102 (Nuisance) along with 

a Health Risk Assessment-Emissions modeling process, in addition to 

District 7000 series toxic rules. 
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III. How does District Rule 4661 compare to rules in other air districts?

District staff compared District Rule 4661 with the rules of other California ozone 

nonattainment air districts for solvents. The results of the analysis are discussed below. 

A. South Coast Air Quality Management District (SCAQMD) Rule 1171 - Solvent Cleaning 

Operations (Amended February 1, 2008) 

SCAQMD Rule 1171 applies to solvent cleaning operations. The rule requires 

solvent VOC content limits, or a VOC capture and control system with efficiencies 

of 90% and 95% respectively. District Rule 4661 has a facility solvent VOC 

emission limit of 833 lb/month or a VOC capture and control system with 

efficiencies of 90% and 95% respectively. Since the two both allow identical add 

control efficiencies, the rules are considered equivalent. Overall SJVAPCD Rule 

4661 is at least as stringent as SCAQMD Rule 1171. 

B. Bay Area Air Quality Management District (BAAQMD) Regulation 8 Rule 16 - 

Solvent Cleaning Operations (amended October 16, 2002) 

BAAQMD Reg 8 Rule 11 applies to solvent cleaning operations. The rule requires 

work practice standards and solvent VOC content limits, or for some categories a 

VOC capture and control system with a control efficiency of 90%. District Rule 

4661 has a facility solvent VOC emission limit of 833 lb/month or a VOC capture 

and control system with efficiencies of 90% and 95% respectively. Overall 

SJVAPCD Rule 4661 is at least as stringent as BAAQMD Regulation 8 Rule 16. 

C. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 

441 (Organic Solvents) amended December 6, 1978 

SMAQMD Rule 441 applies to solvent cleaning operations. The rule requires work 

practice standards and solvent VOC emission limits (e.g. 39.7 lb/day for 

photochemically reactive solvents, and 2970 lb/day for non-photochemically 

reactive solvents), or a VOC reduction of 85% via add on control. District Rule 

4661 has a facility solvent VOC emission limit of 833 lb/month or a VOC capture 

and control system with efficiencies of 90% and 95% respectively. Overall 

SJVAPCD Rule 4661 is at least as stringent as SMAQMD Rule 441. 

 D. Ventura County Air Pollution Control District (VCPCD) - No organic solvent 

rule. 

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4661 

satisfies RACT for organic solvents. 
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Rule 4662 - Organic Solvent Degreasing Operations 

Emissions Inventory: 

Tons per day - summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 0 0 0 0 0 0 0 0 

VOC 4.294 4.295 4.296 4.297 4.295 4.295 4.295 4.296 

(Source: District 2007 Ozone Plan) 

I. District Rule 4662 Description: 

District Rule 4662, recently amended on September 20, 2007, controls VOC emissions 

from organic solvent degreasers (tanks, trays, drums, or other containers). 

District Rule 4662 has solvent VOC content requirements for cold cleaners (25 gVOC/L), or an equivalent control system with no less than 85% overall control for cold 

cleaners, open-vapor, and conveyorized degreasers. The rule also contains work 

practice standards and design requirements for these categories of source. 

II. How does District Rule 4662 compare with federal rules and regulations? 

A. EPA – Control Technique Guidelines (CTG) 

 

1. The CTG EPA-450/2-77-022 1977/11 (Control of Volatile Organic Emissions from 

Solvent Metal Cleaning) applies to degreasing operations located in marginal, 

moderate, serious or severe ozone nonattainment areas that has the potential to 

emit greater than or equal to 25 tons/year of VOC, and equal to greater than 10 

tons/year of VOC for extreme ozone nonattainment areas. 

This 1977 CTG refers to requirements, controls, design, and work-practice 

standards that are no more stringent than SJVAPCD Rule 4662. 

B. EPA - Alternative Control Technology (ACT) – There are no ACTs that apply to 

degreasers. 

C. Standards of Performance for New Stationary Sources (NSPS) – There are no 

NSPS regulations that apply to degreasers. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) – There are no NESHAP 

regulations that apply to degreasers. 
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III. How does District Rule 4662 compare to rules in other air districts?

District staff compared District Rule 4662 with the rules of other California ozone 

nonattainment air districts for solvents. The results of the analysis are discussed below. 

A. South Coast Air Quality Management District (SCAQMD) Rule 1122 - Solvent Degreasers 

(Amended October 1, 2004) 

SCAQMD Rule 1122 applies to solvent degreasers. SCAQMD Rule 1122 contains 

solvent VOC content requirements for cold cleaners (25 g-VOC/L), or an equivalent 

control system with no less than 85% overall control for cold cleaners, open-vapor, 

and conveyorized degreasers. The rule also contains equivalent work practice 

standards and design requirements for these categories of source compared to 

SJVAPCD Rule 4662. 

Since the two both allow identical (or equivalent) control efficiencies, the rules are 

considered equivalent. Overall SJVAPCD Rule 4662 is at least as stringent as 

SCAQMD Rule 1122. 

B. Bay Area Air Quality Management District (BAAQMD) - No degreasing rule. 

C. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 

454 (Degreasing Operations) amended September 25, 2008 

SMAQMD Rule 454 applies to solvent degreasers. SMAQMD Rule 454 contains 

solvent VOC content requirements for cold cleaners (25 g-VOC/L), or an equivalent 

control system with no less than 85% overall control for cold cleaners, open-vapor, 

and conveyorized degreasers. The rule also contains equivalent work practice 

standards and design requirements for these categories of source compared to 

SJVAPCD Rule 4662. 

Since the two both allow identical (or equivalent) control efficiencies, the rules are 

considered equivalent. Overall SJVAPCD Rule 4662 is at least as stringent as 

SMAQMD Rule 454. 

 D. Ventura County Air Pollution Control District (VCPCD) Rule 74.6 (Surface 

Cleaning and Degreasing) amended July 1, 2004 

VCPCD Rule 454 applies to solvent degreasers. VCPCD Rule 74.6 contains 

solvent VOC content requirements for cold cleaners (25 g-VOC/L), or an equivalent 

control system with no less than 85% overall control for cold cleaners, open-vapor, 

and conveyorized degreasers. The rule also contains equivalent work practice 

standards and design requirements for these categories of source compared to 

SJVAPCD Rule 4662. 
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Since the two both allow identical (or equivalent) control efficiencies, the rules are 

considered equivalent. Overall SJVAPCD Rule 4662 is at least as stringent as 

VCPCD Rule 454. 

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4662 

satisfies RACT for organic solvent degreasing operations. 
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Rule 4663 - Organic Solvent Cleaning, Storage, and Disposal 

Emissions Inventory: 

Tons per day - summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 0 0 0 0 0 0 0 0 

VOC 4.294 4.295 4.296 4.297 4.295 4.295 4.295 4.296 

(Source: District 2007 Ozone Plan) 

I. District Rule 4663 Description: 

District Rule 4663, recently amended on September 20, 2007, controls VOC emissions 

from organic solvent cleaning outside a degreaser (tank, tray, drum, or other container) as 

well as storage and disposal of the solvents. 

District Rule 4663 has solvent VOC content requirements for general product cleaning 

or surface preparation, repair and maintenance cleaning, and cleaning of 

coating/adhesive application equipment (all 25 g-VOC/L), as well as specific other 

categories (ranging from 100-800 g-VOC/L) or an equivalent control system with no less 

than 90% overall control for the emissions generated. The rule also requires containers 

for solvent storage and disposal. 

II. How does District Rule 4663 compare with federal rules and regulations? 

A. EPA – Control Technique Guidelines (CTG) 

 

1. The CTG EPA-450/2-77-022 1977/11 (Control of Volatile Organic Emissions from 

Solvent Metal Cleaning) applies to degreasing operations located in marginal, 

moderate, serious or severe ozone nonattainment areas that has the potential to 

emit greater than or equal to 25 tons/year of VOC, and equal to greater than 10 

tons/year of VOC for extreme ozone nonattainment areas. 

Since this CTG covers degreasers, it will not be compared to SJVAPCD Rule 

4663. 

2. The CTG EPA-453/R-06-001 2006/09 (Control Techniques Guidelines for 

Industrial Cleaning Solvents) applies to solvent cleaning operations located in 

marginal, moderate, serious or severe ozone nonattainment areas that has the 

potential to emit greater than or equal to 25 tons/year of VOC, and equal to 

greater than 10 tons/year of VOC for extreme ozone nonattainment areas. 

The CTG requirement is a solvent VOC content limit of 50 g/L or an overall VOC 

control efficiency of 85%. District Rule 4663 has a solvent VOC limits or an 
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overall VOC control efficiency requirement no less than 90%. As such, Rule 

4663 is more stringent than this CTG. 

B. EPA - Alternative Control Technology (ACT) 

1. The ACT EPA-450/3-89-030 1989/08 (Alternative Control Technology 

Document – Halogenated Solvent Cleaners) applies to cleaning machines 

that use halogenated solvents. The halogenated solvents listed in the ACT 

that EPA is concerned about are methylene chloride, trichloroethylene, 

perchloroethylene (tetrachloroethylene), CFC-113 (1,1,2-trichloro-1,2,2-

Trifluoroethane), and methyl chloroform (1,1,1-trichloroethane). 

The District addresses HAPs via rule 4102 (Nuisance) along with a Health 

Risk Assessment-Emissions modeling process, in addition to District 7000 

series toxic rules. 

2. The ACT EPA-453/R-94-015 1994/02 (Alternative Control Techniques 

Document – Industrial Cleaning Solvents) applies to industrial cleaning with 

organic solvents. The ACT focuses on suggested solvent accounting and 

management practices. District Rule 4663 requires solvent VOC emission 

limits or an overall VOC control efficiency requirement greater than 90%. As 

such, Rule 4663 is more stringent than this ACT for VOCs. 

C. Standards of Performance for New Stationary Sources (NSPS) – There are no 

NSPS regulations that apply to solvents. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

NESHAPs and MACTs are requirements contained in 40 Code of Federal 

Regulations (CFR) Part 61 and 40 CFR Part 63. Since EPA has delegated the 

authority to implement NESHAP requirements to the District, NESHAPs and 

MACTs promulgated by EPA are usually incorporated by reference into District 

Rule 4002 (National Emission Standards for Hazardous Air Pollutants). It is 

important to mention that the District implements NESHAPs and MACTs by 

incorporating the emission standards as conditions of the Permits to Operate 

issued to affected sources. 

1. 40 CFR 63 Subpart T (National Emission Standards for HAPs: 

Halogenated Solvent Cleaning) 

Subpart T applies to cleaning machines that use any of the following 

halogenated solvents: methylene chloride, trichloroethylene, 

perchloroethylene (tetrachloroethylene), methyl chloroform (1,1,1-

trichloroethane), carbon tetrachloride, and chloroform. 
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The District addresses HAPs via rule 4102 (Nuisance) along with a Health 

Risk Assessment-Emissions modeling process, in addition to District 7000 

series toxic rules. 

III. How does District Rule 4663 compare to rules in other air districts?

District staff compared District Rule 4663 with the rules of other California ozone 

nonattainment air districts for solvents. The results of the analysis are discussed below. 

A. South Coast Air Quality Management District (SCAQMD) Rule 1171 - Solvent 

Cleaning Operations (Amended February 1, 2008) 

This SCAQMD rule is addressed in the SJVAPCD Rule 4661 (Solvent Cleaning) 

RACT-SIP analysis. Staff considers SJVAPCD solvent requirements, Rules 4661 

and 4663, at least as stringent as SCAQMD Rule 1171. 

B. Bay Area Air Quality Management District (BAAQMD) Regulation 8 Rule 16 - 

Solvent Cleaning Operations (amended October 16, 2002) 

This BAAQMD rule is addressed in the SJVAPCD Rule 4661 (Solvent Cleaning) 

RACT-SIP analysis. Staff considers SJVAPCD solvent requirements, Rules 4661 

and 4663, at least as stringent as BAAQMD Reg 8 Rule 11. 

C. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 

441 (Organic Solvents) amended December 6, 1978 

This SMAQMD rule is addressed in the SJVAPCD Rule 4661 (Solvent Cleaning) 

RACT-SIP analysis. Staff considers SJVAPCD solvent requirements, Rules 4661 

and 4663, at least as stringent as SMAQMD Rule 441. 

D. Ventura County Air Pollution Control District (VCPCD) - No organic solvent 

rule. 

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4663 

satisfies RACT for organic solvent cleaning, storage, and disposal operations. 
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Rule 4672 – Petroleum Solvent Dry Cleaning Operations 

Emissions Inventory: 

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

VOC 0.06 0.06 0.07 0.07 0.07 0.08 0.08 1.09 

(Source: District 2007 Ozone Plan) 

District Rule 4672 Description: 

The purpose of this rule is to limit VOC emissions from petroleum solvent dry cleaning 

operations. 

The rule requires that petroleum solvent dry cleaning equipment shall not be operated if 

solvent liquid and/or vapor is leaking from any portion of the equipment. Solvents shall 

be stored in closed containers. All washer lint traps, button traps, access doors and 

other parts of the equipment where solvent may be exposed to the atmosphere shall be 

kept closed at all times except as required for proper operation or maintenance. All 

wastes from dry cleaning facilities subject to Department of Health Services regulation 

shall be stored, transported and disposed of in accordance with Department of Health 

Services regulations. 

The rule requires used filtering material to be put into a sealed container immediately 

after removal from the filter, unless filtering material is fully drained in a sealed filter 

housing for at least 24 hours before being discarded (12 hours if dried in a dryer is 

vented to an emission control device); or petroleum solvent content in all filtration 

wastes is reduced to 1.0 kilogram or less per 100 kilograms dry weight of articles dry 

cleaned. 

Articles which have been cleaned shall be transferred to the dryer within five minutes 

after they are received from the washer, or shall be stored in closed transfer carts. 

The rule requires petroleum solvent dry cleaners to be equipped with a control device 

which reduces the total emissions of petroleum solvent vapors from drying tumblers, 

washers, and cabinets by at least 90 percent by weight; or to have a solvent recovery 

dryer that recovers at least 90 percent of petroleum solvent by weight. The flow rate of 

recovered solvent from the solvent recovery dryer at the termination of the recovery 

cycle shall not exceed 0.05 liters per minute. 

Leak inspection must be performed every 15 days and any detected leaks repaired 

within 3 days of detection. 
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The rule requires the following records to be maintained and retained for at least two 

years: (a) usage records - records showing amounts of solvents purchased and used; 

(b) solvent filtration records - records of pre-washed weight of articles cleaned per load; 

and (c) solvent filtration waste records - records which indicate the amount of volatile 

organic compounds contained in the filtration waste material per 100 kilograms dry 

weight of articles dry cleaned. 

How does District Rule 4672 compare with federal rules and regulations? 

1. EPA – Control Technique Guidelines (CTG) 

There is no CTG for this category. 

2. EPA – Alternative Control Technology (ACT) 

There is no ACT for this category. 

3. Standards of Performance for Petroleum Dry Cleaners (NSPS) 

40 CFR 60 Subpart JJJ, Standards of Performance for Petroleum Dry Cleaners. 

This NSPS is applicable to dry cleaners with a rated dryer capacity of 84 pounds 

or greater. The NSPS requires the use of a solvent recovery dryer for all 

installations after 12/14/1982. The flow rate of recovered solvent from the solvent 

recovery dryer at the termination of the recovery cycle should be no greater than 

0.05 liters per minute (In the rules discussed, this standard is equivalent to 90% 

control). The NSPS also requires the use of cartridge filters, and requires such 

filters to be drained in their sealed housings for at least 8 hours prior to their 

removal. 

The NSPS further requires leak inspections to be conducted every 15 days, and 

any detected defects to be repaired within the subsequent 15 days. 

This NSPS is less stringent than District Rule 4672 because it applies only to 

petroleum solvent dry cleaners with a minimum dryer capacity of 84 pounds, 

whereas District Rule 4672 applies to all petroleum solvent dry cleaners. 

In addition, the NSPS requires filters to be drained for only 8 hours before 

removal, whereas District Rule 4672 requires at least 12 hours. The NSPS also 

allows up to 15 days for repair of leaks, whereas District Rule 4672 requires 

repairs within 3 days of detection. 

Thus, District Rule 4672 is more stringent overall than this NSPS. 
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4. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There is no NESHAP or MACT applicable to this category. 

How does District Rule 4672 compare to rules in other air districts?

District staff compared emission limits, optional control requirements, and work practice 

standards in District Rule 4672 to comparable requirements in rules from the following 

California nonattainment areas: 

• South Coast AQMD Rule 1102 (amended 11/17/2000) 

• Bay Area AQMD Regulation 8 Rule 17 (amended 9/5/1990) 

• Ventura County APCD Rule 74.5.1 (adopted 12/4/1990) 

• Sacramento Metro AQMD Rule 444 (adopted 8/13/1981) 

1. South Coast AQMD Rule 1102 (amended 11/17/2000) 

South Coast AQMD rule 1102, Dry Cleaners Using Solvents Other Than 

Perchloroethylene, is applicable to dry cleaning equipment using petroleum solvents. 

The rule requires that: (a) all washer lint traps, button traps, access doors, and other 

parts of the equipment where solvent may be exposed to the atmosphere shall be kept 

closed at all times except when required for proper operation or maintenance; (b) button 

and lint traps shall be cleaned each working day; (c) the still residue, used filtering 

material, lint, used solvent and all other wastes containing solvent shall be stored in 

sealed containers until properly transported for disposal; (d) for any dry cleaning system 

that is equipped with cartridge filters containing paper or carbon or a combination 

thereof, the cartridge filters shall be fully drained in a sealed filter housing for at least 24 

hours before removal; (e) all solvents shall be stored in closed containers; (f) waste 

water evaporators shall be operated to ensure that no liquid solvent or visible emulsion 

is allowed to vaporize to the atmosphere. 

The rule further requires the installation and use of a solvent recovery dryer or an 

equivalent control device that reduces VOC emissions from drying tumblers by at least 

90 percent by weight. Materials which have been dry cleaned shall be transferred to the 

dryer by hand or in an enclosed transfer cart within five minutes after they are removed 

from the washer. The rule limits the amount of solvent used to less than 4.5 pounds per 

100 pounds of materials dry cleaned. 

Monthly leak inspections are required. Detected leaks must be repaired within 3 working 

days of detection. 
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Records of solvent usage and leak inspections/detection/repair shall be maintained and 

retained for at least two years. 

In terms of the major emission control requirements such as the use of solvent recovery 

devices, handling of solvent and solvent-laden material, and leak inspections and 

repairs, District Rule 4672 and South Coast AQMD Rule 1102 are similar. Both rules 

require the use of a solvent recovery dryer or similar add-on device capable of reducing 

solvent emissions by at least 90%. Both rules require solvent and solvent-laden 

materials to be stored in sealed containers, and both rules require regular leak 

inspections with prompt repairs of any detected leaks. 

The differences between the two rules are not significant enough to make either rule 

more or less stringent than the other. Therefore, District Rule 4672 is at least as 

stringent as South Coast AQMD Rule 1102. 

2. Bay Area AQMD Regulation 8 Rule 17 (amended 9/5/1990) 

The purpose of Bay Area AQMD Regulation 8 Rule 17, Petroleum Dry Cleaning 

Operations, is to limit the emissions of petroleum solvents used in dry cleaning facilities. 

Small facilities using less than 2,642 gallons of solvent per year are exempt, as long as 

they maintain records of solvent usage. 

The rule stipulates that a person shall not operate petroleum solvent dry cleaning 

equipment unless: (a) there is no solvent liquid or solvent vapor leaking from any portion 

of the equipment or the leaking equipment shall not be operated; (b) solvents and spent 

solvents are stored in closed containers; (c) all washer and dryer traps, access doors, 

and other parts of these pieces of equipment where solvent may be exposed to the 

atmosphere are kept closed at all times except when required for proper operation or 

maintenance; (d) cartridge filters are drained in the filter housing for at least 12 hours or 

placed in an enclosed device including a solvent recovery dryer until dry before being 

discarded; (e) all wastes from dry cleaning facilities must be maintained and transported 

in sealed containers and disposed of in accordance with Department of Health Services 

regulations; (f) articles which have been cleaned must be transferred to the dryer within 

five minutes after they are removed from the washer, or shall be stored in closed 

transfer carts. 

The rule also requires the installation and use of an emission control system on the dry 

cleaning equipment. The required control method may be either: (a) an add-on-control 

device which reduces the total emissions of precursor organic compounds by at least 85 

percent by weight; or (b) a solvent recovery dryer that recovers at least 85% of 

petroleum solvent by weight. 

To comply with solvent filtration requirements, an operator may: (a) use a cartridge 

filtration system, or (b) reduce the total volatile organic compound content in all filtration 

wastes to 1.0 kilogram or less per 100 kilograms dry weight of articles cleaned (or no 
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more than 0.25 kilogram of solvent per kilogram of solvent still or filter waste) before 

disposal and exposure to the atmosphere. 

The rule requires record keeping only for facilities claiming low usage exemption 

(records of quantities of solvent used) and those not using cartridge filters (records of 

weights of materials washed). Required records must be maintained for a period of two 

years. 

District Rule 4672 is more stringent than Bay Area AQMD Regulation 8 Rule 17 

because it requires a higher control efficiency (90%) for emission control add-on 

devices and solvent recovery dryers. In addition, unlike Bay Area AQMD Regulation 8 

Rule 17, District Rule 4672 provides no low-use exemption, requires regular inspection 

of dry cleaning equipment and prompt repair of any leaks or defects, and requires 

record keeping for all affected facilities. 

Thus, District Rule 4672 is more stringent overall than Bay Area AQMD Regulation 8 

Rule 17.

3. Ventura County APCD Rule 74.5.1 (adopted 12/4/1990) 

Ventura County APCD Rule 74.5.1, Petroleum Solvent Dry Cleaning, stipulates that a 

person shall not operate petroleum solvent dry cleaning equipment unless: (a) there is 

no solvent liquid or solvent vapor leaking from any portion of the equipment or the 

leaking equipment shall not be operated; (b) solvents and spent solvents are stored in 

closed containers; (c) all washer and dryer traps, access doors, and other parts of these 

pieces of equipment where solvent may be exposed to the atmosphere are kept closed 

at all times except when required for proper operation or maintenance; (d) cartridge 

filters are drained in the filter housing for at least 24 hours or 12 hours if further dried in 

an enclosed container vented to a control device; (e) all wastes from dry cleaning 

facilities must be maintained and transported in sealed containers and disposed of in 

accordance with Department of Health Services regulations; (f) articles which have 

been cleaned must be transferred to the dryer within five minutes after they are 

removed from the washer, or shall be stored in closed transfer carts. 

The rule also requires the installation and use of an emission control system on the dry 

cleaning equipment. The required control method may be either: (a) an add-on-control 

device which reduces the total emissions of precursor organic compounds by at least 90 

percent by weight; or (b) a solvent recovery dryer that recovers at least 90% of 

petroleum solvent by weight. 

To comply with solvent filtration requirements, an operator may: (a) use a cartridge 

filtration system, or (b) a filter system or process that reduces the petroleum solvent 

content in all filtration wastes to no greater than 1.0 lb per 100 lb dry weight of articles 

cleaned. 
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The rule requires record keeping for weights of materials cleaned, solvent purchase and 

usage, hazardous waste disposal, and cartridge filter draining and drying operations. All 

records are to be retained for at least two years. 

In terms of the major emission control requirements such as the use of solvent recovery 

devices, handling of solvent and solvent-laden materials, and record keeping, District 

Rule 4672 and Ventura County APCD Rule 74.5.1 are similar. Both rules require the 

use of a solvent recovery dryer or add-on device capable of reducing solvent emissions 

by at least 90%. Both rules require solvent and solvent-laden materials to be stored in 

sealed containers, and both rules require record keeping for materials cleaned and 

solvent usage. 

The differences between the two rules are not significant enough to make either rule 

more or less stringent than the other. For instance, Ventura County APCD Rule 74.5.1 

does not provide a specific leak inspection schedule or require leak inspections and 

repair records, but at the same time it stipulates that leaking equipment shall not be 

operated. 

 Therefore, District Rule 4672 is at least as stringent as Ventura County APCD Rule 

74.5.1.

4. Sacramento Metro AQMD Rule 444 (adopted 8/13/1981) 

The purpose of Sacramento Metro AQMD Rule 444, Petroleum Solvent Dry Cleaning, is 

to limit the emissions of petroleum solvents used in dry cleaning facilities. 

Small facilities using less than 2,642 gallons of solvent per year are exempt from 

emission control installation requirements, but must observe emission-limiting operating 

requirements. 

The rule stipulates that a person shall not operate petroleum solvent dry cleaning 

equipment unless: (a) there is no liquid leaking from any portion of the equipment; (b) 

solvents are stored in closed containers; (c) all washer and dryer traps, access doors, 

and other parts of these pieces of equipment where solvent may be exposed to the 

atmosphere are kept closed at all times except when required for proper operation or 

maintenance; (d) still residue is stored in sealed containers or underground tanks, and 

disposed of by procedures approved by the Air Pollution Control Officer; (e) used 

filtering material shall be placed in sealed containers unless the dry cleaning system 

uses cartridge filters which are drained in the filter housing for at least 12 hours before 

removal, diatomaceous earth with centrifugal solvent extractor capable of reducing 

solvent content to less than 0.4 kg per kg of residue, or other filtering system capable of 

reducing solvent content of discarded filter material to less than 1.0 kg per 100 kg of 

materials cleaned. 

The rule also requires that a person operating dry cleaning equipment shall: (a) limit 

solvent emissions to the atmosphere to an average of 3.5 kilograms of solvent per 100 
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kilograms of articles dry cleaned, or (b) install and operate a solvent recovery dryer in a 

manner such that the dryer remains closed and the recovery phase continues until a 

final recovered solvent flow rate of not more than 50 milliliters per minute is attained. (In 

the comparable rules discussed, this standard is equivalent to an emission control of 

90%). 

Although both District Rule 4672 and Sacramento Metro AQMD Rule 444 have a similar 

control efficiency (90%) for the dry cleaning emission control devices, District Rule 4672 

has more stringent operating requirements for the handling of solvent-laden material, 

inspections and record keeping. District Rule 4672 requires solvent-laden materials to 

be transferred into dryers within 5 minutes, requires regular leak inspections and prompt 

repairs, and also requires record keeping for weights of materials cleaned, solvent 

usage and leak inspection and repair. Sacramento Metro AQMD Rule 444 has no 

corresponding requirements in these categories. 

District Rule 4672 is therefore more stringent overall than Sacramento Metro AQMD 

Rule 444.

Conclusion

After evaluation of federal rules and regulations as well as prohibitory rules in other 

California nonattainment areas, District staff concludes that District Rule 4672 satisfies 

RACT for Petroleum Solvent Dry Cleaning Operations. 
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Rule 4681 (Rubber Tire Manufacturing) 

Emissions Inventory: 

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 0 0 0 0 0 0 0 0

VOC 0.27 0.27 0.27 0.27 0.27 0.27 0.47 0.53

VOC 

adjusted* 

0 0 0 0 0 0 0 0

*The inventory is suspect. This source category has no active facilities. 

I. District Rule 4681 Description: 

District Rule 4681 limits the VOC emissions from rubber tire and recapping treadstock 

manufacturing facilities. The rule specifies emission standards for undertread 

cementing operations, green tire coating, bead cementing, and tread end cementing as 

discussed below. The rule requires containers for organic solvents and cements to be 

leak-free at all times, and covered except when adding or removing solvents and 

cements or when the containers are being cleaned or during gauging. The rule includes 

recordkeeping requirements. There are no exemptions in the rule. It is important to 

mention that there are no existing rubber tire manufacturing facilities currently operating 

in the District. A new rubber tire manufacturing facility that would like to operate in the 

District will be evaluated for Best Available Control Technology and emission offset 

requirements pursuant to District Rule 2201 (New and Modified Stationary Source 

Review Rule). 

District Rule 4681 Control Requirements 

3⁄4 Undertread Cementing Operation 

• Enclose the cement applicator, cement tank, and tread drying conveyor during 

normal operations so that VOC evaporation are captured. 

• All openings to the enclosure must have a minimum indraft of 60 meters per 

minute, except when it is opened to allow work inside. 

• Captured VOC must be transported to an emission control device with at least 

95% removal efficiency. 

• For new sources, the tread drying conveyor must operate to capture VOC 

emissions from the operation for at least 30 seconds after undertread cement 

has been applied. 

• As an alternative control, an equivalent reduction technique approved by the 

APCO is allowed if the undertread cement emissions are reduced to15 grams 

VOC or less per tire (daily average) 

3⁄4 Green Tire Coating Operation 
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• Coating must be waterborne, no more than one percent by weight if based on 

formulation data or 10 grams/liter of coating, including water but less exempt 

compounds, if determined by testing. 

3⁄4 Bead Cementing Operation 

• Operate an APCO approved emission control system or demonstrate that 

emissions, in grams/tire, from bead cementing operation have been reduced by 

at least 75% from the daily average for 3 consecutive years prior to rule adoption. 

A carbon adsorption must have at least 95% VOC removal efficiency and 

equipped with continuous VOC monitoring equipment to detect carbon bed 

breakthrough. An incineration system must oxidize at least 90% of VOC which 

enters the incinerator and equipped with temperature indicators in the 

combustion chambers. The collection system must achieve at least 85% 

collection efficiency. 

3⁄4 Tread End Cementing Operation 

• Operate an approved emission control system as described above for bead 

cementing operation or demonstrate that emissions, in grams/tire, from tread end 

cementing operation have been reduced by at least 62% from the daily average 

for 3 consecutive years prior to rule adoption. 

II. How does District Rule 4681 compare with federal rules and regulations? 

A. EPA – Control Technique Guidelines (CTG) 

1. EPA-450-2-78-030 (Control of Volatile Organic Emissions from Manufacture of 

Pneumatic Rubber Tires), December 1978 

This CTG establishes the recommended standards to control of VOC emissions from 

rubber tire manufacturing plants through tight control of solvent operations and the use 

of effective capture systems and exhaust treatment devices. VOCs are added to rubber 

components to aid in mixing, promote elasticity, produce tack (stickiness, or extend 

(replace) a portion of the rubber hydrocarbons. The CTG recommendation to reduce 

solvent emissions is based on lowering the solvent content of the raw material and 

treating the exhaust gas. The four major sources of VOC emissions from tire 

manufacturing and the control technology for each that is considered reasonably 

available are discussed below. 

3⁄4 Undertread Cementing 

• Carbon adsorption system with a capture efficiency of 65% to 85% and control 

device efficiency of 95%. The overall capture and control efficiency is 62% to 

81%; or 

• Incineration system with a capture efficiency of 65% to 85% and a control device 

efficiency of 90%. The overall capture and control efficiency is 59% to 77%. 

3⁄4 Green Tire Spraying 
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• Waterbased coating (overall efficiency of 97% depending on formulation; or 

• Carbon adsorption system with a capture efficiency of 80% to 90% and control 

device efficiency of 95%. The overall capture and control efficiency is 76% to 

86%; or 

• Incineration system with a capture efficiency of 65% to 85% and a control device 

efficiency of 90%. The overall capture and control efficiency is 59% to 77%. 

3⁄4 Bead Dipping 

• Carbon adsorption system with a capture efficiency of 75% to 85% and control 

device efficiency of 95%. The overall capture and control efficiency is 71% to 

81%; or 

• Incineration system with a capture efficiency of 75% to 85% and a control device 

efficiency of 90%. The overall capture and control efficiency is 68% to 77%. 

3⁄4 Tread End Cementing 

• Carbon adsorption system with a capture efficiency of 65% to 85% and control 

device efficiency of 95%. The overall capture and control efficiency is 62% to 

81%; or 

• Incineration system with a capture efficiency of 65% to 85% and a control device 

efficiency of 90%. The overall capture and control efficiency is 59% to 77%. 

Comparison of CTG and District Rule 4681 

District Rule 4681 emission control requirements (carbon adsorption: 95% control 

efficiency and 85% capture efficiency; incineration: 90% control efficiency and 86% 

capture efficiency) are more stringent than the capture and control efficiency standards 

for each major source of VOC emissions from tire manufacturing recommended by the 

CTG. It is important to mention that there are no rubber tire manufacturing facilities 

currently operating in the District. If a new rubber tire manufacturing facility wants to 

operate in the District in the future, it will be evaluated for Best Available Control 

Technology and emission offset requirements pursuant to District Rule 2201 (New and 

Modified Stationary Source Review Rule). Based on the above discussion, District staff 

deems that District Rule 4681 satisfies RACT. 

 

B. EPA – Alternative Control Techniques (ACT) Document 

District staff’s review of the EPA ACT list indicates that there is no ACT for rubber tire 

manufacturing. 
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C. Standards of Performance for New Stationary Sources (NSPS) 

1. 40 CFR 60 Subpart BBB (Standards of Performance for the Rubber Tire 

Manufacturing Industry) 

This NSPS applies to rubber tire manufacturing plants (each undertread cementing 

oepration, each sidewall cementing operation, each tread end cementing operation, 

each bead cementing operation, each green tire spraying operation, each Michelin-A 

operation, each Michelin-B operation, and each Michelin-C automatic operation) that 

commence construction, modification, or reconstruction after January 20, 1983. 

The NSPS requires operators to meet the following standards: 

3⁄4 Each Undertread Cementing Operation 

• Discharge into the atmosphere no more than 25% of the VOC used (75% 

emission reduction) for each month; or 

• Maintain total (uncontrolled) VOC use less than or equal to 8,531 lb VOC per 28 

days, 8.846 lb VOC/29 days, 9,149 lb VOC per 30 days, 9,436 lb VOC per 31 

days, or 10, 670 lb VOC per 35 days. 

3⁄4 Each Sidewall Cementing Operation 

• Discharge into the atmosphere no more than 25% of the VOC used (75% 

emission reduction) for each month; or 

• Maintain total (uncontrolled) VOC use less than or equal to 7,099 lb VOC per 28 

days, 7,363 lb VOC per 29 days, 7,606 VOC per 30 days, 7,870 lb VOC per 31 

days, or 8,885 lb VOC per 35 days. 

3⁄4 Each Tread End Cementing Operation: Discharge no more than 10 grams (0.022 lb) 

VOC per bead cemented for each month. 

3⁄4 Each Bead Cementing Operation: Discharge no more than 5 grams (0.011 lb) VOC 

per bead cemented for each month. 

3⁄4 Each Green Tire Spraying Operation using only water based sprays: Discharge no 

more than 1.2 grams (0.0026 lb) VOC per tire sprayed with an inside green tire 

spray for each month and no more than 9.3 grams (0.021 lb) VOC per tire sprayed 

with an outside green tire spray each month. 

3⁄4 Each Green Tire Spraying Operation using only organic solvent-based sprays: 

Discharge no more than 25% of the VOC used (75% reduction) for each month; or 

maintain total (uncontrolled) VOC use less than or equal to 7,099 lb VOC per 28 

days, 7,363 lb VOC per 29 days, 7,606 VOC per 30 days, 7,870 lb VOC per 31 

days, or 8,885 lb VOC per 35 days. 
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3⁄4 Each Green Tire Spraying Operation where both waterbased and organic solventbased sprays are used: Discharge no more than 1.2 grams (0.0026 lb) VOC per tire 

sprayed with waterbased inside green tire spray for each month and no more than 

9.3 grams (0.021 lb) VOC per tire sprayed with waterbased outside green tire spray 

for each month; and either discharge no more than 25% of the VOC used in 

organicsolvent-based green tire sprays (75% reduction) for each month or maintain 

total (uncontrolled) VOC use less than or equal to 7,099 lb VOC per 28 days, 7,363 

lb VOC per 29 days, 7,606 VOC per 30 days, 7,870 lb VOC per 31 days, or 8,885 lb 

VOC per 35 days. 

3⁄4 Each Michelin-A Operation 

• Discharge no more than 35% of the VOC used (65% reduction) for each month; 

or 

• Maintain total (uncontrolled) VOC use less than or equal to 3,461 lb VOC per 28 

days, 3,593 lb VOC per 29 days, 3,726 lb VOC per 30 days, 3,836 lb VOC per 31 

days, or 4,343 lb VOC per 35 days. 

3⁄4 Each Michelin-B Operation 

• Discharge no more than 25% of the VOC used (75% reduction); or 

• Maintain total (uncontrolled) VOC use less than or equal to 2,888 lb VOC per 28 

days, 2,998 lb VOC per 29 days, 3,086 lb VOC per 30 days, 3,197 lb VOC per 31 

days, or 3,616 lb VOC per 35 days. 

3⁄4 Each Michelin-C Operation 

• Discharge no more than 55% of the VOC used (75% reduction); or 

• Maintain total (uncontrolled) VOC use less than or equal to 3,461 lb VOC per 28 

days, 3,593 lb VOC per 29 days, 3,726 lb VOC per 30 days, 3,836 lb VOC per 31 

days, or 4,343 lb VOC per 35 days. 

Operators of each undertread cementing operation and each sidewall cementing 

operation in rubber tire manufacturing plants that commenced construction modification, 

or reconstruction after January 20, 1983 and before September 15, 1987 has the option 

of complying with Section 60.542a (alternate standard for VOC) which prohibits 

discharge into the atmosphere no more than 25 grams (0.55 lb) VOC per tire processed 

for each month if the operation uses 25 grams (0.055 lb) or less VOC per tire processed 

and does not employ a VOC emission reduction system. 

Comparison of NSPS and District Rule 4681 

District Rule 4681 emission control requirements overall, are more stringent than the 

NSPS standards. For undertread cementing operation, District rule 4641 requires an 

overall capture and control efficiency of at least 80% for carbon adsorption or 76% for 

incineration while the NSPS only require 75% emission reduction. For green tire 

spraying, District Rule 4681 only allows waterborne coating which contains no more 

than one percent by weight if based on formulation data or 10 grams/liter of coating, 

including water but less exempt compounds, if determined by testing, while the NSPS 
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allows the use of both waterbased and organic solvent-based coatings that meet certain 

requirements as discussed above. Although District Rule 4681 does not specify any 

emission standards for Michelin, the overall capture and control efficiency of District 

Rule 4681 is more stringent than NSPS emission reduction standard of 65% for 

Michelin-A, 75% for Michelin-B, and 65% for Michelin-C operations. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

NESHAPs and MACTs are requirements contained in 40 Code of Federal Regulations 

(CFR) Part 61 and 40 CFR Part 63. Since EPA has delegated the authority to 

implement NESHAP requirements to the District, NESHAPs and MACTs promulgated 

by EPA are usually incorporated by reference into District Rule 4002 (National Emission 

Standards for Hazardous Air Pollutants). It is important to mention that the District 

implements NESHAPs and MACTs by incorporating the emission standards as 

conditions of the Permits to Operate issued to affected sources. 

1. 40 CFR Part 63 Subpart XXXX (NESHAP for Rubber Tire Manufacturing) 

 

This NESHAP applies to a rubber tire manufacturing that is located at, or is a part of, a 

major source of HAP emission. A major source of HAP emission is any stationary 

soruce or group of stationary source within a contiguous area and is under a common 

control that emits or has the potential to emit considering controls, in the aggregate, a 

single HAP at a rate of 9.07 megagrams (10 tons) or more per year or any combination 

of HAP at a rate of 22.68 megagrams (25 tons) or more per year. This NESHAP does 

not apply if the primary product produced at the affected major source is subject to 

another subpart under this part 63 as of the effective date of this subpart, or start of the 

source, which ever is later; or if the rubber tire manufacturing affected source is a 

research and development facility whose primary purpose is to conduct research and 

development into new processes and products, where such a source is operated under 

the close supervision of technically trained personnel and is not engaged in the 

manufacture of products for commercial use for commercial sale in commerce, except 

in a de minimis manner. An affected source is a new affected source if a new 

construction if construction of the affected source commenced after October 18, 2000 

and it meets the applicability criteria discussed above. An affected source is 

reconstructed if it meets the criteria as defined in 40 CFR Part 63 Subpart A Section 

63.2. An affected source is existing if it is not a new or reconstructed. 

This NESHAP specify emission limits for tire production, tire cord production, and 

puncture sealant application. For tire production or tire cord production, there are two 

compliance options: HAP constituent option or production-based option, both options 

have specified HAP limits. For puncture sealant application, there two compliance 

options: percent reduction option (measured as VOC emissions) or HAP constituent 

option. The percent reduction option includes operating limits for control devices. In 
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addition, the NSPS includes monitoring, operation, maintenance, recordkeeping and 

reporting requirements. 

Comparison of NESHAP and District Rule 4681 

It is important to mention that the NESHAP HAP emission limits which are expressed in 

terms of mass (kg) of HAP per mass of cements, solvents, sealants or coatings used at 

the tire production operation are not directly comparable to the VOC limits of District rule 

4681 because, some HAPs may be exempt VOCs, and some VOCs may be HAPs; 

therefore, there is no direct correlation between the NESHAP limit versus District Rule 

4681 VOC limits. In addition, District Rule 4681 emission limits cannot be directly 

compared to the NESHAP limits because District Rule 4681 specify the limits for 

undertread cementing, green tire coating, bead cementing, and tread end cementing 

rule while the NESHAP specify the limits for tire production, tire cord production, and 

puncture sealant application. 

III. How does District Rule 4681 compare to rules in other air districts?

District staff compared District Rule 4641 with the rules of other California ozone 

nonattainment air districts’ rules on rubber tire manufacturing. Except for the Bay Area 

Air Quality Management District, South Coast Air Quality Management District, 

Sacramento Metropolitan Air Quality Management Air District, and Ventura County Air 

Pollution Control District have no rules for this source category. The result of the 

analysis of the BAAQMD rule is discussed below. 

1. Bay Area Air Quality Management District (BAAQMD) Regulation 8 Rule 21 

(Rubber Tire Manufacturing Operations) adopted March 5, 1980 

BAAQMD Regulation 8 Rule 21 limits the emissions of volatile organic compounds from 

pneumatic rubber tire manufacturing operations. The rule does not apply to operations 

applying new tread to used tires (exempts retread operations). For cementing and bead 

dipping operations, the rule requires the operation of an emission control system with at 

least 85% capture efficiency and 95% control efficiency. For green tire coating, the rule 

requires the use of waterbase (less than 3% VOC) coatings only or the operation of a 

collection system with at least 90% collection efficiency and a control device with at 

least 95% efficiency. An alternative compliance option, an operator may comply with 

the rule through an APCO-approved emission control plan provided the emissions of 

VOC, on a daily weighted average, is no greater than the amount which would result if 

the affected operations complied with the specified limits for cementing and bead 

dipping operation, and green tire coating operation. In addition to the emission limits, 

the rule requires containers for organic solvents or cements containing organic solvents 

to be covered at all times except when cleaning or adding or removing material, and any 

leaks must be repaired immediately. 
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Comparison of BAAQMD Regulation 8 Rule 21 and District Rule 4681 

BAAQMD Regulation 8 Rule 21 exempts retread of used tires while District Rule 4681 

does not have such exemption. BAAQMD Regulation 8 Rule 21 green tire coating 

requirements allow the use of waterbase coating with a VOC content of no more than 

3% or operate an emission control system with at least 85% capture efficiency and 95% 

control efficiency. In contrast, District Rule 4681 only allows the use of waterbase 

coating with no more than 1% by weight which is more stringent than BAAQMD 

Regulation 8 Rule 21 VOC limit of 3%. Both BAAQMD Regulation 8 Rule 21 and 

District Rule 4681 have the same emission control system capture and control 

efficiencies for cementing and bead dipping operations. Based on the above 

discussion, District staff deems that overall, District Rule 4681 is as stringent as 

BAAQMD Regulation 8 Rule 21. 

IV. Conclusion 

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4681 

satisfies RACT for rubber tire manufacturing. It is important to mention that there are no 

existing rubber tire manufacturing facilities currently operating in the District. A new 

rubber tire manufacturing facility that would like to operate in the District will be 

evaluated for Best Available Control Technology and emission offset requirements 

pursuant to District Rule 2201 (New and Modified Stationary Source Review Rule). 

Based on the above discussion, District staff deems that District Rule 4681 satisfies 

RACT. 
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Rule 4682 – Polystyrene, Polyethylene, and Polypropylene Products 

Manufacturing 

Emissions Inventory: 

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 0.128 0.143 0.154 0.157 0.165 0.175 0.185 0.194 

VOC 0.32 0.35 0.37 0.39 0.43 0.46 0.49 1.39 

(Source: District 2007 Ozone Plan) 

District Rule 4682 Description: 

The purpose of this rule is to limit emissions of VOC and trichlorofluoromethane (CFC11) and dichlorofluoromethane (CFC-12) from manufacturing and processing of 

products composed of polystyrene, polyethylene, or polypropylene and from the storage 

of VOC blowing agents. The provisions of this rule shall apply to any manufacturing, 

processing, and storage of products composed of polystyrene, polyethylene, or 

polypropylene. The provisions of this rule shall not apply to manufacturing and 

processing operations using polymeric materials containing less than 1 percent volatile 

organic compounds by weight, and not using a blowing agent in their process. 

District Rule 4682 requires that no facility shall operate controllable VOC emission 

sources at a polystyrene foam, polyethylene, or polypropylene manufacturing or 

processing operation unless one of the following VOC emission reduction methods is 

provided: 

• A blowing agent other than a VOC or trichlorofluoromethane (CFC-11) or 

dichlorodifluoromethane (CFC-12) is exclusively used; or 

• A system designed to achieve at least 90 percent VOC capture efficiency, and a 

thermal oxidizer which abates captured VOC emissions by at least 95 percent by 

weight; or 

• VOC emissions are controlled by a method which achieves an emission 

reduction equivalent to Section 5.1.2 and which does not include the use of 

trichlorofluoromethane (CFC-11) or dichlorodifluoromethane (CFC-12), and is 

approved by the APCO. 

On September 20, 2010, operations shall not conduct any manufacturing operations, as 

defined in Section 3.0, unless one of the following emission reduction methods is met: 

• The operator demonstrates, to the satisfaction of the APCO, that the total product 

emissions do not exceed 2.4 pounds of VOC per 100 pounds of total material 

processed, calculated over a monthly period. 

• A blowing agent other than a VOC or trichlorofluoromethane (CFC-11) or 

dichlorofluoromethane (CFC-12) is exclusively used. 

• An approved emission control system is installed and operating with 

manufacturing emissions vented only to the approved emission control system; 
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and emissions from the final manufactured product are to be vented only to the 

approved emission control system. The rule requires that the control device shall 

have a capture and control efficiency of 93%. This is greater than the previous 

emission control system requirements of 90% capture and 95% control (85.5% 

capture and control efficiency). 

• The operator demonstrates to the satisfaction of the APCO that the 

manufacturing emissions are no greater than the facility emissions which would 

occur under Section as calculated according to Section 5.5, and which does not 

include the use of trichlorofluoromethane (CFC-11) or dichlorodifluoromethane 

(CFC-12). 

How does District Rule 4682 compare with federal rules and regulations? 

1. EPA – Control Technique Guidelines (CTG) 

EPA-450/3-83-006 Control of Volatile Organic Compound Emissions from Manufacture 

of High-Density Polyethylene, Polypropylene, and Polystyrene Resins. 

The CTG applies to equipment in process units operated to produce one or more of the 

synthetic organic chemicals listed in Appendix E of the proposed standards of 

performance for SOCMI (46 FR 1136, January 5, 1981) ,methyl tert-butyl ether (MTBE), 

polyethylene, polypropylene, and polystyrene. District Rule 4682 applies to the 

manufacturing, processing, and storage of products composed of polystyrene, 

polyethylene, or polypropylene. Since the CTG applies to the manufacturing of

polyethylene, polypropylene, and polystyrene, and District Rule 4682 applies to the 

manufacturing of products made with polyethylene, polypropylene, and polystyrene, 

these two regulations are not regulating the same equipment. Therefore, this CTG and 

District Rule 4682 will not be compared. 

EPA-450/3-83-008 Control of Volatile Organic Compound Emissions from Manufacture 

of High-Density Polyethylene, Polypropylene, and Polystyrene Resins. 

This CTG covers the polymers and resins industry. The polymers and resins industry 

includes operations that convert monomer or chemical intermediate materials obtained 

from the basic petrochemical industry and the synthetic organic chemicals 

manufacturing industry into polymer products. Such products include plastic materials, 

synthetic resins, synthetic rubbers, and organic fibers. 

This CTG states that the following emission reductions or limitations are considered 

representative of RACT: 

• For polypropylene plants using liquid phase processes: a 98 weight percent 

reduction or reduction to 20 ppm of continuous VOC emissions from the 

polymerization reaction section (i.e., reactor vents), the material recovery section 

(i.e., decanter vents, neutralizer vents, by-product and diluent recovery 

operations vents), and the product finishing section (i.e., dryer vents and 

extrusion and pelletizing vents). 
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• For high-density polyethylene plants using liquid phase slurry processes: a 98 

weight percent reduction or reduction to 20 ppm of continuous VOC emissions 

from the material recovery section (i.e., ethylene recycle treater vents) and the 

product finishing section (i.e., dryer vents and continuous mixer vents). 

• For polystyrene plants using continuous processes: an emission limit of 0.12 kg 

VOC/1,000 kg product from the material recovery section (i.e., product 

devolatilizer system). 

District Rule 4682 requires that the operators use a blowing agent that does not contain 

VOCs or use a control system that has a comparable capture and control efficiency that 

is discussed as RACT in this CTG. Therefore, District Rule 4682 and this CTG have 

equivalent emission limiting requirements. 

2. EPA – Alternative Control Technology (ACT) 

EPA-450/3-90-020 Control of VOC Emissions From Polystyrene Foam Manufacturing. 

The purpose of this study was to conduct a survey of the polystyrene foam 

manufacturing industry to characterize the industry, define the nature and scope of 

volatile organic compound (VOC) emissions from this source category, identify potential 

controls for reducing VOC emissions, and develop cost estimates for VOC capture and 

control technologies. 

This ACT lists the following major findings concerning VOC emission controls: 

Incineration and carbon adsorption have been demonstrated as readily available add-on 

control technology for reducing VOC emissions, and the use of alternative blowing 

agents in place of CFC and hydrocarbon blowing agents has been implemented. Since 

District Rule 4682 requires that the facility either exclusively uses a blowing agent that is 

not a VOC, CFC-11 or CFC-12, or installs an approved control device to control VOC 

emission, the requirements of District Rule 4682 are equivalent to the ACT. 

3. Standards of Performance for New Stationary Sources (NSPS) 

Subpart DDD — Standards of Performance for Volatile Organic Compound (VOC) 

Emissions from the Polymer Manufacturing Industry. 

The provisions of this subpart apply to affected facilities involved in the manufacture of 

polypropylene, polyethylene, polystyrene, or poly (ethylene terephthalate). The affected 

facilities designated below for polypropylene and polyethylene are inclusive of all 

equipment used in the manufacture of these polymers, beginning with raw materials 

preparation and ending with product storage, and cover all emissions emanating from 

such equipment. 

This subpart requires the following actions be taken from various different types of 
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operations: 

Polypropylene, low density polyethylene, and high density polyethylene Continuous 

Emissions:

Operations shall reduce emissions of total organic compounds (minus methane and 

ethane) (TOC) by 98 weight percent, or to a concentration of 20 parts per million by 

volume (ppmv) on a dry basis, whichever is less stringent. In addition, the facility may 

control VOC emissions by combusting the exhaust in a boiler or steam generator with a 

heat input greater than 150 MMBtu/hr or combust in a flare. 

Polypropylene, low density polyethylene, and high density polyethylene Intermittent 

Emissions:

Operations shall control VOC emissions by combusting the exhaust in a boiler or steam 

generator or combust in a flare. 

Polystyrene:

Operators shall show not allow continuous TOC emissions to be greater than 0.0036 kg 

TOC/Mg (0.0072 lb TOC/ton) product; or allow the outlet gas stream temperature from 

each final condenser in the material recovery section to exceed −25 °C (−13 °F). 

Polyethylene:

Each owner or operator of a PET process line using a dimethyl terephthalate process 

shall limit the continuous TOC emissions from the material recovery section (i.e., 

methanol recovery) or limit the continuous TOC emissions and, if steam-jet ejectors are 

used to provide vacuum to the polymerization reactors, the ethylene glycol 

concentration from the polymerization reaction section by complying with the 

appropriate standard set forth below. 

Each owner or operator of a PET process line using a terephthalic acid process shall 

not allow the continuous TOC emissions from the esterification vessels in the raw 

materials preparation section to be greater than 0.04 kg TOC/Mg (0.08 lb TOC/ton) 

product or shall limit the continuous TOC emissions and, if steam-jet ejectors are used 

to provide vaccum to the polymerization reactors, the ethylene glycol concentration from 

the polymerization reaction section by complying with the appropriate standard set forth 

below. 

District Rule 4682 requires that no facility shall operate controllable VOC emission 

sources at a polystyrene foam, polyethylene, or polypropylene manufacturing or 

processing operation unless one of the following VOC emission reduction methods is 

provided: 

• A blowing agent other than a VOC or trichlorofluoromethane (CFC-11) or 

dichlorodifluoromethane (CFC-12) is exclusively used; or 

• A system designed to achieve at least 90 percent VOC capture efficiency, and a 

thermal oxidizer which abates captured VOC emissions by at least 95 percent by 

weight; or 
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• VOC emissions are controlled by a method which achieves an emission 

reduction equivalent to Section 5.1.2 and which does not include the use of 

trichlorofluoromethane (CFC-11) or dichlorodifluoromethane (CFC-12), and is 

approved by the APCO. 

On and after September 20, 2010, the requirements to meet compliance with District 

Rule 4682 will become more stringent. The current requirements are as stringent as the 

requirements of Subpart DDD, therefore the increase in the stringency of the rule will 

assure that District Rule 4682 remains as stringent as Subpart DDD. 

Subpart DDD requires the following monitoring requirements: 

• Whenever a particular item of monitoring equipment is specified in this section to 

be installed, the owner or operator shall install, calibrate, maintain, and operate 

according to manufacturer's specifications. 

• The owner or operator shall install, as applicable, the monitoring equipment for 

the control means used to comply with §60.562–1, except §60.562–1(a)(1)(i)(D). 

• Owners or operators of control devices used to comply with the provisions of this 

subpart, except §60.562–1(a)(1)(i)(D), shall monitor these control devices to 

ensure that they are operated and maintained in conformance with their designs. 

• An owner or operator complying with the standards specified under §60.562–1, 

except §60.562–1(a)(1)(i)(D), with control devices other than an incinerator, 

boiler, process heater, flare, absorber, condenser, or carbon adsorber or by any 

other means shall provide to the Administrator information describing the 

operation of the control device and the process parameter(s) which would 

indicate proper operation and maintenance of the device. The Administrator may 

request further information and will specify appropriate monitoring procedures or 

requirements. 

District Rule 4682 requires monitoring requirements and recordkeeping requirements 

that are as stringent as Subpart DDD. Therefore the requirements of District Rule 

4862 are as stringent as Subpart DDD. 

How does District Rule 4682 compare to rules in other air districts?

District staff compared VOC limits, optional control requirements, and work practice 

standards in District Rule 4682 to comparable requirements in rules from the following 

California nonattainment areas: 

• South Coast AQMD Rule 1175, as amended September 7, 2007 

• Bay Area AQMD Regulation 8 Rule 52, as adopted July 7, 1999 

• Sacramento Metro AQMD does not have a specific prohibitory rule for this source 

category. 

• Ventura County APCD does not have a specific prohibitory rule for this source 

category. 
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1. South Coast AQMD Rule 1175 

South Coast AQMD Rule 1175 (Control of Emissions From the Manufacture of 

Polymeric Cellular (Foam) Products) applies to polymeric cellular products 

manufacturing operations including but not limited to expandable polystyrene, 

polystyrene foam extrusion, polyurethane, isocyanurate and phenolic foam operations. 

All steps of the manufacturing operation and the storage of the final product for a 

maximum of 48 hours. District Rule 4682 is application to the same types of operations. 

SCAQMD Rule 1175 defines an approved emission control system as a system that 

captures 90% of the manufacturing and storage emissions, and reduces 95% of the 

emissions captured. District Rule 4682 has the same definition for an approve emission 

control system. 

SCAQMD Rule 1175 requires that manufacturing operations excluding expandable 

polystyrene mold operations discontinue the use of CFCs, VOCs, or methylene chloride 

and to reduce their annual emissions from their 1988 emissions baseline by 100% by 

1994. SCAQMD Rule 1175 also requires that expandable polystyrene molding 

operations demonstrate that the manufacturing emissions and post-manufacturing 

emissions are less than 2.4 lbs/100 lbs of raw material processed. District Rule 4682 

states that starting September 20, 2010, the facility shall show compliance with the rule 

by either demonstrating that the manufacturing emissions and post-manufacturing 

emissions are less than 2.4 lbs/100 lbs of raw material processed, a blowing agent 

other than a VOC or CFC is exclusively used or an approved emission control system is 

installed and operating, District Rule 4682 has equivalent requirements to the 

requirements of SCAQMD Rule 1175 therefore these two rules have equivalent 

emissions requirements. 

In addition, the monitoring and testing requirements of SCAQMD Rule 1175 are 

equivalent to that of District Rule 4682. 

2. Bay Area AQMD Regulation 8 Rule 52

Bay Area AQMD Regulation 8 Rule 52 (Polystyrene, Polypropylene, and Polyethylene 

Foam Product Manufacturing Operations) applies to the manufacturing of foam products 

composed of polystyrene, polyethylene or polypropylene. District Rule 4682 is 

application to the same types of operations. 

BAAQMD Reg 8 Rule 52 states that polystyrene foam product manufacturing operations 

shall not manufacture polystyrene foam products within the District unless, for each 100 

pounds of raw material processed, VOC emissions, which include emissions from the 

product manufacturing operation and residual blowing agent in the finished foam 

product, do not at any time exceed: 

• 2.8 pounds for expandable polystyrene cup molding product manufacturing 

operations; or 
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• 2.7 pounds for expandable polystyrene shape and block molding product 

manufacturing operations; or 

• 2.4 pounds for loose fill product manufacturing operations; or 

• 2.4 pounds for extruded polystyrene foam board and sheet product 

manufacturing operations. 

District Rule 4682 states that starting September 20, 2010, the facility shall show 

compliance with the rule by either demonstrating that the manufacturing emissions and 

post-manufacturing emissions are less than 2.4 lbs/100 lbs of raw material processed. 

Since this is the lowest limit listed by BAAQMD Reg 8 Rule 52, the emission 

requirements of District Rule 4682 is as stringent as the BAAQMD rule. 

BAAQMD Reg 8 Rule 52 states that a person shall not manufacture polyethylene or 

polypropylene foam products within the District unless at least 85% by weight of the 

VOC emissions from the product manufacturing operation are captured and vented to 

an abatement device with a control efficiency of at least 98% by weight at all times. 

District Rule 4682 states that an approved emission control system is a system that 

captures 90% of the manufacturing and storage emissions, and reduces 95% of the 

emissions captured. Therefore, the emission control system requirements of District 

Rule 4682 are equivalent to that of BAAQMD Reg 8 Rule 52. 

BAAQMD Reg 8 Rule 52 requires that the facility maintain the type of resin(s) and 

blowing agent(s) used in product manufacturing operations, the amount of polymerized 

styrene, ethylene, propylene, and blowing agent in each resin formulation used in 

percent by weight as indicated by the specifications of the foam product manufacturer, 

and the manufacturer or supplier of the raw polymeric material. In addition, monthly 

records of the amount of each raw polymeric material processed, the amount of each 

finished foam product manufactured, the amount of each VOC blowing agent used, and 

the hours of operation shall be maintained. Since District Rule 4682 has similar 

monitoring and recordkeeping requirements, it can be considered equivalent to 

BAAQMD Reg 8 Rule 52. 

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4682 

satisfies RACT for polystyrene, polyethylene, and polypropylene manufacturing 

operations. 
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Rule 4684 – Polyester Resin Operations 

Emissions Inventory: 

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 0.02 0.02 0.02 0.02 0.03 0.03 0.03 0.03 

VOC 0.35 0.38 0.40 0.40 0.47 0.49 0.52 0.72 

(Source: District 2007 Ozone Plan) 

District Rule Description: 

This rule includes commercial and industrial polyester resin operations, organic solvent 

cleaning, and the storage and disposal of all solvents and waste solvent materials 

associated with such operations. The polyester resin users typically are making 

composite materials, meaning mixing the resin with glass fiber to make a product. This 

rule also covers manufacturers of boats and yachts as well as those making fiberglass 

shower units. Polyester resin operations that used less than 20 gallons per month are 

exempt from the requirements of this rule. 

This rule requires polyester resin operations to use low-VOC polyester resins with the 

following monomer content: Low VOC resins, except for specialty resins and gel coats, 

contain no more than 35% monomer by weight. Low VOC pigmented gel coats contain 

no more than 45% monomer by weight. Low VOC specialty resins and clear gel coats, 

contain no more than 50% monomer by weight; or use resin containing a vapor 

suppressant, such that the weight loss from the VOC emissions does not exceed 60 

grams per square meter of exposed surface during resin polymerization; or use a 

closed-mold system; or install and operate a VOC emissions control system. 

How does District Rule 4684 compare with federal rules and regulations? 

1. EPA – Control Technique Guidelines (CTG) 

EPA-450/3-83-006 Control of Volatile Organic Compound Emissions from Manufacture 

of High-Density Polyethylene, Polypropylene, and Polystyrene Resins. 

The CTG applies to equipment in process units operated to produce one or more of the 

synthetic organic chemicals listed in Appendix E of the proposed standards of 

performance for SOCMI (46 FR 1136, January 5, 1981), methyl tertiary-butyl ether 

(MTBE), polyethylene, polypropylene, and polystyrene. District Rule 4684 applies to 

commercial and industrial polyester resin operations, organic solvent cleaning, and the 

storage and disposal of all solvents and waste solvent materials associated with such 

operations. Since the CTG applies to the manufacturing of polyethylene, polypropylene, 

and polystyrene, and District Rule 4684 applies to the manufacturing of products made 
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with polyester resin, these two regulations are not regulating the same equipment. 

Therefore, this CTG and District Rule 4684 will not be compared. 

EPA-450/3-83-008 Control of Volatile Organic Compound Emissions from Manufacture 

of High-Density Polyethylene, Polypropylene, and Polystyrene Resins. 

This CTG covers the polymer and resin industry. The polymer and resin industry 

includes operations that convert monomer or chemical intermediate materials obtained 

from the basic petrochemical industry and the synthetic organic chemicals 

manufacturing industry into polymer products. Such products include plastic materials, 

synthetic resins, synthetic rubbers, and organic fibers. This CTG only addresses the 

control of emissions from high-density polyethylene, polypropylene, and polystyrene 

resin operations. District Rule 4684 only addresses emissions from polyester resin 

operations. Therefore these two regulations are not applicable to the same equipment 

and will not be compared. 

EPA-453/R-08-004 Control Technique for Fiberglass Boat Manufacturing Materials 

This CTG provides control recommendations for reducing VOC emissions from 

the use of gel coats, resins, and materials used to clean application equipment in 

fiberglass boat manufacturing operations. 

The CTG lists the available controls options for resin and gel coal as follows: 

• Low monomer VOC resins and gel coats. 

• Vapor suppressed resins and gel coats. 

• Non-atomizing resin applications. 

• Closed Molding. 

• Add on control systems. 

The CTG requires the following in order to meet the recommended open molding resin 

and gel coat limits: (1) achieve the individual monomer VOC content limit through the 

use of low-monomer VOC materials, either by using only low monomer 

VOC materials within a covered operation, or by averaging the monomer VOC contents 

for all materials used within an operation on a weight-adjusted basis; (2) meet the 

numerical monomer VOC emission rate limits, which would enable a facility to average 

emissions among different operations using equations to estimate monomer VOC 

emission rates from each operation based on the material and application method; or 

(3) use add-on controls to achieve a numerical monomer VOC emission rate that is 

determined for each facility based on the mix of application methods and materials used 

at that facility. 

The CTG’s limitations for open molding operations are listed in the table below. These 

are also the same limitations found in 40 CFR 63 Subpart VVVV. 
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Organic HAP Content Requirements 

Operation Type Application Method Organic HAP content (weight 

percent) requirement 

Production Resin Operations Atomized 28 

Production Resin Operations Nonatomized 25 

Pigmented Gel Coat 

Operations Any method 33 

Clear Gel Coat Any method 48 

Tooling Resin Operations Atomized 30 

Tooling Resin Operations Nonatomized 39 

Tooling Gel Coat Operations Any Method 40 

District Rule 4684 contains requirements that would require a polyester resin operation 

to either use resins and gel coats that meet monomer content limits or install an add on 

emission control device. As shown in the table above, the monomer content limits of 

the CTG are more stringent than those of District Rule 4684. The add on emission 

control device requirements are equivalent for both regulations. 

2. EPA – Alternative Control Technology (ACT) 

There is no ACT for this source category. 

3. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS for this source category. 

4. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

Subpart VVVV—National Emission Standards for Hazardous Air Pollutants for Boat 

Manufacturing 

This subpart establishes national emission standards for hazardous air pollutants (HAP) 

for new and existing boat manufacturing facilities with resin and gel coat operations, 

carpet and fabric adhesive operations, or aluminum recreational boat surface coating 

operations. This subpart also establishes requirements to demonstrate initial and 

continuous compliance with the emission standards. The applicability of this subpart is 

equivalent to that of District Rule 4684. 

Subpart VVVV states that you may show compliance with the subpart by using one of 

the following options for the resins and gel coats used in open molding operations at 

your facility: 

(a) Maximum achievable control technology (MACT) model point value 

averaging (emissions averaging) option. (1) Demonstrate that emissions from the 

open molding resin and gel coat operations that you average meet the emission limit 
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in §63.5698 using the procedures described in §63.5710. Compliance with this 

option is based on a 12-month rolling average. 

(2) Those operations and materials not included in the emissions average must 

comply with either paragraph (b) or (c) of this section. 

(b) Compliant materials option. Demonstrate compliance by using resins and gel 

coats that meet the organic HAP content requirements in Table 2 to this subpart. 

Compliance with this option is based on a 12-month rolling average. 

(c) Add-on control option. Use an enclosure and add-on control device, and 

demonstrate that the resulting emissions meet the emission limit in §63.5698. 

Compliance with this option is based on control device performance testing and 

control device monitoring. 

This Subpart’s limitations for open molding operations are listed in the table below. 

Organic HAP Content Requirements 

Operation Type Application Method Organic HAP content (weight 

percent) requirement 

Production Resin Operations Atomized 28 

Production Resin Operations Nonatomized 25 

Pigmented Gel Coat 

Operations Any method 33 

Clear Gel Coat Any method 48 

Tooling Resin Operations Atomized 30 

Tooling Resin Operations Nonatomized 39 

Tooling Gel Coat Operations Any Method 40 

District Rule 4684 contains requirements that would require a polyester resin operation 

to either use resins and gel coats that meet monomer content limits or install an add on 

emission control device. As shown in the table above, the monomer content limits of 

Subpart VVVV are more stringent than those of District Rule 4684. The add on 

emission control device requirements are equivalent for both regulations. 

Subpart VVVV requires that monthly records of the resin and gel coats used be 

maintained. District Rule 4684 requires that these records be maintained on a daily 

basis. District Rule 4684 has more stringent recordkeeping requirements than Subpart 

VVVV. 

How does District Rule 4684 compare to rules in other air districts?

District staff compared VOC limits, optional control requirements, and work practice 

standards in District Rule 4684 to comparable requirements in rules from the following 

California nonattainment areas: 

• South Coast AQMD Rule 1162, as amended July 2005 

• Bay Area AQMD Regulation 8 Rule 50, as adopted November 1996 
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• Sacramento Metro AQMD Rule 465, as amended September 2008 

• Ventura County APCD Rule 74.14, as amended April 2005. 

1. South Coast AQMD Rule 1162 

South Coast AQMD Rule 1162 (Polyester Resin Operations) applies to all polyester 

resin operations that fabricate, rework, repair, or touch-up products for commercial, 

military, or industrial use including, but not limited to, boats, tubs, pools, shower 

enclosures, spas, bathroom fixtures, jigs, tools, molds, building panels, air pollution 

control equipment, sewage treatment equipment, storage tanks, transportation parts, 

automotive, aircraft, and aerospace components, and other industrial and consumer 

products. District Rule 4684 is applicable to the same types of operations, however 

District Rule 4684 also contains an exemption for facilities which use less than 20 

gallons of polyester resin per month. The applicability of these two rules are equivalent. 

South Coast AQMD Rule 1162 and District Rule 4684 have the same application 

method requirements: airless, air assisted airless, high-volume, low-pressure (HVLP) 

spray equipment, or electrostatic spray equipment. The application methods for these 

two rules are equivalent. 

South Coast AQMD Rule 1162 requires that the polyester resin material in an open 

molding system shall not exceed the following monomer percentage by weight as 

applied: clear gel coat for marble resins (40%), clear gel coat for other resins (44%), 

pigmented gel coat white and off white (30%), pigmented gel coat non-white (37%), 

pigmented gel coat primer (28%), specialty gel coat (48%), general purpose marble 

resin (10%), general purpose solid surface resin (17%), general purpose tub/shower 

resin (24%), lamination resin (32%), other general purpose resin (35%). District Rule 

4684 requires that clear gel coats contain no more than 50% monomer by weight, 

pigmented gel coats contain no more than 45% monomer by weight, and general 

purpose resins contain no more than 35% monomer by weight. Since District Rule 

4684 has a higher monomer percentage by weight limit than SCAQMD Rule 1162, the 

resin monomer percentage by weight limits of District Rule 4684 are not as stringent as 

SCAQMD Rule 1162. 

SCAQMD Rule 1162 has a more stringent vapor suppressed resin requirement when 

compared to District Rule 4684. SCAQMD Rule 1162 requires additives to reduce VOC 

evaporation loss to less than 50 g/m2

 of surface area, while District Rule 4684 requires 

additives to reduce VOC evaporation loss to less than 60 g/m2 of surface area 

SCAQMD Rule 1162 has a more stringent control equipment requirement when 

compared to District Rule 4684. SCAQMD Rule 1162 requires an emission control 

system to have an overall capture and control efficiency of 90 percent or more on a 

mass basis, while District Rule 4684 requires an emission control system to have an 

overall capture and control efficiency of 85 percent or more on a mass basis. 
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SCAQMD Rule 1162 and District Rule 4684 have equivalent recordkeeping, monitoring, 

and testing requirements. 

2. Bay Area AQMD Regulation 8 Rule 50 

BAAQMD Regulation 8 Rule 50 (Polyester Resin Operations) applies to all facilities that 

manufacture products using polyester resins. District Rule 4684 is applicable to the 

same types of operations, however District Rule 4684 also contains an exemption for 

facilities which use less than 20 gallons of polyester resin per month. The applicability 

of these two rules are equivalent. 

BAAQMD Regulation 8 Rule 50 requires an operation to use one or more of the 

following emission reducing methods: 1) Use polyester resin material with a monomer 

content of no greater than 35 percent by weight. 2) Use a resin containing vapor 

suppressant, such that weight loss from VOC emissions do not exceed 60 grams per 

square meter of exposed surface area during resin polymerization. 3) Use a closedmold system. District Rule 4684 has equivalent requirements for options 2 and 3, 

however it has a higher limit for the monomer content of polyester resin used. District 

Rule 4684 it is not as stringent as BAAQMD Regulation 8 Rule 50. 

BAAQMD Regulation 8 Rule 50 and District Rule 4684 have the same spray application 

method requirements: airless, air assisted airless, high-volume, low-pressure (HVLP) 

spray equipment, or electrostatic spray equipment. The application methods for these 

two rules are equivalent. 

BAAQMD Regulation 8 Rule 50 and District Rule 4684 both require an emission control 

system to have an overall capture and control efficiency of 85 percent or more on a 

mass basis. 

BAAQMD Regulation 8 Rule 50 limits the cleaning materials used by the polyester resin 

operation to less than 200 g-VOC/L. District Rule 4684 limits the VOC content of clean 

up solvents to 25 g-VOC/L. District Rule 4684 has more stringent surface preparation 

and clean-up solvent requirements than BAAQMD Regulation 8 Rule 50. 

BAAQMD Regulation 8 Rule 50 and District Rule 4684 have equivalent recordkeeping, 

monitoring, and testing requirements. 

3. Sacramento Metro AQMD Rule 465 

Sacramento Metro AQMD Rule 465 (Polyester Resin Operations) applies to all facilities 

that operate polyester resins operations except for facilities that use less than 20 

gallons of resin per month. District Rule 4684 is applicable to the same types of 

operations and has the same exemption. The applicability of these two rules are 

equivalent. 
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The process and control requirements of Sacramento Metro AQMD Rule 465 are almost 

equivalent to the requirements of District Rule 4684. The one difference is that 

Sacramento Metro AQMD Rule 465 requires that the VOC control system provide an 

overall system efficiency of 90% compared to 85% which is required by District Rule 

4684. The control efficiency of District Rule 4684 it is not as stringent as that of 

Sacramento Metro AQMD Rule 465. 

Sacramento Metro AQMD Rule 465 and District Rule 4684 have the same spray 

application method requirements: airless, air assisted airless, high-volume, lowpressure (HVLP) spray equipment, or electrostatic spray equipment. The application 

methods for these two rules are equivalent. 

The cleaning material requirements of Sacramento Metro AQMD Rule 465 states that 

on September 25, 2009, all cleaning materials shall have VOC contents of 0.21 pounds 

of VOC per gallon (25 g/l) as applied, or less. District Rule 4684 currently requires 

cleaning materials to have VOC contents of 0.21 pounds of VOC per gallon (25 g/l) as 

applied, or less. District Rule 4684 has more stringent cleaning material requirements 

than Sacramento Metro AQMD Rule 465. 

Sacramento Metro AQMD Rule 465 requires that monthly records of the resin and 

cleaning materials be maintained for operations with VOC emissions greater than 5 

tons-VOC/year and annual records be maintained for operations with VOC emissions 

with less than 5 ton-VOC/year. District Rule 4684 requires that these records be 

maintained on a daily basis. District Rule 4684 has more stringent recordkeeping 

requirements than Sacramento Metro AQMD Rule 465. 

4. Ventura County APCD Rule 74.14 

Ventura County APCD Rule 74.14 (Polyester Resin Material Operations) applies to all 

facilities that operate polyester resins operations except for facilities that use less than 

20 gallons of resin per month. District Rule 4684 is applicable to the same types of 

operations and has the same exemption. The applicability of these two rules are 

equivalent. 

Ventura County APCD Rule 74.14 requires that the polyester resin material in an open 

molding system shall not exceed the following monomer percentage by weight as 

applied: clear gel coat for marble resins (40%), clear gel coat for other resins (44%), 

pigmented gel coat white and off white (30%), pigmented gel coat non-white (37%), 

pigmented gel coat primer (28%), specialty gel coat (48%), general purpose marble 

resin (10%), general purpose solid surface resin (17%), general purpose tub/shower 

resin (24%), lamination resin (32%), other general purpose resin (35%). District Rule 

4684 requires that clear gel coats contain no more than 50% monomer by weight, 

pigmented gel coats contain no more than 45% monomer by weight, and general 

purpose resins contain no more than 35% monomer by weight. Since District Rule 

4684 has a higher monomer percentage by weight limit than Ventura County APCD 
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Rule 74.14, the resin monomer percentage by weight limits of District Rule 4684 are not 

as stringent as Ventura County APCD Rule 74.14. 

Ventura County APCD Rule 74.14 and District Rule 4684 have the same spray 

application method requirements: airless, air assisted airless, high-volume, lowpressure (HVLP) spray equipment, or electrostatic spray equipment. The application 

methods for these two rules are equivalent. 

The cleaning material requirements of Ventura County APCD Rule 74.14 states that all 

cleaning materials shall be either a Clean Air Solvent or shall not exceed 25 grams 

ROC per liter of material as applied. District Rule 4684 currently requires cleaning 

materials to have VOC contents of 0.21 pounds of VOC per gallon (25 g/l) as applied, or 

less. The cleaning material requirements for these two rules are equivalent. 

Ventura County APCD Rule 74.14 requires that the VOC control system provide an 

overall system efficiency of 90% compared to 85% which is required by District Rule 

4684. The control efficiency of District Rule 4684 it is not as stringent as that of Ventura 

County APCD Rule 74.14. 

Ventura County APCD Rule 74.14 requires that monthly records of the resin and 

cleaning materials be maintained. District Rule 4684 requires that these records be 

maintained on a daily basis. District Rule 4684 has more stringent recordkeeping 

requirements than Ventura County APCD Rule 74.14. 

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that the recently adopted 

CTG has several requirements that are more stringent than those in Rule 4684 for 

polyester resin operations. Although Rule 4684 limits are not as stringent as some of 

those contained within other district’s rules, those rules have been recently amended 

and some of their limits are considered beyond RACT, since those requirements are 

more stringent than the CTG requirements. Since the CTG was recently adopted 

(2008), EPA would have conducted a thorough analysis for determining the reasonably 

available control to apply to the source category. Therefore, although RACT is 

inherently a “moving target”, a recently adopted CTG can be assumed as defining 

RACT. As discussed in Section 4.2 and Table 4-3 below, the rule is on a schedule for 

addressing the differences between its current requirements versus the CTG and the 

other rule requirements. 
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Rule 4691 – Vegetable Oil Processing Operations 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

VOC 0.36 0.37 0.40 0.40 0.44 0.46 0.48 0.48 

(Source: District 2007 Ozone Plan) 

District Rule 4691 Description

This rule controls VOC emissions from facilities that extract oil from vegetable sources 

like cottonseeds and corn. 

How does District Rule 4691 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

There is no CTG for this source category. 

B. EPA – Alternative Control Technology (ACT) 

There is no ACT for this source category. 

C. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS for this source category. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There are no NESHAPs for this source category. 

How does District Rule 4691 compare to rules in other air districts?

District staff compared VOC limits, optional control requirements, and work practice 

standards in District Rule 4691 to comparable requirements in rules from the following 

California nonattainment areas: 

• South Coast AQMD does not have a specific prohibitory rule for this source 

category. 

• Bay Area AQMD Regulation 8 Rule 41, as adopted December 1986. 
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• Sacramento Metro AQMD does not have a specific prohibitory rule for this source 

category. 

• Ventura County APCD does not have a specific prohibitory rule for this source 

category. 

Bay Area AQMD Regulation 8 Rule 41 

Bay Area AQMD Regulation 8 Rule 41 (Vegetable Oil Manufacturing Operations) 

applies to vegetable oil solvent extraction operations. Equipment that is used 

exclusively for research, laboratory analysis or determination of production is exempt 

from the emission control requirements of this rule. 

District Rule 4691 is applicable to all vegetable oil plants. 

Both BAAQMD Regulation 8 Rule 41 and District Rule 4691 have identical requirements 

for the control of emissions from both an extractor, desolventizer-toaster, and a 

desolventizer-toaster conveyor, cooler or tumbler. In addition, both rules have identical 

monitoring and recordkeeping requirements. 

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4691 

satisfies RACT for vegetable oil plants. 
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Rule 4692 – Commercial Charbroiling 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 0 0 0 0 0 0 0 0 

VOC 0.442 0.461 0.484 0.491 0.526 0.547 0.569 0.613 

(Source: District 2007 Ozone Plan) 

District Rule 4692 Description

This source category includes charbroiling equipment located in restaurants, including 

hospitals, educational institutions, military, and government facilities. The rule applies 

to commercial cooking operations utilizing chain-driven (conveyorized) charbroilers that 

grill at least 875 pounds of meat per week. Operators with units that emit less than one 

pound of pollutant per day of criteria pollutant are exempt. 

How does District Rule 4692 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG)

There is no CTG for this source category. 

B. EPA – Alternative Control Technology (ACT) 

There is no ACT for this source category. 

C. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS for this source category. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There is no NESHAP or MACT for this source category. 

How does District Rule 4692 compare to rules in other air districts?

District staff compared VOC limits, optional control requirements, and work practice 

standards in District Rule 4692 to comparable requirements in rules from the following 

California nonattainment areas: 
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• South Coast AQMD Rule 1138, as adopted November 1997 

• Bay Area AQMD Regulation 6 Rule 2, as adopted December 2007 

• Ventura County APCD Rule 74.25, as adopted October 2004 

• Sacramento Metro AQMD has no prohibitory rule for this source category. 

A. South Coast AQMD Rule 1138 

South Coast AQMD Rule 1138 (Commercial Charbroiling) requires that a chain-driven 

charbroiler be operated with either a certified catalytic oxidizer or other control device. 

The alternative control device must be as or more effective than the catalytic oxidizer in 

reducing particulate matter (PM) and VOC emissions. The rule does not specify a 

particular PM or VOC emission rate or a control efficiency for the charbroiler/control 

device combination. The minimum requirement for certification is contained in the test 

protocol. The catalytic oxidizer must reduce emissions of VOC an PM by at least 83%. 

District Rule 4692 essentially mirrors the South Coast AQMD rule by requiring a South 

Coast AQMD certified catalytic oxidizer. 

B. Bay Area AQMD Regulation 6 Rule 2 

Bay Area AQMD Regulation 6 Rule 2 (Commercial Cooking Equipment) was adopted in 

December 2007. The rule applies to both chain-driven charbroilers and to under-fired 

charbroilers. There are exemptions for facilities that buy less than a certain amount of 

meat per week and for facilities that grill less than a certain amount per week. 

For chain-driven charbroilers, there are both PM and VOC emission rate limits. Since 

PM is not an ozone precursor, the allowable PM emission rate is not part of this RACT 

analysis. The VOC emission rate for chain-driven charbroilers represents an 83% 

reduction over Bay Area AQMD’s uncontrolled emission factor for the grilling of beef. 

This mirrors the criteria for South Coast AQMD certification. For under-fired 

charbroilers, there are PM emission rate limits, but no VOC emission rate limits, so the 

rule does not define applicable RACT for under-fired charbroilers. The Bay Area AQMD 

rule is equivalent to District Rule 4692 for chain-driven charbroilers. 

C. Ventura County APCD Rule 74.25 

Ventura County APCD Rule 74.25 applies to conveyorized (chain-driven) charbroilers. 

There is one exemption that applies only to chain-driven charbroilers placed in service 

before October 12, 2005. If these units grill less than 875 pound of meat or less per 

week, they are exempt from the control requirements. Catalytic oxidizers or other 

control device is required for these units. The control device must be certified as 

reducing PM and reactive organic compound emissions by at least 83% when tested 

according to South Coast AQMD’s test protocol. The VOC emission reduction 

requirement represents the minimum emission reduction required for certification under 

the South Coast AQMD test protocol for catalytic oxidizers. District Rule 4692 requires 

South Coast AQMD-certified catalytic oxidizer for chain-driven charbroilers. Since the 
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83% reduction is the minimum reduction for certification, the control requirements in 

District Rule 4692 and Ventura County APCD Rule 74.25 are equivalent. 

Conclusion

There are no federal rules or regulations covering emissions from this source category. 

After careful evaluation of prohibitory rules in other California nonattainment areas, 

District staff concludes that District Rule 4692 satisfies RACT for commercial 

charbroilers. 
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Rule 4693 – Bakery Ovens 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

VOC 0.52 0.54 0.56 0.57 0.61 0.63 0.66 0.66 

(Source: District 2007 Ozone Plan) 

District Rule 4693 Description

This rule includes all bakery ovens at Major Sources that are used for the baking of 

yeast leavened products. 

How does District Rule 4693 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

There is no CTG for this source category. 

B. EPA – Alternative Control Technology (ACT) 

EPA-453/R-92-017 Alternative Control Technology Document for Bakery Oven 

Emissions 

This document outlines the available control techniques for bakery ovens. The 

document lists no specific VOC emission limit, although it does suggest estimated 

percent VOC reduction from uncontrolled levels. In not having a specific VOC limit for 

any of the bakery ovens, the document does not define RACT for bakery ovens. 

C. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS for this source category. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There is no NESHAP for this source category. 
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How does District Rule 4693 compare to rules in other air districts?

District staff compared VOC limits, optional control requirements, and work practice 

standards in District Rule 4693 to comparable requirements in rules from the following 

California nonattainment areas: 

• South Coast AQMD Rule 1153, as amended January 1995 

• Bay Area AQMD Regulation 8 Rule 42, as adopted June 1994 

• Sacramento Metro AQMD Rule 458, as amended September 1996 

• Ventura County APCD does not have a specific prohibitory rule for this source 

category. 

A. South Coast AQMD Rule 1153 

South Coast AQMD Rule 1153 (Commercial Bakery Ovens) only applies to units with a 

burner rating greater than 2.0 MMBtu/hr and VOC emissions greater than 50 lbVOC/day. This rule also requires the facility to reduce the amount of VOC emission 

emitted by: 70% by weight if the oven has a daily average of 50 lbs -100 lbs of VOC 

emitted, 95% by weight if the oven has a daily average greater than 100 lbs of VOC 

emitted, and 95% by weight for new ovens that have a daily average greater than 50 lbs 

of VOC emitted. 

District Rule 4693 is applicable to all bakery ovens at major sources. Based on South 

Coast AQMD Rule 1153, bakeries with VOC emissions less than 50 lb/day (18,250 

lb/year) are exempt from the requirements of the rule. Since facilities in the SJVAPCD 

with emissions of 18,250 lb-VOC/year are not considered major sources; the 

applicability of District Rule 4693 is not as stringent as South Coast AQMD Rule 1153. 

South Coast AQMD Rule 1153 also states that bakeries with VOC emissions between 

50 lb/day (18,250 lb/year) and 100 lb/day (36,500 lb/year) must reduce their emissions 

by 70% by weight. 

However, upon EPA approval of the Districts revised NSR rule (which is expected to be 

adopted by the District’s Board in December 2008), the Major Source threshold for VOC 

emissions will be lowered to 20,000 lb-VOC/year. The lowering of the Major Source 

threshold will make the requirements of District Rule 4693 applicable to previously 

exempt bakeries. The applicable bakeries will be required to collect emissions from the 

bakery ovens vent them to a control device with at least a 95% control efficiency. In 

comparison, South Coast AQMD Rule 1153, states that bakeries with VOC emissions 

between 50 lb/day (18,250 lb/year) and 100 lb/day (36,500 lb/year) must reduce their 

emissions by 70% by weight. Therefore, District Rule 4693 will have more stringent 

VOC emission control requirements that are than South Coast Rule 1153. 

B. Bay Area AQMD Regulation 8 Rule 42 

Bay Area AQMD Regulation 8 Rule 42 (Large Commercial Bread Bakeries) applies to 

bread bakeries with an average daily production of greater than 100,000 lb/bread. 
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Bakeries with daily VOC emissions less than 150 lb/day (54,750 lb/year) are considered 

low emitting ovens and are exempt from the emission control requirements of this rule. 

New and modified bakery ovens that meet the applicability of this rule are required to 

vent all emissions to a control system capable of reducing emissions by 90%. 

District Rule 4693 is applicable to all bakery ovens at major sources. Based on 

BAAQMD Regulation 8 Rule 42, bakeries with VOC emissions less than 150 lb/day 

(54,750 lb/year) are exempt from the requirements of the rule. Since facilities in the 

SJVAPCD with emissions of 54,750 lb-VOC/year are considered major sources, the 

applicability requirements of District Rule 4693 are more stringent than those of 

BAAQMD Regulation 8 Rule 42. District Rule 4693 also states that collected emissions 

from all bakery ovens are required to be vented to a control device with at least a 95% 

control efficiency. District Rule 4354 has VOC emission control requirements that are 

more stringent than BAAQMD Regulation 8 Rule 42. 

C. Sacramento Metro AQMD Rule 458 

Sacramento Metro AQMD Rule 458 (Large Commercial Bread Bakeries) applies to 

bread bakeries which produce equal to or more than 100 lb-VOC/day. All bakery ovens 

that meet the applicability of this rule are required to vent all emissions to a control 

device with a control efficiency of 95% on a mass basis. 

District Rule 4693 is applicable to all bakery ovens at major sources. Based on 

Sacramento Metro AQMD Rule 458, bakeries with VOC emissions less than 36,500 

lb/year are exempt from the requirements of the rule. Since facilities in the SJVAPCD 

with emissions of 36,500 lb-VOC/year are not considered major sources; the 

applicability of District Rule 4693 is not as stringent as Sacramento Metro AQMD Rule 

458. However, upon EPA approval of the Districts revised NSR rule (which is expected 

to be adopted by the District’s Board in December 2008), the Major Source threshold for 

VOC emissions will be lowered to 20,000 lb-VOC/year. This lowering of the Major 

Source threshold will result in the applicability of the District Rule 4693 more stringent 

than Sacramento Metro AQMD Rule 458. District Rule 4693 also states that collected 

emissions from all bakery ovens are required to be vented to a control device with at 

least a 95% control efficiency. Therefore, District Rule 4354 and Sacramento Metro 

AQMD Rule 458 have at least equivalent if not more stringent (when the District’s major 

source threshold is lowered) VOC emission control requirements. 

Conclusion

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4693 

satisfies RACT for bakery ovens. 
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Rule 4694 – Wine Fermentation and Storage Tanks 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

VOC 3.6 3.7 3.8 3.8 3.9 4.0 4.1 4.1 

(Source: District 2007 Ozone Plan) 

District Rule 4694 Description

The purpose of this rule is to reduce emissions of volatile organic compounds (VOC) 

from the fermentation and bulk storage of wine, or achieve equivalent reductions from 

alternative emission sources. 

The rule requires facilities to reduce the VOC emissions from fermentation by 35% of 

their baseline emissions annually. Tanks over 5,000 gallons in volume must be 

equipped with pressure/vacuum relief valves operating within 10% of the maximum 

allowable working pressure of the tank, and the temperature of stored wine must be 

maintained at or below 75 degrees Fahrenheit. 

The rule exempts storage tanks constructed primarily of concrete or wood and wineries 

that emit less than 10 tons of VOC per year. 

How does District Rule 4694 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

There is no CTG for this source category. 

B. EPA – Alternative Control Technology (ACT) 

There is no ACT for this source category. 

C. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS for this source category. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There is no NESHAP or MACT for this source category. 
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Rule 4702 – Internal Combustion Engines – Phase 2 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 31.80 31.58 29.77 29.12 27.72 25.52 23.18 20.69 

VOC 5.29 5.25 5.19 5.17 5.15 5.15 5.17 5.21 

(Source: District 2007 Ozone Plan) 

District Rule 4702 Description

Rule 4702, recently amended on January 18, 2007, limits NOX, CO, and VOC emissions 

from internal combustion engines. The main rule requirement is the limitation of NOX, 

CO, and VOC emissions. These limitations are shown in the tables below. 

Rule 4702 Emission Limits – Spark Ignited Engines 

Engine Type 

NOx Emission 

Limit (ppmv @ 

15% O2, dry) 

CO Emission 

Limit (ppmv @ 

15% O2, dry) 

VOC Emission 

Limit (ppmv @ 

15% O2, dry) 

1. a. Rich Burn, Waste Gas Fueled 50 or 90% 

reduction 2,000 250 

1. b. Rich Burn, Cyclic Loaded, 

Field Gas Fueled 50 2,000 250 

1. c. Rich Burn, All Other Engine 25 or 96% 

reduction 2,000 250 

2. a. Lean Burn 2-Stroke, Gaseous 

Fueled, < 100 hp 

75 or 85% 

reduction 2,000 750 

2. b. Lean Burn, All Other Engines 65 or 90% 

reduction 2,000 750 

3. a. Rich-Burn Engines Used 

Exclusively in Ag Operations, 

Comply by 1/1/2009 of if the 

owner has an agreement to 

electrify comply by 1/1/2010 

90 ppmv or 80% 

reduction 2000 ppmv 250 ppmv 

4. a. Lean-Burn Engines Used 

Exclusively in Ag Operations, 

Comply by 1/1/2009 of if the 

owner has an agreement to 

electrify comply by 1/1/2010 

150 ppmv or 70% 

reduction 2000 ppmv 750 ppmv 

5. a. Certified Spark-Ignited Engine 

Used Exclusively in AO and 

installed on or before June 16, 

2005, Comply by 6/1/2006 

Meet Certified Spark-Ignited Engine Standard of HC + NOX < 

0.6 g/bhp-hr 
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Rule 4702 Emission Limits – Compression Ignited Engines 

Engine Type Emission Limit / Standard Compliance Date 

1. a. Non-Certified CompressionIgnited Engine, Greater than 

50 bhp but not more that 500 

EPA Tier 3 or Tier 4 1/1/2010 

1. b. Non-Certified CompressionIgnited Engine, Greater than 

500 bhp but not more than 750 

bhp and less than 1000 annual 

operating hours 

EPA Tier 3 1/1/2010 

1. c. Non-Certified CompressionIgnited Engine, Greater than 

750 bhp and less than 1000 

annual operating hours 

EPA Tier 4 7/1/2011 

1. d. Non-Certified CompressionIgnited Engine, Greater than 

500 bhp and greater than or 

equal to 1000 annual 

operating hours 

80 ppm NOX, 2,000 ppm CO, 

750 ppm VOC 

1/1/2008 or, if owner 

has an agreement 

to electrify, comply 

by 1/1/2010 

2. a. Certified Compression-Ignited 

Engine, EPA Certified Tier 1 or 

Tier 2 Engine 

EPA Tier 4 

1/1/2015 or 12 

years after 

installation date, 

whichever is later 

2. b. Certified Compression-Ignited 

Engine, EPA Certified Tier 3 or 

Tier 4 Engine 

Meet Certified Compression-Ignited 

Engine Standard in effect at time of 

installation 

At time of 

installation 

On January 10, 2008 EPA took direct final action to approve revisions to the San 

Joaquin Valley Unified Air Pollution Control District portion of the California State 

Implementation Plan. These revisions included approval of District Rule 4702. EPA, in 

evaluating and approving Rule 4702 included the following: 

“We believe these rules are consistent with the relevant policy and guidance 

regarding enforceability, RACT, BACM, and SIP relaxations.” (CFR Volume 72, 

Number 103) 

Since Rule 4702 was recently approved by EPA as meeting RACT requirements, the 

District did not pursue a detailed RACT analysis. 

How does District Rule 4702 compare with federal rules and regulations?

The District did not conduct a detailed analysis of federal rules and regulations for Rule 

4702. 
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How does District Rule 4702 compare to rules in other air districts?

The District did not conduct a detailed comparison to rules in other air districts for Rule 

4702. 

Conclusion

District staff concludes that District Rule 4702 satisfies RACT for internal combustion 

engines. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

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Rule 4703 – Stationary Gas Turbines 

Emissions Inventory: 

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 8.4 4.8 5.0 5.1 5.2 5.3 5.6 5.7

VOC 0.64 0.67 0.68 0.68 0.68 0.71 0.74 0.76

I. District Rule Description: 

Rule 4703, recently amended on September 20, 2007, limits NOX and VOC emissions 

from stationary gas turbines with a ratings equal to or greater than of 0.3 MW or a 

maximum heat input of more than 3.0 MMBtu/hr. The main rule requirement is the 

limitation of NOX emissions. Laboratory units used in research and testing for the 

advancement of gas turbine technology, units limited by permit condition to be operated 

exclusively for firefighting and/or flood control, and emergency standby units limited by 

permit condition to operate less than 100 hours per calendar year for maintenance and 

testing purposes are not subject to the emission requirements of this rule. These 

limitations are shown in the tables below. 

Rule 4703 Emission Limits – Tier 2 

NOX Compliance Limit 

Turbine Classification Rating Compliance (ppmv @ 15% O2) Option 

Gas Fuel Liquid Fuel 

a) Less than 2.0 MW Solar Saturn, 

driving a centrifugal compressor Standard 50 50 

b) No greater than 10 MW, if a DLN 

System is commercially available 

for the specific unit, as of April 30, 

2003. 

Standard 25 65 

c) No greater than 10 MW, if a DLN 

System is not commercially 

available for the specific unit, as of 

April 30, 2003. 

Standard 35 65 

d) Greater than 10 MW, Combined Standard 5 25 

cycle. Enhanced 3 25 

e) Greater than 10 MW, Simple Standard 5 25 

cycle, and permit condition for 

greater than 877 hrs/yr operation. Enhanced 3 25 

Standard 25 42 f) Greater than 10 MW, Simple cycle, 

and permit condition for no greater 

than 877 hrs/yr operation. Enhanced 5 25 
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Rule 4703 Emission Limits – Tier 3 

NOX Compliance Limit 

Turbine Classification Rating (ppmv @ 15% O2) 

Gas Fuel Liquid Fuel 

a) Less than 3 MW. 9 25 

b) 3 MW to 10 MW pipeline gas 

turbine. 

8 during steady 

state and 12 

during non-steady 

state 

25 

c) 3 MW to 10 MW and permit 

condition for less than 877 hrs/yr 

operation and not listed above. 

9 25 

d) 3 MW to 10 MW and permit 

condition for 877 hrs/yr operation 

or greater and not listed above. 

5 25 

e) Greater than 10 MW, Simple 

cycle, and permit condition for 

greater than 200 hrs/yr operation, 

except as provided in Section 

5.1.3.3. 

25 42 

f) Greater than 10 MW, Simple cycle, 

and permit condition for greater 

than 200 hrs/yr operation but no 

greater than 877 hrs/yr operation. 

5 25 

II. How does District Rule 4703 compare to rules in other air districts?

District staff compared VOC limits, optional control requirements, and work practice 

standards in District Rule 4703 to comparable requirements in rules from the following 

California nonattainment areas: 

• South Coast AQMD Rule 1134, as amended August 1997 

• Bay Area AQMD Regulation 9 Rule 9, as amended December 2006 

• Sacramento Metro AQMD Rule 413, as amended March 2005 

• Ventura County APCD Rule 74.23, as amended January 2002 

1. South Coast AQMD Rule 1134 

South Coast AQMD Rule 1134 (Emission of Oxides of Nitrogen From Stationary Gas 

Turbines) applies to all existing stationary gas turbine, 0.3 megawatt MW and larger. 

The NOX emissions limits for different rated turbines are shown in the table below. 
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SCAQMD Rule 1134 Emission Limits 

Type of Unit NOX Limit 

ppmv @ 15% O2

District Rule 4703 NOX Limit 

ppmv @ 15% O2

0.3 to Less Than 2.9 MW 25 9 

2.9 to Less Than 10.0 MW 9 8 during steady state 

12 during non-steady state 

2.9 to Less Than 10.0 MW No SCR 15 9 

10.0 MW and Over 9 25 

10.0 MW and Over No SCR 12 25 

60 MW and Over Combined Cycle No 

SCR 9 5 

60 MW and Over Combined Cycle 9 5 

2.9 to Less Than 10.0 MW Utilizing 

Fuel Containing a Minimum of 60% 

Sewage Digester Gas by Volume on a 

Daily Average 

25 5 

As shown in the table above, the NOX emission limits for District Rule 4703 are 

equivalent the NOX emission requirements for SCAQMD Rule 1134 for most types of 

units. There are more stringent NOX emission limits in District Rule 4703 for the types 

of units that are not as stringent as SCAQMD Rule 1134, however the units they apply 

to have a more descriptive description than the SCAQMD Rule. Therefore, if there were 

two NOX emission limits in District Rule 4703 that could apply to the type of units 

described in SCAQMD Rule 1134, the higher of the two limits was chosen. District Rule 

4703 has comparable NOX emission limits when compared to SCAQMD Rule 1134. 

Therefore the emission limitations of District Rule 4703 are comparable to those of 

SCAQMD Rule 1134. 

Since the emission limits of District Rule 4703 are comparable to SCAQMD Rule 1134, 

District Rule 4703 meets RACT for stationary gas turbines. 

2. Bay Area AQMD Regulation 9 Rule 9 

Bay Area AQMD Regulation 9 Rule 9 (Nitrogen Oxides from Stationary Gas Turbines) 

applies to stationary gas turbines with a heat input greater than 5 MMBtu/hr. Turbines 

used solely for the testing of aircraft engines for flight certification and turbines used 

solely for the firefighting and/or flood control are not subject to the requirements of this 

rule. 
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BAAQMD Reg 9 Rule 9 Emission Limits 

(Effective January 1, 2010) 

NOX Limit ppmv @ 15% O2

Type of Unit Natural 

Gas 

Refinery Fuel Gas, 

Waste Gas or LPG 

District Rule 4703 

NOX Limit 

5 to 50 MMBtu/hr (< 3 MW) 42 50 9 

>50 to 150 MMBtu/hr (No retrofit 

available) (3 to 10 MW) 42 50 

8 during steady state 

12 during non-steady 

state 

>50 to 150 MMBtu/hr (WI/SI 

enhancement available) (3 to 10 MW) 35 50 

8 during steady state 

12 during non-steady 

state 

>50 to 150 MMBtu/hr (DLN technology 

available) (10 to 19 MW) 25 50 5 

>150 to 250 MMBtu/hr (10 to 19 MW) 15 15 5 

>250 to 500 MMBtu/hr (19 to 40 MW) 9 9 5 

>500 MMBtu/hr (40+ MW) 5 9 5 

Until January 1, 2010, a person may operate a stationary gas turbine for up to 877 

hours in any 12-month period (not counting hours of emergency use) without complying 

with the emission limits Section 9-9-301 as long as nitrogen oxides (NOx) emission 

concentrations, do not exceed 42 ppmv @ 15% O2 when firing with natural gas. 

After January 1, 2010, a person may operate a stationary gas turbine rated at 50 

MMBtu/hr or greater for up to 877 hours in any 12-month period (not counting hours of 

emergency use) without complying with the emission limits set forth in Section 9-9-301 

as long as nitrogen oxides (NOx) emissions are less than either of the of the alternative 

limits listed below for the turbine’s heat input rating and the type of fuel burned. 

BAAQMD Reg 9 Rule 9 Emission Limits 

NOX Limit ppmv @ 15% O2

Type of Unit Natural 

Gas 

Refinery Fuel Gas, 

Waste Gas or LPG 

District Rule 

4703 NOX Limit 

>50 to 150 MMBtu/hr (3 to 10 MW) 42 N/A 9 

>150 to 250 MMBtu/hr (10 to 19 MW) 42 N/A 5 

>250 to 500 MMBtu/hr (19 to 40 MW) 25 N/A 5 

>500 MMBtu/hr (40+ MW) 25 N/A 5 

As shown in the tables above, District Rule 4703 has lower emission limits for NOX than 

BAAQMD Reg 9 Rule 9 for all types of units. Therefore the emission limitations of 

District Rule 4703 are as stringent as BAAQMD Reg 9 Rule 9. 

Since the emission limits of District Rule 4703 are as stringent as BAAQMD Reg 9 Rule 

9, District Rule 4703 meets RACT for stationary gas turbines. 
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3. Sacramento Metro AQMD Rule 413 

Sacramento Metro AQMD Rule 413 (Stationary Gas Turbines) applies to all stationary 

gas turbines with ratings equal to or greater than 0.3 megawatt (MW) output, or 3 

MMBTU/hr input and operated on gaseous and/or liquid fuel. The emission 

requirements of this rule shall not apply to the operation of gas turbines used to provide 

emergency electrical power, emergency water pumping for flood control or fire fighting, 

emergency potable water pumping, or emergency sewage pumping. Only the gaseous 

fuel fired limits from this rule will be compared to District Rule 4703. 

Sacramento Metro AQMD Rule 413 Emission Limits 

Time of Operation Type of Unit NOX Limit ppmv 

@ 15% O2

District Rule 4703 NOX Limit 

ppmv @ 15% O2

Any (RACT) ≥ 0.3 MW 42.0 Exempt 

Any (BARCT) ≥ 0.3 to 2.9 MW 42.0 9 

< 877 (BARCT) ≥ 2.9 MW 42.0 9 

≥ 877 (BARCT) ≥ 2.9 to <10 MW 25.0 5 

≥ 877 (BARCT) ≥ 10.0 (no SCR) 15.0 5 

≥ 877 (BARCT) ≥ 10.0 (w/ SCR) 9.0 5 

As shown in the tables above, District Rule 4703 has lower emission limits for NOX than 

Sacramento Metro Rule 413 for all types of units. Therefore the emission limitations of 

District Rule 4703 are as stringent as Sacramento Metro Rule 413. 

Since the emission limits of District Rule 4703 are as stringent as Sacramento Metro 

Rule 413, District Rule 4703 meets RACT for stationary gas turbines. 

4. Ventura County APCD Rule 74.23 

Ventura County APCD Rule 74.23 (Stationary Gas Turbines) applies to stationary gas 

turbines rated at 0.3 MW or greater operated on gaseous or liquid fuel. Turbines used 

for research and testing for the advancement of gas turbine technology, for fire fighting 

or floor control, less than 200 hour per year, and turbines used as emergency standby 

engines limited to maintenance operation less than 104 hours per year are not subject 

to the emission requirements of this rule. Only the gaseous fuel fired limits from this 

rule will be compared to District Rule 4703. 
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VCAPCD Rule 74.23 Emission Limits 

Type of Unit NOX Limit ppmv 

@ 15% O2

District Rule 4703 NOX Limit 

ppmv @ 15% O2

0.3 to < 2.9 MW 42 9 

2.9 to < 10.0 MW 25 x E/25 8 during steady state 

12 during non-steady state 

10.0 MW and up, w/ SCR 9 x E/25 5 

10.0 MW and up, w/o SCR 15 x E/25 5 

4.0 MW and up, less than 877 hours 

per calendar year 42 9 

E = (MRE [Continuous] at LHV) (LHV) ÷ (HHV) 

Where LHV = the lower heating value of the fuel 

 HHV = the higher hearing value of the fuel 

 MRE = manufacturer’s rated thermal efficiency 

According to AP-42, 3.1-1 (4/00), the typical efficiency for a stationary gas turbine is 

38% to 60%. Assuming the highest efficiency of 60%, the NOX emission limits from 

District Rule 4703 are still lower than that of VCAPCD Rule 74.23 for all types of units. 

Therefore the emission limitations of District Rule 4703 are as stringent as VCAPCD 

Rule 74.23. 

Since the emission limits of District Rule 4703 are as stringent as VCAPCD Rule 74.23, 

District Rule 4703 meets RACT for stationary gas turbines. 

III. Conclusion 

After careful evaluation of prohibitory rules in other California nonattainment areas, 

District staff concludes that District Rule 4703 satisfies RACT for stationary gas 

turbines. 
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Rule 4902 – Residential Water Heaters 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 1.37 1.27 1.30 1.31 1.33 1.36 1.39 1.42 

VOC 0.10 0.11 0.11 0.11 0.111 0.11 0.12 0.12 

(Source: District 2007 Ozone Plan) 

District Rule 4902 Description:

Units in this source category are water heaters located in private residences with heat 

input of 75,000 British thermal units per hour (Btu/hr) or less. The following units are 

exempt: water heaters using fuels other than natural gas, natural gas-fired heaters 

used exclusively to heat swimming pools or hot tubs, and water heaters used 

exclusively in recreational vehicles. 

How does District Rule 4902 compare with federal rules and regulations?

A. EPA – Control Technique Guidelines (CTG) 

There is no CTG for this source category. 

B. EPA – Alternative Control Technology (ACT) 

There is no ACT for this source category. 

C. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS for this source category. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There is no NESHAP or MACT for this source category. 

How does District Rule 4902 compare to rules in other air districts?

District staff compared NOx limits and optional control requirements in District Rule 

4902 to comparable requirements in rules from the following California nonattainment 

areas: 
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• South Coast AQMD Rule 1121, as amended September 2004 

• Bay Area AQMD Regulation 9 Rule 6, as amended November 2007 

• Sacramento Metropolitan AQMD Rule 414, as adopted August 1996 

• Ventura County APCD Rule 74.11. as amended December 1986 

A. South Coast AQMD Rule 1121 

South Coast AQMD Rule 1121 (Control of NOx from Residential Type Natural GasFired Water Heaters) applies to manufacturers, distributors, retailers, and installers of 

natural gas-fired water heaters, with heat input rates less than 75,000 Btu per hour. 

Water heaters in recreational vehicles are exempt from control requirements. For water 

heaters not in mobile homes, has two NOx limits for residential water heaters that are 

considered equivalent – one based on heat input to the unit and the other based on 

heat output from the unit. The emission limits are no more than 10 nanograms of NOx 

per joule of heat output (23 pounds per billion Btu (lb/billion Btu) of heat output) or 15 

parts per million by volume at 3% oxygen, dry (17.5 lb/billion Btu of heat input). Water 

heaters in mobile homes have a different NOx limit - no more than 40 nanograms of 

NOx per joule of heat output (93 lb/billion Btu of heat output) or 55 parts per million by 

volume (ppmv) at 3% oxygen, dry (71 lb/billion Btu of heat input). 

These limits were phased in over three years beginning in 2006; meaning that the limits 

have not been fully implemented until this year. From this perspective, the lower limits in 

South Coast AQMD Rule 1121 represent RACT for future rule-making and not for 

current analysis of District Rule 4902. District Rule 4902 is undergoing rule 

development as part of the District’s 8-hour ozone attainment strategy. District staff 

anticipates incorporating the South Coast AQMD limits for this source category. 

Adoption of the rule amendments is expected in the first quarter of 2009. 

B. Bay Area AQMD Regulation 9 Rule 6 

Bay Area Regulation 9 Rule 6 (Nitrogen Oxides Emissions from Boilers and Water 

Heaters) is an umbrella rule that covers boilers and water heaters up to two million Btu 

per hour. The rule applies to all units regardless of whether the units are residential, 

commercial, industrial, or institutional use. Units with heat input of not more than 

75,000 Btu per hour are generally considered residential units, so the portion of the rule 

that applies to units of this size will be used for the analysis. This rule was amended 

recently. The current requirements for residential-type units is certified units with 

emissions of not more than 40 nanograms NOx (calculated as NO2) per joule of heat 

input. Beginning in 2009 and phasing in over the next three years, the NOx limit will be 

10 nanograms NOx per joule of heat input. The new units would need to be certified to 

this lower limit. The 10 nanograms per joule limit mirrors the South Coast rule for this 

source category, however to date, the rule has not been fully implemented. From this 

perspective, the lower limits in the Bay Area AQMD rule represent RACT for future rulemaking and not for current analysis of District Rule 4902. District Rule 4902 is 

undergoing rule development as part of the District’s 8-hour ozone attainment strategy. 
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District staff anticipates incorporating the lower limits for this source category. Adoption 

of the rule amendments is expected in the first quarter of 2009. 

C. Sacramento Metropolitan AQMD Rule 414 

Sacramento Metropolitan AQMD Rule 414 (Natural Gas-Fired Water Heaters) applies to 

any person who manufactures, distributes, offers for sale, sells, or installs any natural 

gas-fired water heater with a rated heat input capacity less than 75,000 Btu/hr. 

Exempted units include water heaters in recreational vehicles, water heaters in 

swimming pools and hot tubs and water heaters that use fuel other than natural gas. 

The rule requires that certified units be used. For water heaters used in mobile homes, 

the rule limits NOx emissions to 50 nanograms of NOx per joule of heat output (116 

lb/billion Btu of heat output). All other subject units are limited to NOx emission of no 

more than 40 nanograms NOx per joule of heat output (93 lb/billion Btu of heat output). 

Both NOx limits are calculated as NO2. The NOx limits in current District Rule 4902 are 

at least as stringent as the Sacramento Metropolitan AQMD Rule 414. 

D. Ventura County APCD Rule 74.11 

Ventura County APCD Rule 74.11 (Natural Gas-fired Residential Water Heaters – 

Control of NOx) applies to any person selling, offering for sale, or installing natural gasfired residential water heaters in Ventura County. The units subject to the rule have a 

rated heat input of less than 75,000 Btu/hour. Water heaters used in recreational 

vehicles and water heaters installed in mobile homes are exempt. The rule requires a 

certified unit that emits no more than 40 nanograms of NOx (calculated as NO2) per 

joule of heat output (93 pounds NOx per billion Btu of heat output). The NOx limits in 

current District Rule 4902 match the requirements of the Ventura County APCD rule. 

Conclusion

There are no federal rules for regulations covering air emissions for this source 

category. After careful evaluation of prohibitory rules in other California nonattainment 

areas, District staff concludes that current District Rule 4902 satisfies RACT for 

residential water heaters. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-375 

Rule 4905 – Natural Gas-Fired, Fan-Type Residential Central Furnaces 

Emissions Inventory:

Tons per day – summer season 

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023 

NOx 4.21 4.12 4.03 4.00 3.93 3.81 3.67 3.5 

VOC 0.21 0.20 0.20 0.20 0.19 0.19 0.18 0.17 

(Source: District 2007 Ozone Plan) 

District Rule 4905 Description

Rule 4905, recently adopted on October 20, 2005, limits NOx emissions from residential 

central furnaces. The main rule requirement is written, as follows: No person shall 

supply, sell, offer for sale, install, or solicit the installation of any natural gas-fired fantype residential central furnace for use within the District unless it has certified 

emissions of oxides of nitrogen less than or equal to 0.093 pounds of oxides of nitrogen 

per million BTU heat output or 55 ppm NOx at 3.00% O2 stack gas by volume (dry). 

Since Rule 4905 was recently approved by EPA, and the source category does not 

include any major sources, the District did not pursue a detailed RACT analysis. 

How does District Rule 4905 compare with federal rules and regulations?

The District did not conduct a detailed analysis of federal rules and regulations for Rule 

4905. 

How does District Rule 4905 compare to rules in other air districts?

The District did not conduct a detailed comparison to rules in other air districts for Rule 

4905. 

Conclusion

District staff concludes that District Rule 4905 is exempt from RACT requirements 

because the Natural Gas-Fired, Fan-type, Residential Central Furnaces source 

category contains no major sources. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

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4-376 

4.2 RULES ON A SCHEDULE TO IMPLEMENT RACT/CTG REQUIREMENTS 

After a careful and wide-ranging examination of individual rules against multiple federal 

rules, regulations, and technology guidelines as well as evaluating District rules against 

comparable rules from California’s most technologically progressive air districts, staff 

has identified a few rules which will require amendments to fully implement RACT or 

CTG requirements. 

4.2.1 Rules Implementing RACT Requirements 

Out of the 55 rules evaluated in this report, only two rules (Rule 4311 - Flares and Rule 

4684 - Polyester Resin Operations) have been identified as potentially needing revision 

to fully address RACT requirements. As outlined in Table 4-3 below, Rule 4311 is 

currently undergoing a rule amendment and will be heard for adoption by the Governing 

Board in June 2009. 

With respect to Rule 4684, as discussed in Chapter 1 of this report, RACT is inherently 

a “moving target” and technology/emission limits considered to meet RACT at the time 

of SIP-approval is generally rendered obsolete by more effective technology that is 

introduced at a later date. The last significant modification made to Rule 4684 was in 

late 200115, whereas the other district rules which were used for comparison were 

modified in 2005 (SCAQMD and VCAPCD) and as recently as September 2008 

(SMAQMD). It should be noted that the BAAQMD Rule which has not been modified 

since 1996, is less stringent than Rule 4684; further enforcing the concept of RACT as a 

moving target. Table 4-3 outlines the rule schedule for addressing the discrepancies 

between Rule 4684 and the other rules. 

4.2.2 Rules Implementing CTG Requirements 

In September 2008, EPA finalized and published four CTGs for air districts to 

implement, since according to Section 182(b)(2)(A), states must revise their SIPs to 

include RACT for each category of volatile organic compounds (VOC) sources covered 

by Control Techniques Guidelines (CTG) documents between November 15, 1990 and 

the date of attainment. EPA guidance requires that rules implement CTG requirements 

within one year of the date the CTGs are finalized. Two District rules (Rule 4603 and 

Rule 4653) need revisions to incorporate the new CTG requirements. Table 4-3 

outlines the rule schedule for addressing the discrepancies between the rules and the 

CTGs. 

 

15 Although Rule 4684 was modified in September 2007, the changes made only addressed the solvent cleaning 

portions of the rule and did not modify any other emission limits within the rule. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

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Table 4-3 Schedule for District Rules Needing Amendment 

Rule # Rule Title Last 

Amended 

Scheduled Adoption 

Date Reason 

4311 Flares 6/15/2006 June 2009 RACT 

4603 Surface Coating of Metal Parts 

and Products 10/16/2008 September 2009 CTG 

4653 Adhesives 9/20/2007 September 2009 CTG 

4684 Polyester Resin Operations 9/20/2007 September 2009 CTG 
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Appendix A 

 

COMMENTS AND RESPONSES 
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San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Appendix A: Comments and Responses 

RACT Demonstration for Ozone SIP 

A-1 

Appendix A:

Comments and Responses

A.1 EPA COMMENTS 

1. COMMENT: SJ 4306 – Boilers, Steam Generators and Process Heaters, > 5 

MMBtu/hr: The October 16, 2008 version of this rule, referred to in the RACT 

analysis, has not been submitted for SIP approval. The District should submit 

the rule. 

RESPONSE: As mentioned above the rule was approved by the District’s 

Governing Board on October 16, 2008 and was subsequently transmitted to ARB 

in December 2008. According to the ARB website, the rule package was 

forwarded to the EPA on March 17, 2009. 

2. COMMENT: SJ 4307 – Boilers, Steam Generators and Process Heaters, 2 – 5 

MMBtu/hr: The October 16, 2008 version of this rule, referred to in the RACT 

analysis, has not been submitted for SIP approval. The District should submit 

the rule.

RESPONSE: See response to Comment #1. 

3. COMMENT: SJ 4311 – Flares: The conclusion on page 4-58 states that the 

District is amending the rule to incorporate flare minimization plans (FMPs) and 

expects to submit the amendments to its Board in the second quarter of 2009. 

Incorporation of an FMP requirement will help demonstrate implementation of 

RACT. 

RESPONSE: Based on EPA comments, Chapter 4 of the report has been 

revised to include new Section 4.2 (Rules On A Schedule to Implement 

RACT/CTG Requirements) and Table 4-3 to identify the rules which need 

amendments to fulfill RACT or CTG requirements and their corresponding 

schedules. As described above Rule 4311 is on a schedule to fulfill RACT 

requirements. 

4. COMMENT: SJ 4352 – Solid Fuel Boilers, Steam Generators and Process 

Heaters: Page 4-68 states that a 40 ppm NOx emission limit is technologically 

infeasible for solid fuel fired units. The District should include or reference 

documentation to support this conclusion. 

RESPONSE: The District has conducted source tests on all biomass units 

applicable to Rule 4352 and none have achieved 40ppm NOx. In addition, 

District staff is unaware of any biomass fired units that are capable of achieving 

40ppm NOx. A feasibility study is currently underway for this source category, 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Appendix A: Comments and Responses 

RACT Demonstration for Ozone SIP 

A-2 

and the District will consider amending Rule 4352 if lower NOx limits are 

determined to be technologically feasible. 

5. COMMENT: SJ 4354 – Glass Melting Furnaces: On page 4-71, the District 

states that the limits in Rule 4354 are more stringent than all other analogous 

limits except flat glass in the BAAQMD rule, and that there are no flat glass 

furnaces in the BAAQMD. The District should document that there are no such 

units in the BAAQMD, at least with reference to communication with BAAQMD 

staff. 

RESPONSE: Revisions to the report to reference communication with BAAQMD 

staff has been included as suggested. 

6. COMMENT: SJ 4402, Crude Oil Production Sumps: EarthJustice has 

commented that this rule has more exemptions than other Districts and that 

SJVAPCD’s 8-hour ozone attainment plan identified the inventory as 3-60 tons 

of VOC per day. SJVAPCD’s current analysis estimates the inventory at 0.4 

tpd VOC and explains why 1st stage tanks are not necessarily better than sumps. 

The analysis further explains that other exemptions are not cost effective or have 

negligible emission differences. We recommend the analysis also clarify how the 

original 3-60 tpd inventory was in error. 

RESPONSE: Revisions to the report to clarify how the original inventory of 60 

tpd was calculated and how the revised inventory of 3 tpd, has been included as 

suggested. 

7. COMMENT: SJ 4570 – Confined Animal Facilities: In light of the nature of the 

industry, the limited regulatory history and the additional information expected in 

the near term, the District’s draft RACT analysis may be appropriate for many 

CAF activities. However, additional analysis seems appropriate for those 

activities with relatively large emissions and potentially smaller variability, such 

as avian CAFs. Specifically, we recommend closer analysis of the avian CAF 

menus provided in the rule to see if specific menu options can be required 

because they are widely available, economically feasible and effective at 

reducing emissions. 

RESPONSE: Based on EPA comments, Chapter 4 of the report has been 

revised to include language on Poultry operations. In addition, a poultry BACT 

analysis has also been attached which outlines the requirements of Rule 4570 

being required as BACT. Since these measures have been considered to be 

BACT for poultry operations, Rule 4570 exceeds the RACT requirements 

8. COMMENT: SJ 4602/4612 – Motor Vehicle and Mobile Equipment Coating 

Operations: We recommend the District include a brief discussion of CARB’s 

Suggested Control Measure for auto-refinishing in the RACT analysis. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Appendix A: Comments and Responses 

RACT Demonstration for Ozone SIP 

A-3 

RESPONSE: Revisions to the report to address CARB’s Suggested Control 

Measure (SCM) has been included as suggested. 

9. COMMENT: SJ 4603 – Surface Coating of Metal Parts and Products: Page 4-

174 notes several areas where the 2008 CTG is more stringent than Rule 4603 

(e.g., VOC limits for baked extreme performance and repair and touch up 

coatings, and work practice standards for miscellaneous metal parts and 

products). Rules meeting the 2008 CTGs are required within one year of the date 

the CTGs are finalized (i.e., September 30, 2009). 

RESPONSE: Revisions to the report further clarifying how Rule 4603 is, overall, 

as stringent as the CTG, has been included. In addition, as described in Table 4-

3 of the report, Rule 4603 is on a schedule to fulfill CTG requirements. 

10. COMMENT: SJ 4605 – Aerospace Assembly and Component Coating 

Operations: The analysis states that EPA approved Rule 4605 on May 30, 2007. 

However, we believe that EPA last approved Rule 4605 on December 20, 2001 

and that more detailed RACT discussion is therefore appropriate. 

RESPONSE: A more detailed RACT analysis for Rule 4605 has been included 

as suggested. 

11. COMMENT: SJ 4606 - Wood Products: Rule 4606 exempts refinishing, 

replacement and custom replica furniture coating operations, while the CTG and 

rules from other Districts do not. More detailed discussion of this exemption in 

the RACT analysis seems appropriate. 

RESPONSE: Revisions to the report further clarifying how the two permitted 

facilities which refinish are exempt from the requirements of the CTG, has been 

included as recommended. In addition, in a follow-up email from EPA, they 

further stated “Sorry about the confusion, but we now realize that the Wood 

Furniture Manufacturing Operations CTG does not apply to refinishing or 

replacement operations.” 

12. COMMENT: SJ 4641 - Cutback, Slow Cure and Emulsified Asphalt Paving and 

Maintenance Operations: Please explain why the exemption for medium cure 

asphalt for ambient temperature less than 50 degrees F is allowed. 

RESPONSE: Revisions to the report to explain why the exemption for medium 

cure asphalt for ambient temperature less than 50 degrees F is allowed, has 

been included as suggested. 

13. COMMENT: SJ 4651 - Soil Decontamination Operations: Please change 

“Municipal Waste Disposal Sites” to “Soil Decontamination Operations” in the 

conclusion. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Appendix A: Comments and Responses 

RACT Demonstration for Ozone SIP 

A-4 

RESPONSE: Revisions to the report has been included as suggested. 

14. COMMENT: SJ 4653 – Adhesives: Page 4-294 states that the District will 

evaluate the September 2008 CTG for inclusion into District rules within one 

year. We note that submittal (not just evaluation) of rules (or negative 

declarations) meeting the 2008 CTGs are due by September 2009. We also note 

SJVAPCD’s determination that Rule 4653 is less stringent than some other 

District adhesive limits and that more detailed evaluation of RACT during the next 

amendment to the rule is appropriate. 

RESPONSE: As described in Table 4-3 of the report, Rule 4603 is on a 

schedule to fulfill CTG requirements and during the next rule amendment 

process will address discrepancies between Rule 4653 and other District’s limits. 

15. COMMENT: SJ 4682 – Polystyrene Foam, Polyethylene, and Polypropylene 

Manufacturing: Additional information would be useful justifying the 93% 

capture/control efficiency option and 30-day averaging. 

RESPONSE: District Rule 4682 requires that the control device shall have a 

capture and control efficiency of 93%. This is greater than the previous emission 

control system requirements of 90% capture and 95% control (85.5% capture 

and control efficiency). The District Rule 4682 evaluation in Chapter 4 of the 

RACT Demonstration for Ozone SIP will be updated with this information. 

Additional information for the monthly averaging period of emissions in District 

Rule 4682 can be found in the Final Staff Report for Revised Proposed 

Amendments to Rule 4682, dated September 20, 2007, and sent to EPA through 

ARB on March 7, 2008. 

16. COMMENT: SJ 4684 – Polyester Resin Operations: Page 4-338 concludes that 

Rule 4684 does not satisfy RACT. We appreciate the District’s analysis, and are 

available to review proposed changes to the rule. 

RESPONSE: As discussed in Chapter 1, RACT is inherently a “moving target” 

and technology/emission limits considered to meet RACT at the time of SIPapproval is generally rendered obsolete by more effective technology that is 

introduced at a later date. The last significant modification made to Rule 4684 

was in late 20011

, whereas the other district rules which were used for 

comparison were modified in 2005 (SCAQMD and VCAPCD) and as recently as 

September 2008 (SMAQMD). It should be noted that the BAAQMD Rule which 

has not been modified since 1996, is less stringent than Rule 4684; further 

enforcing the concept of RACT as a moving target. Although Rule 4684 limits 

are not as stringent as some of those contained within other district’s rules, their 

limits may be considered beyond RACT, especially since their requirements are 

 

1

 Although Rule 4684 was modified in September 2007, the changes made only addressed the solvent cleaning 

portions of the rule and did not modify any other emission limits within the rule. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Appendix A: Comments and Responses 

RACT Demonstration for Ozone SIP 

A-5 

more stringent than the CTG requirements. Since the CTG was recently adopted 

(2008), EPA would have conducted a thorough analysis for determining the 

reasonably available control to apply to the source category. Therefore, although 

RACT is inherently a “moving target”, a recently adopted CTG can be assumed 

as establishing RACT. Table 4-3 outlines the rule schedule for addressing the 

discrepancies between Rule 4684 versus the CTG and the other rules. 

17. COMMENT: SJ 4694 – Wine Fermentation and Storage Tanks: The brief 

discussion starting on page 4-347 provides some support for the District’s finding 

that this rule implements RACT. We note that it does not address the extensive 

cost-effectiveness analysis previously performed by the District or the alternative 

compliance options identified as concerns by EPA on October 24, 2005, and in 

subsequent correspondence. 

RESPONSE: Revisions to the report further clarifying how Rule 4694 is at a 

minimum RACT, if not goes beyond RACT, has been included. 

18. COMMENT: SJ 4702 – IC Engines, Phase 2: The District states that they did not 

pursue a thorough RACT analysis because EPA approved the rule into the SIP 

on May 30, 2007. We believe the correct date is January 10, 2008. 

RESPONSE: Revisions to the report has been included as suggested. 

19. COMMENT: SJ 4703 – Stationary Gas Turbines: Page 4-353 states that a 

detailed RACT analysis is not needed because EPA approved the rule on May 

30, 2007. We believe the last version approved was amended in 2002 approved 

by EPA in 2004, and the RACT analysis should be revised appropriately. 

RESPONSE: Based on this comment from EPA, the District has performed an 

evaluation comparing the NOx emission limit requirements of District Rule 4703 

to rules from select air districts within California nonattainment areas (South 

Coast AQMD, Bay Area AQMD, Sacramento Metro AQMD, and Ventura County 

APCD). Revisions to the District Rule 4703 RACT evaluation in Chapter 4 has 

been included as suggested.. 

A.2 ARB COMMENTS 

No comments were received. 

A.3 PUBLIC COMMENTS 

No comments were received. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Appendix A: Comments and Responses 

RACT Demonstration for Ozone SIP 

A-6 

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Appendix B 

 

Rule 4570 BACT Analysis 
RACT Demonstration for Ozone SIP

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B- 1 

Appendix B:

Rule 4570 BACT Analysis

TOP-DOWN BACT ANALYSIS 

POULTRY BROILER HOUSES 

Facility Name: Foster Farms, El Dorado Ranch Date: September 19, 2005 

P.O. Box 831 

Attn: Environmental Affairs 

Livingston CA, 95334 

Reviewing Engineer: Ramon Norman 

Mailing Address:

Lead Engineer: Martin Keast 

Contact Person: Dave Duke 

Telephone: (209) 394-5343 

Application #: C-5439-1-1 

Project #: C-1051505 

Deemed Complete: September 2, 2005 

I. PROPOSAL: 

The primary business of Foster Farms, El Dorado Ranch is the production of broiler 

chickens to provide meat for human consumption. Foster Farms, El Dorado Ranch has 

requested Authority to Construct (ATC) permits for the addition of 12 new mechanically 

ventilated broiler houses for 397,440 birds (33,120 birds/house) and one diesel-fired 

emergency IC engine at 1324 South El Dorado Ave. in Tranquility, CA. 

Foster Farms, El Dorado Ranch is an agricultural operation that raises fowl for human 

consumption. Pursuant to Senate Bill (SB) 700, all agriculture operations, including 

Confined Animal Facilities (CAF), with emissions greater than 1⁄2 the major source 

emissions threshold levels (12.5 ton/year of NOX or VOC), are required to obtain a District 

permit. The existing 1,280,000 bird broiler operation has emissions exceeding the 12.5 

ton-VOC/year threshold and is classified as a large CAF by the California Air Resources 

Board (ARB). The facility received a District permit for the existing operation on April 28, 

2005. 

Since the broiler operation is subject to permitting requirements and the addition of the new 

mechanically ventilated broiler houses will result in VOC and NH3 emissions exceeding the 

Best Available Control Technology (BACT) threshold of 2.0 lb/day for each house, BACT is 

required for VOC and NH3 emissions from the new houses. 

II. PROCESS DESCRIPTION:

Broilers are produced to meet specific requirements of the customer, which can be a retail 

grocery store, fast-food chain, or an institutional buyer. The process of raising broiler 
B- 2 

chickens in the proposed houses is similar to the practices at modern broiler ranches. The 

production cycle of broilers is divided into two phases: brooding and grow-out. The 

brooding phase begins when freshly hatched chicks from local hatcheries are delivered by 

truck and placed in a heated section of a broiler house known as the brood chamber. The 

brood chamber of the house is maintained above 90 °F for newly hatched chicks. At this 

site, about 33,120 chicks will be released into each house at the beginning of each grow-out 

period. The chicks will be placed on fresh litter in the front half of the house opposite the 

tunnel-ventilation fans for 10 days. During the birds’ first few weeks of growth, the 

temperature is gradually decreased. Once the birds need floor space, the remaining half of 

the house is opened and the chicks are fed out to market weight. After completion of the 

grow-out phase the broilers are transported by truck to a nearby processing plant. 

Typically, all of the houses within a ranch complex will be populated with chicks, and 

depopulated with mature birds within the same few days. 

All broiler chickens in the house are the same age and will be removed from the house at 

the same time. Typically, about 4.5 to 5 percent of the broilers in a house will die (mortality) 

during the grow-out cycle. Mortality must be removed from each house at least daily during 

the grow-out cycle to prevent the spread of disease. The length of the grow-out phase for 

the broiler chickens is approximately 45 days, resulting in an average weight of 4.5 to 5.5 

pounds. Broiler houses will be empty of chickens for approximately 10 days between flocks 

to allow for cleaning and maintenance. This results in a cycle time of about 55 days per 

flock. Typically, six flocks per year are grown in each broiler house. 

Broiler Housing 

Broilers are raised in either totally or partially enclosed housing with a compacted soil floor 

covered with dry bedding. The broiler houses at this site will be constructed with earthen 

floors, wood framing, and corrugated metal roofing and siding. The ceiling and walls will be 

insulated. Each house will be 460 feet long and 54 feet wide. As stated above, about 

33,120 chicks will be released into each house at the beginning of each grow-out period. 

The birds will be able to move about freely in the heated front section of the house. As the 

birds grow and require less heat, the other half of the house is opened to allow them to have 

more space. Water and feed will be provided to the birds throughout the grow-out period. 

Propane heaters and evaporative cooling pads are utilized to control temperature within the 

broiler houses. 

In poultry houses, ventilation is used to remove moisture and ammonia from the houses 

during the winter season and to remove excess heat and ammonia from the houses during 

the summer season. Partially enclosed housing structures have open sidewalls with 

curtains that are opened and closed to control the house ventilation rate. At this site, all of 

the houses will be totally enclosed. In totally enclosed housing, mechanical ventilation is 

used. Mechanical ventilation is typically provided by an induced draft or negative-pressure 

system. An induced draft system pulls fresh air into the house from one end and exhausts 

on the other. A negative-pressure system draws fresh air into the house from side vents 

and out through the exhaust fan. Totally enclosed mechanically ventilated housing is known 

as tunnel-type housing or environmental housing. 
B- 3 

The proposed houses will have an advanced environmental control system that uses 

thermostats, sensors, and timers to more effectively control their exhaust fans. 

Environmental conditions (e.g. temperature, humidity, ventilation, lighting) within the 

proposed houses will be controlled by a computer system. The ranch staff will also monitor 

the conditions within the houses at least twice daily. 

 

Broiler Manure Management 

All broiler chickens are raised unconfined within the houses on dry bedding (litter). Litter 

can be sawdust, wood shavings, rice hulls, chopped straw, peanut hulls, or other products, 

depending on availability and cost. Foster Farms, El Dorado Ranch typically uses rice hulls 

for litter. Manure that is excreted by birds has a high water content. The main function of 

the litter is to absorb the moisture excreted by the birds. 

A typical broiler house with a capacity for 22,000 birds at a time will produce 120 tons of litter 

per year (NCC, 1999). Since the proposed houses are 50% larger, containing 33,120 birds, 

each house would be expected to produce 180.7 tons of litter per year. Two kinds of manure 

are removed from broiler houses: litter and cake. Litter is a mixture of bedding and manure. 

Cake is a compacted and concentrated mixture of manure and litter that usually builds up on 

the surface of the litter around waterers and feeders, where much of the manure is deposited. 

Moisture from manure and waterers binds the mixture of litter and manure together forming 

cake. Broiler houses are partially cleaned between each flock to remove cake. The remaining 

litter may be “top dressed” with an inch or so of new bedding material. 

Typically, the litter (bedding and manure) is only completely cleaned from broiler houses 

every one to three years after at least 6 flocks, with a trend towards performing complete 

clean-outs less than annually. Litter in the proposed houses will be completely cleaned out 

twice a year after only 3 flocks have been raised on the litter. At Foster Farms, El Dorado 

Ranch used litter is completely cleaned out of the brood chamber and moved to the other 

half of the house before chicks are placed. In the proposed houses, chicks will always be 

placed on fresh litter in the brood chamber. After complete clean-outs and brood chamber 

clean-outs, the removed litter is replaced with fresh litter. When the broiler house is 

completely cleaned out, the litter is typically removed with a front-end loader. When the 

house is cleaned, the equipment (including slats) is removed from the house to allow a 

front-end loader to push all of the manure to the center section of the house. Then the 

front-end loader places the mixture of manure and litter into a spreader for land application. 

A thorough cleaning after each flock removes pathogens that could be transferred to the 

next flock. After removal of all organic matter, the house is disinfected. 

Broiler Manure Storage 

After complete cleanout of the litter after each flock, the litter is trucked off site. 

Traditionally, cake from broiler production facilities has been stored in uncovered stockpiles 

until conditions permitted land application. However, water quality concerns have led to the 

increased use of storage structures known as litter sheds for cake storage. Litter sheds 

typically are partially enclosed pole type structures. Water quality concerns also have led to 

the recommendation that cake not stored in litter sheds be placed in well-drained areas and 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

Chapter 4: Rule Analysis 

RACT Demonstration for Ozone SIP 

4-362 

How does District Rule 4694 compare to rules in other air districts?

District staff compared emission limits, optional control requirements, and work practice 

standards in District Rule 4694 to comparable requirements in rules from the following 

California nonattainment areas: 

• South Coast AQMD (no rule for this source category) 

• Bay Area AQMD (no rule for this source category) 

• Ventura County APCD (no rule for this source category) 

• Sacramento Metro AQMD (no rule for this source category) 

Conclusion

During the rule development process of adopting Rule 4694, staff performed extensive 

research to determine what types of controls that could be applied to this source 

category. The staff report for the rule states: 

“The US EPA maintains a database on case-specific information on the "Best Available" air 

pollution technologies that have been required to reduce the emission of air pollutants from 

stationary sources (e.g., power plants, steel mills, chemical plants, etc.). The US EPA 

database contains no examples of controlling wine fermentation emissions. Additional 

literature searches produced no examples of fermentation emission control being implemented 

anywhere in the world. The District is the first district in the nation, perhaps the world, to 

propose controlling VOC emissions from wine fermentation tanks.” 

In addition, District staff work with industry stakeholders to perform an extensive costeffectiveness analysis for the proposed control technologies proposed for the rule. 

Since there are no federal regulations or prohibitory rules in other California 

nonattainment areas, District staff concludes that District Rule 4694 at a minimum 

satisfies RACT, if not goes beyond RACT for Wine Fermentation and Storage Tanks. 
B- 4 

be covered to prevent contaminated runoff and leaching. However, covering of stockpiles of 

cake is rare. 

Emissions from Broiler Litter 

The principal pollutants emitted from broiler houses are Volatile Organic Compounds (VOC) 

and ammonia (NH3). A small amount of particulate matter (PM) is also emitted through the 

ventilation system. Factors that affect emissions from broiler houses include the moisture 

content of the litter; the pH; the ventilation rate; the temperature; and the amount of manure 

and length of the time the manure is present in the broiler house. 

Manure as excreted by the birds has a high water content, most of which evaporates, emitting 

ammonia as the manure dries out. Ideally, litter in the broiler houses should contain no more 

than 20-25% moisture.1 High moisture content in the litter will lead to the development of 

anaerobic conditions and the production of hydrogen sulfide and other reduced sulfur 

compounds. High moisture content in the litter will also lead to greater production of VOCs 

and methane and will facilitate the further conversion of organic nitrogen to ammonia. 

Additionally, the greater the moisture content the more favorable the environment for microbes 

responsible for emissions of ammonia and volatile organic compounds (VOC), which increases 

the likelihood that these compounds will be emitted. Moisture inside the broiler houses is 

controlled by adequate ventilation and regular maintenance of waterers to ensure that there 

are no leaks. 

The ventilation rate affects the amount of ammonia, VOC, and particulate matter carried out 

of the broiler house. During the growth of the flock, continuous airflow removes ammonia 

and other gases and reduces the moisture of content freshly excreted manure. The constant 

volatilization and removal of ammonia from the broiler houses results in lower nitrogen 

content of the litter. 

The potential to emit ammonia and VOCs increases with greater manure storage time and 

greater manure accumulation in the houses. The amount of manure and length of the time 

the manure is present in the broiler house is determined by the number of flocks that are 

raised on the litter before a complete cleanout. Fresh litter will have negligible emissions. 

Litter that has been reused for several flocks may have considerable emissions because of 

the accumulation of manure. As stated above, broiler houses are typically completely 

cleaned out after at least 6 flocks have been raised but the litter in the proposed houses will 

be completely cleaned after only 3 flocks have been raised. 

 

VOC Emissions 

Volatile organic compounds are formed as intermediate metabolites in the degradation of 

organic matter in manure. Under aerobic conditions, any VOC formed are rapidly oxidized 

to carbon dioxide and water. Under anaerobic conditions, complex organic compounds are 

microbially decomposed to volatile organic acids and other volatile organic compounds, 

 

1

 Lesson 11: Using Dietary and Management Strategies to Reduce the Nutrient Excretion of Poultry; Paul Patterson 
B- 5 

which in turn are mostly converted to methane and carbon dioxide by methanogenic 

bacteria. When the activity of the methanogenic bacteria is not inhibited, virtually all of the 

VOC are metabolized to simpler compounds, and the potential for VOC emissions is 

minimized. However, the inhibition of methane formation results in a buildup of VOCs in the 

litter and ultimately to volatilization to the air. VOC emissions will vary with temperature 

because the rate of VOC formation, reduction to methane, and volatilization varies with 

temperature.2

Control of VOC Emissions 

In comparison to the research on ammonia emissions from broiler houses, little research 

has been performed on the methods to reduce VOC emissions from broiler houses. Most of 

the research to this point has focused specifically on odor reduction. However, since VOC 

and ammonia emissions are the result of a similar microbial process, some of the methods 

that have been proven to reduce ammonia emissions are also expected to reduce VOC 

emissions. In addition to thermal incineration and carbon adsorption, other possible 

controls include biofiltration; diet manipulation; the use of acidifying litter amendments such 

as Alum (aluminum sulfate), Poultry Litter Treatment (PLT, sodium bisulfate), Poultry Guard 

(clay material containing sulfuric acid), phosphoric acid, etc.; litter management practices 

and broiler house construction; and the use of certain probiotics. 

A biofilter is a device for removing contaminants from a gas in which the gas is passed through 

a media that supports the microbial activity by which the pollutant is degraded. One type of 

biofilter involves a porous medium (typically soil, compost or wood chips - green waste) that 

contains large populations of microbes. This type of biofilter system can be used to control the 

VOC emissions in the exhaust of the broiler house. 

Nutritional management of broiler feed is routinely practiced to improve meat production and 

bird health. The potential for VOC emissions can be reduced by reducing the quantity of 

undigested nutrients in the litter. The majority of VOCs originate from the decomposition of 

undigested protein from which ammonia is also a byproduct.3

 The level of microbial action in 

the litter corresponds to the level of organic nitrogen content in the litter; the lower the level of 

nitrogen the lower the level of microbial action and the lower the production of ammonia and 

VOC. 

A diet that is formulated to feed proper amounts of protein will result in improved nitrogen 

utilization by the animal and corresponding reduction in uric acid, organic nitrogen content of 

litter, and VOC and ammonia production. Nitrogen excretion can be reduced by replacing 

crude protein in broiler diets with the specific amino acids required. It is possible to reduce 

crude protein levels by 3-4%, which will result in reductions of 13-22% in nitrogen without 

detriment to bird performance.4 Enzymes and feed additives are also commonly used in 

conjunction with certain feeds to increase nutrient digestibility and nitrogen retention.4

 Studies 

on the digestibility of protein and amino acids in broiler chickens fed a corn and soybean diet 

 

2

 Emissions From Animal Feeding Operations – Draft, pg. 2-10 3

 PJ Hobbs et al 

4 Lesson 11: Using Dietary and Management Strategies to Reduce the Nutrient Excretion of Poultry; Paul Patterson 
B- 6 

showed the supplementation of the enzyme phytase resulted in increased weight gain and 

digestibility of most amino acids.5

 The latest National Research Council (NRC) guidelines for 

the selection of an optimal poultry diet should be followed to the maximum extent possible. 

The diet recommendations made in this publication seek to achieve the maximum uptake of 

protein by the bird and the minimum carryover of nitrogen into the litter. 

Acidifying litter amendments such as Alum (aluminum sulfate), Poultry Litter Treatment (PLT, 

sodium bisulfate), Poultry Guard (clay material containing sulfuric acid), phosphoric acid, etc. 

are commonly used in poultry houses to reduce ammonia concentrations in the house during 

the critical first few weeks of bird development. Acidifying litter amendments are available in 

both granular and solution form, depending on the needs of the grower. Preliminary studies 

indicate that these amendments also result in lower VOC emissions. The reduction in VOC 

emissions is likely to be related to the inhibition of the growth of microbes responsible for 

decomposition of nutrients in the litter. It has been demonstrated that sufficient application of 

acidifying litter amendments to floor of a poultry house can reduce the total bacterial count by 

more than 99.99%.6 The application of PLT to litter resulted in significant reductions of total 

bacterial count for 21 days as compared to control.7 At an application rate of 100 lb per 1,000 

ft2

 of broiler house floor space, granulated sulfuric acid and sodium bisulfate reduced bacterial 

pathogen levels. There have been several studies that show that acidifying litter amendments 

such as alum reduce the levels of bacterial pathogens, such as Salmonella and 

Campylobacter in the litter and on bird carcasses.8 Since bacteria are responsible for VOC 

and ammonia production, this inhibition of microbial action translates into a reduction in VOC 

and ammonia emissions. More information about acidifying litter amendments is given under 

ammonia control options. 

Broiler house construction and management practices are another method to reduce VOC 

emissions. The proposed houses are completely enclosed environmentally controlled houses 

in which the relative humidity is monitored to ensure that excessive moisture does not contact 

the litter. There is some research indicating that mechanically ventilated houses have less 

ammonia emissions than naturally ventilated houses.9 Since there is correlation between VOC 

and ammonia emissions in poultry houses10, there may also be VOC reductions from 

mechanically ventilated houses in comparison to naturally ventilated houses. The computer 

controlled ventilation fans are more effective at reducing moisture inside the houses than 

natural (curtain) ventilation. The use of evaporative cooling pads as opposed to misting 

systems also reduces the chances that excessive moisture will contact the litter. House 

insulation and the use of mixing fans inside the house will help create greater uniformity in the 

temperature and relative humidity in the houses. This will minimize condensation inside the 

house caused when warmer air contacts cooler surfaces. Total cleanout of the houses twice 

per year will reduce the amount of organic material in the litter and the amount of time that this 

material is present, thereby decreasing the potential to emit VOCs and ammonia.

 

5 Sebastian et al. 

6

 “Litter Amendments as a Tool for Optimizing Poultry House Clean Out”, Avian Advice, Summer 2003, Vol.5, No. 2 7

 Dr. Richard Chin, California Veterinary Diagnostic Laboratory, Fresno - Final Bacteriological Results July 31, 1995 8

 Dr. Philip Moore, Jr., USDA/ARS, Fayetteville, Arkansas 

9

 Ammonia Monitoring in Northern Ireland – comparison of ammonia concentrations downward of two types of broiler houses in 

Northern Ireland (March 2005), SNIFFER 10 PJ Hobbs et al 
B- 7 

Probiotics are microorganisms with beneficial characteristics. These microorganisms are 

usually the viable microbial cultures or their fermentation products. Most probiotics work 

through competitive exclusion, meaning that they cause a shift in the bacterial population from 

less desirable species to more desirable species. Probiotics have many of the advantages of 

antibiotics without the drawback of possibly creating antibiotic resistant pathogens. Bacterial 

enzymes in probiotics also promote the digestion of protein, lipids, and carbohydrates11, which 

will cause less of these nutrients to be excreted. Probiotics are used extensively in the poultry 

industry to promote animal health. The introduction of certain probiotics to poultry feed and 

litter has potential to reduce VOC and ammonia emissions. Recently, they have been used in 

Taiwan's animal farming industry to address concerns about the environmental impact of the 

animal farming. In one experiment, the introduction of Ecozyme©, a lactobacilli containing 

probiotic, to broiler feed reduced the pH and moisture content of the litter and resulted in 

greater than 90% reductions in malodorous VOC compounds.12 The results of the study were 

confirmed by the Malaysian Animal Research Institute. The use of probiotics to control 

emissions is a developing area and more research is needed to quantify all potential 

reductions. Non-pathogenic bacteria can also be introduced into the litter in order to speed the 

oxidation of ammonia to nitrate and nitrite.13

Ammonia Emissions 

Ammonia in the presence of sulfur dioxide and nitrogen oxides is a precursor for the 

secondary formation of PM2.5 in the atmosphere. Ammonia reacts with sulfuric and nitric 

acids, which are produced from sulfur dioxide and nitrogen oxides in the ambient air, to form 

ammonium sulfate, ammonium nitrate, and other fine particulates.14 Exposure to high levels 

of ammonia can cause irritation to the skin, throat, lungs, and eyes. 

Ammonia volatilization is the result of the microbial decomposition of nitrogenous 

compounds in poultry litter. The primary nitrogenous compound in poultry litter is uric acid, 

but nitrogenous compounds also occur in the form of undigested organic nitrogen in poultry 

feces. Whenever uric acid comes in contact with the enzyme urease, which is excreted in 

animal feces, the uric acid will hydrolyze rapidly to form ammonia and this ammonia will be 

emitted soon after. The formation of ammonia will continue more slowly (over a period of 

months or years) with the microbial breakdown of organic nitrogen in the litter. The rate of 

ammonia volatilization is influenced by a number of factors including the concentrations of 

nitrogenous compounds in the litter, temperature, air velocity, surface area, and moisture. 

Several researchers have attempted to quantify ammonia emissions from broiler houses. 

However, there is great variability in the estimates to quantify ammonia emissions from 

broiler houses. Wheeler (2003) reported that overall ammonia emissions for birds from 1 to 

23 days old housed in eleven broiler houses in Kentucky and Pennsylvania during the 

winter months varied from 0.2 – 0.92 g day-1 bird-1 on used litter and 0.0 – 0.92 g day-1 bird-1

 

11 Larbier and Leclercq, 1994 

12 M. H. Chang and T. C. Chen, International Journal of Poultry Science 2 (5): 313-317, 2003 13 “Litter Treatment”, Martine Boulianne, University of Montreal 14 Workshop Review Draft for EPA Regional Priority AFO Science Question Synthesis Document - Air Emission Characterization and 

Management, pg. 2 
B- 8 

on fresh litter. Gates et al. (2004) reported that overall ammonia emissions from twelve 

broiler houses in Kentucky and Pennsylvania during the winter months varied from 0.0 – 1.5 

g day-1 bird-1. Lacey et al. (2003) reported ammonia emissions ranging from 0.05 – 1.90 g 

day-1 bird-1 for broilers raised in central Texas over a 49 day grow-out period. Groot 

Koerkamp et al. (1998) reported ammonia emissions ranging from 8.9 mg hr-1 bird-1 (0.21 g 

day-1 bird-1; 0.17 lb year-1 bird-1) to 19.8 mg hr-1 bird-1 (0.48 g day-1 bird-1; 0.38 lb year-1 bird1

). An average ammonia emission factor of 0.22 lb year-1 bird-1 (0.28 g day-1 bird-1) was 

reported in the EPA Regional Priority AFO Science Question Synthesis Document - Air 

Emission Characterization and Management (Table 2-6, Poultry Emission Factors). A recent 

California Air Resources Board study at a Foster Farms broiler house resulted in an ammonia 

emission factor of 0.0958 lb year-1 bird-1 (approximately 0.121 g day-1 bird-1). Variations in 

temperature, humidity, litter management, feed formulation, stocking density, and 

measurement methodology may all contribute to the wide variation in ammonia emission 

estimates from broiler houses. 

Control of Ammonia Emissions 

Many of the VOC control strategies mentioned above are also effective in controlling 

ammonia emissions. Of these strategies much research has confirmed the ability of 

acidifying litter amendments such as Alum (aluminum sulfate), Poultry Litter Treatment 

(PLT, sodium bisulfate), Poultry Guard (clay material containing sulfuric acid), phosphoric 

acid, etc. to reduce ammonia volatilization. 

Ammonia emissions are greatly influenced by litter pH. Once formed, the ammonia will be in 

one of two forms: as the uncharged form of ammonia (NH3) or the ammonium ion (NH4+), 

which is nonvolatile. Ammonia is also less soluble in water than the ammonium ion. Under 

acidic conditions (pH values of less than 7.0) ammonium is the predominate species, and 

ammonia volatilization occurs at a lower rate than at higher pH values. However, some 

ammonia volatilization occurs even under moderately acidic conditions. Volatilization of 

ammonia increases with increasing pH. Uric acid decomposition occurs most rapidly under 

alkaline (pH>7) conditions. Uricase, the enzyme that catalyzes uric acid breakdown, has 

maximum activity at a pH of 9. One principal ureolytic bacterium, Bacillus pasteurii, cannot 

grow at neutral pH, but thrives in litter above pH 8.5.15 The litter pH in a broiler house can 

range between 8.5 and 10.0, which results in fairly rapid ammonia volatilization. 

 

15 Alabama Cooperative Extension, ANR-1199 April 2001 
B- 9 

All acidifying litter amendments work in a similar manner. The free hydrogen ions (H+) that 

exist under acidic conditions react with ammonia to form nonvolatile ammonium ions. The 

ammonium then reacts with sulfate ions to form ammonium sulfate ((NH4)2SO4), a watersoluble fertilizer. Because of these reactions, the amount of ammonia emitted from the litter 

will be reduced and the nitrogen (N) content of the litter will increase, which may make it 

more valuable as a fertilizer. 

Acidifying litter amendments are generally most effective the first three weeks after 

application. Since poultry manure is alkali, the continual addition of more manure to the 

litter will counteract the acidifying affect of the amendments, eventually raising the pH above 

neutral. Although these products are typically only applied at the beginning of the grow-out 

cycle, it is possible to reapply some acidifying litter amendments such as PLT (a non-toxic 

product) to reduce pH and provide further ammonia control after the birds have been 

placed. Dry alum activates more quickly if sufficient moisture is present (>18%). Because of 

this more growers are currently using liquid alum (which doesn't need moisture to activate) 

than dry alum.16

Research has shown that alum can be used to reduce ammonia emissions by 70%.16 A flux 

chamber study by Moore, USDA (1997b) demonstrated the use of alum reduced ammonia 

emissions by 97% during the 1st four weeks of grow-out and 75% during for the full 6 weeks. 

These results were confirmed by Brewer in 1998 (1999 Poultry Science Journal 78:692-

698). McWard and Taylor found that all acidifying litter treatments worked to reduce 

ammonia emissions for up to four weeks and found little difference in the effectiveness of 

the treatments that they tested (alum, sodium bisulfate, and acidified clay) (2001 Journal of 

Applied Poultry Research Vol. 9, No. 4). A study by Moore, Daniel, Edwards, and Miller on 

the “Effect of Chemical Amendments on Ammonia Volatilization from Poultry Litter” showed 

that alum reduced ammonia volatilization by up to 99% vs. untreated litter (American 

 

16 Dr. Philip Moore, Jr., USDA/ARS, Fayetteville, Arkansas 
B- 10 

Society of Agronomy, Mar/Apr 1995 v. 24(2) pg. 293-300). Terzich (1998) reported that 

sodium bisulfate significantly reduced litter pH and ammonia emissions. 

Operating Schedule:

The typical operating schedule for the facility is 24 hours per day, 7 days per week, and 12 

months per year. 

III. EQUIPMENT LISTING: 

12 new mechanically ventilated broiler houses for 397,440 birds (33,120 birds/house) (177 

total combined hp) 

Each House

One 460' L X 54' W mechanically ventilated broiler house with capacity for 33,120 birds

Ten 52” tunnel ventilation exhaust fans (1 hp each) 

One 48” exhaust fan (1 hp) 

One 36” exhaust fan (3⁄4 hp) 

Six 24” circulating fans (1⁄2 hp each) 

14.75 total electric hp 

Proposed Modification: 

C-5439-1-1: MODIFICATION OF 1,280,000 BROILER HEN RANCH, CONSISTING 48 

NATURALLY/MECHANICALLY VENTILATED BROILER HOUSES, 

INCLUDING ELECTRIC FANS TOTALING 480 HP: ADD 397,440 BROILERS 

AND 12 MECHANICALLY VENTILATED BROILER HOUSES 

Post Project Equipment Description: 

C-5439-1-1: 1,677,4400 BROILER HEN RANCH, CONSISTING 60 

NATURALLY/MECHANICALLY VENTILATED BROILER HOUSES, 

INCLUDING ELECTRIC FANS TOTALING 657 HP 

VI. EMISSION CONTROL TECHNOLOGY EVALUATION 

A. BACT Applicability

Pursuant to District Rule 2201, Sections 4.1.1 and 4.1.2, BACT shall be applied to a new, 

relocated, or modified emissions unit if the new or relocated unit has a Potential to Emit 

(PE) exceeding two pounds in any one day or the modified emissions unit results in an 

Adjusted Increase in Permitted Emissions (AIPE) exceeding 2 lb/day for NOX, SOX, PM10, 

CO, VOC, or NH3. For CO emissions, the CO Post-project Stationary Source Potential to 

Emit (SSPE2) must also exceed 200,000 lb/year to trigger BACT. 
B- 11 

As shown in section VII.C.1 of the engineering evaluation and the table below, each of the 

proposed new broiler houses will result in a PE of 2.3 lb/day for VOC and 8.7 lb/day for NH3. 

Therefore, BACT is triggered for VOC and NH3 emissions. 

Post Project Potential to Emit (PE2) (lb/day) 

NOX SOX PM10 CO VOC NH3

New Broiler House for 

33,120 birds 0 0 1.8 0 2.3 8.7 

BACT triggered? No No No No Yes Yes 

B. BACT Policy

 

Per District Policy BACT APR 1305-1, Section IX, “A top-down BACT analysis shall be 

performed as a part of the Application Review for each application subject to the BACT 

requirements pursuant to the District’s NSR Rule.” For source categories or classes 

covered in the BACT Clearinghouse, relevant information under each of the steps may be 

simply cited from the Clearinghouse without further analysis. 

C. Achieved in Practice Determination 

The U.S. Environmental Protection Agency (USEPA) RACT/BACT/LAER Clearinghouse, 

the California Air Pollution Control Officers Association (CAPCOA) BACT Clearinghouse, 

the San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) BACT 

Clearinghouse, the Bay Area Air Quality Management District (BAAQMD), and the South 

Coast Air Quality Management District (SCAQMD) BACT Guidelines were reviewed to 

determine potential control technologies for this class and category of operation. No BACT 

guidelines were found for this class and category of source. No prohibitory rules specifically 

regulating this category of source were identified for any California air district. 

D. Best Available Control Technology (BACT) Analysis for Permit Unit C-5439-1-1 

 BACT Analysis for VOC Emissions: 

 Step 1 - Identify All Possible Control Technologies

 The control technology options include: 

 Option 1. Emissions from Broiler House controlled by Carbon Adsorption 

 Option 2. Emissions from Broiler House controlled by Thermal Incineration 

Option 3. Emissions from Broiler House controlled by Catalytic Incineration 

Option 4. Emissions from Broiler House controlled by a Biofilter capable of achieving 

80% control 

Option 5. Total house cleanout after two flocks (3 times per year) 

Option 6. Total house cleanout after one flock (6 times per year) 

Option 7. Animals fed in accordance with National Research Counsel (NRC) or 

other District accepted guidelines utilizing routine nutritional analysis for 

rations 
B- 12 

 Option 8. Broiler House Construction and Management Practices 

1. Insulated & mechanically ventilated poultry house + 

2. Mortality removed twice per day + 

3. Evaporative cooling pads to regulate house temperature + 

4. Mixing Fans 

Option 9. Usage of probiotics 

 

 Step 2 – Eliminate Options

Option 5 (Total house cleanout after two flocks (3 times per year)) and Option 6 (Total 

cleanout after one flock) will be eliminated from consideration at this time. Although 

more frequent removal of litter from the broiler houses would result in less emissions 

from the house, it is likely that these emissions would merely be shifted to litter storage 

areas. Unless the litter storage areas were controlled, there would be no emission 

reductions. Additionally, as a particulate matter control, the facility’s Conservation 

Management Practice (CMP) plan requires that the litter be used for at least two flocks. 

More frequent cleanouts would cause a greater amount of direct PM10 emissions to the 

atmosphere. 

Option 9 (use of probiotics) will be eliminated from consideration at this time. Although 

this method shows some promise, more research is needed to verify the emission 

reductions. Probiotics are living organisms and their ability to inhibit emissions is likely 

to be affected by many variables. These variables have not yet been identified to an 

extant that would insure that emissions would be decreased in cases in which probiotics 

are used. 

Step 3 – Rank Remaining Control Technologies by Control Effectiveness

Control technologies for VOC: 

VOC Emission Control Technology Rankings 

Rank Control 

Efficiency Status 

1) Thermal Incineration 98% 17 Technologically Feasible 

2) Catalytic Incineration 95% 18 Technologically Feasible 

3) Carbon Adsorption 95% 19 Technologically Feasible 

4) Biofiltration 80% 20 Technologically Feasible 

 

17 OAQPS Control Cost Manual, 4th Edition, EPA 450/3-90-006, January 1990, page 3-8. 18 EPA-456/R-95-003, Survey of Control Technologies for Low Concentration Organic Vapor Gas Streams, Control Technology Center, 

May 1995, section 2.1, Catalytic Incineration, pages 13-16. The 95% value used is based upon EPA permit No. 23GS-93-OT-1 for 

3M Company in St. Paul for an ARI, Econ-Abator catalytic oxidizer, Emission Point No. 2. 19 EPA-456/R-95-003, Survey of Control Technologies for Low Concentration Organic Vapor Gas Streams, Control Technology Center, 

May 1995, Section 3, Adsorption, pages 45 - 46. 20 According to the SCAQMD Rule 1133.2 final staff report (page 18) “Technology Assessment Report states a well designed, well 

operated, and well-maintained biofilter is capable of achieving 80% destruction efficiency for VOC and NH3.” 
B- 13 

VOC Emission Control Technology Rankings 

Rank Control 

Efficiency Status 

5) Broiler House Construction and Foster 

Farms Management Practices 15%21 Achieved in Practice 

6) Acidifying Litter Amendments 15%22 Technologically Feasible 

7) Animals fed in accordance with National 

Research Counsel (NRC) or other District 

accepted guidelines utilizing routine nutritional 

analysis for rations 

9%23 Achieved in Practice 

Step 4 - Cost Effectiveness Analysis

Thermal & Catalytic Incineration:

The following cost analysis demonstrates that the cost of natural gas alone, not 

including any capital costs, causes catalytic incineration to exceed the District VOC cost 

effective threshold. The temperature required for catalytic incineration is 600 °F. The 

temperature required for thermal incineration is 1,400 °F. Since the fuel requirements 

and fuel cost for thermal incineration are greater than catalytic incineration, the following 

analysis also demonstrates that thermal incineration would not be cost effective. 

Broiler House Air Flow Rate

In order to effectively calculate the costs of this control option, the broiler house airflow 

rate must be determined. According to the applicant, the broiler house airflow rate can 

range from 2,700 cfm (new chicks on a cold night) to 212,000 cfm (mature birds on a 

hot day). Typical flow rates are 70,000 cfm in the spring and fall, 100,000 cfm in the 

summer, and 40,000 cfm in the winter. For more conservative calculations, an average 

airflow rate of 40,000 cfm will be assumed for the broiler houses. 

Fuel Requirement:

The gas leaving the broiler house is principally air, with a volumetric specific heat of 

0.0194 Btu/scf - °F under standard conditions. 

Natural Gas Requirement = (flow)(CpAir)(ΔT)(1-HEF) 

 Where: 

 

21 Estimate based on the ability of the computer-controlled, enclosed, mechanically ventilated broiler house to maintain lower litter 

moisture, which inhibits microbial action leading to VOC emissions. 

22 Conservative estimate based on the ability of lower pH to inhibit microbial action leading to VOC emissions 23 Assuming that undigested protein in bird excrement, which emits VOCs during decomposition, can be reduced 15% by feeding with 

NRC guidelines and that 60% of VOC emissions are from decomposition of excrement in the litter (CARB emissions report states that 

propane and vinyl acetate emissions, which compose 28.9% of total VOC emissions, are likely from propane heaters, feed and 

supplements, and off-gassing from house materials. Some emissions are also from fermentation of the feed.) 
B- 14 

Flow (Q) = exhaust flow rate of VOC broiler house exhaust: 40,000 ft3/hr 

CpAir = specific heat of air: 0.0194 Btu/scf - °F 

ΔT = increase in the temperature of the contaminated air stream required 

for catalytic oxidation to occur (It will be assumed that the air stream would 

increase in temperature from 100 °F to 600 °F.) 

HEF = heat exchanger factor: 0.7 

 

Natural Gas Requirement = (40,000 scf/hr)(0.0194 Btu/scf - °F)(600 °F - 100 °F) 

 (1-0.7) 

= 116,400 Btu/hr 

Fuel Cost for Incinerator:

The cost for natural gas shall be based upon on an average taken from February 2005 

to August 2005 from the Oil Energy website: http://www.oilnergy.com/1gnymex.htm#year

Cost for gas = $7.34/MMBtu 

The oxidizer is assumed to operate 24 hours per day and 300 days per year. 

The fuel costs to operate the incinerator are calculated as follows: 

116,400 Btu/hr x 1 MMBtu/106

 Btu x 24 hr/day x 300 day/year x $7.34/MMBtu = 

= $6,152/house-year 

VOC Emission Reductions

The California Air Resources Board (CARB) has performed a source test on the Foster 

Farms Broiler operation that resulted in a VOC emission factor of 0.0248 lb-VOC/birdyear. Foster Farms is constructing enclosed computer-controlled broiler houses. Both 

humidity and water usage are monitored in the houses. Since the moisture control 

exceeds the industry standard, the emission factor is considered 15% lower than 

industry standard and must be increased to industry standard for cost analysis 

purposes. 

VOC emissions = (0.0248 lb-VOC/bird-year) (1/0.85) (33,120 bird/house) 

 = 947 lb-VOC/house-year 

 Cost of VOC Emission Reductions

 Cost of reductions = ($6,152/year-house)/((947 lb-VOC/year)(1 ton/2000 lb)) 

 = $12,993/ton of VOC reduced 

As shown above, the natural gas cost alone for thermal or catalytic incineration would 

cause the cost of the VOC reductions to be greater than the $5,000/ton cost 
B- 15 

effectiveness threshold of the District BACT policy. The equipment is therefore not cost 

effective and is being removed from consideration at this time. 

Carbon Adsorption:

Carbon adsorption occurs when air that contains contaminants is blown through a 

carbon unit and the pollutants are adsorbed onto the surface in the variously sized 

pours in the activated carbon unit. 

Two main areas of cost are the cost of the device itself, and the operating cost of the 

carbon adsorption system. 

The following cost analysis demonstrates that the cost of activated carbon alone, not 

including any other costs, causes carbon adsorption to exceed the District cost effective 

threshold. Treated activated carbon can control both VOC and ammonia emissions. 

Although, this technology can control both pollutants, a cost effective threshold has not 

been established for ammonia. Therefore, only achieved-in-practice options will be 

considered for ammonia at this time and a multi-pollutant cost effective analysis for 

VOC and ammonia will not be performed. 

VOC Emission Reductions

VOCs controlled = 0.0248 lb-VOC/bird-year x 33,120 bird/house x 0.95 

 = 780.3 lb-VOC/house-year 

Adjusted to industry standard = 780.3 lb-VOC/house-year x (1/0.85) 

= 918 lb-VOC/house-year 

Amount of Activated Carbon Required for VOC Control

Carbon can adsorb 20% of it's weight in VOCs.24 

Carbon required = (918 lb-VOC/year) x 1 lb-Carbon/0.2 lb-VOC 

 = 4,590 lb-carbon/year 

Cost for Activated Carbon for VOC Control:

Assuming a price for carbon of $1.00/lb* 

*Note: from GEAR 12 - Motor Vehicle and Mobile Equipment Coating Operations: Actual cost estimate 

was $2.00/lb. An amount of $1.00/lb was assumed to be conservative. 

Carbon cost = 4,590 lb-carbon/yr x $1.00/lb = $4,590/house-year

 Cost of VOC Emission Reductions

 

24 District GEAR 9 - Soil Remediation Project Utilizing an Activated Carbon System 
B- 16 

 Cost of reductions = ($4,590/house-year)/((918 lb-VOC/yr)(1 ton/2000 lb)) 

 = $10,000/ton of VOC reduced 

As shown above, the cost of the activated carbon alone for carbon adsorption would 

cause the cost of the VOC reductions to be greater than the $5,000/ton cost 

effectiveness threshold of the District BACT policy. Therefore, this option is not cost 

effective and is being removed from consideration at this time. 

Biofiltration:

Biofiltration is a method of reducing pollutants in which exhaust air that contains 

contaminants is blown through a media (e.g., soil, compost, wood chips) that supports a 

microbial population. The microbes utilize the pollutants such as VOCs and ammonia 

as nutrients and oxidize the compounds as they pass through the filter. 

The following cost analysis demonstrates that the cost of biofiltration exceeds the 

District cost effective threshold. Biofiltration can control both VOC and ammonia 

emissions. Although, this technology can control both pollutants, a cost effective 

threshold has not been established for ammonia. Therefore, only achieved-in-practice 

options will be considered for ammonia at this time and a multi-pollutant cost effective 

analysis for VOC and ammonia will not be performed. 

Costs

The cost estimate for a biofiltration system is taken from the University of Minnesota 

Extension Service Biosystems and Agricultural Engineering Update “Biofilter Design 

Information” (March 2004). The cost is largely dependent on the airflow rate that the 

filter must handle. The University of Minnesota publication states “Biofilters used to treat 

ventilating air exhausted from a livestock building should be sized to treat the maximum 

ventilation rate, which is typically the warm weather rate, of the building.” According to 

the applicant, the broiler house airflow rate can range from 2,700 cfm (new chicks on a 

cold night) to 212,000 cfm (mature birds on a hot day). The maximum airflow rate for 

the house is calculated as follows: 

Maximum Airflow Rate

10 fans @ 26,800 cfm = 268,000 cfm 

1 fan @ 18,300 cfm = 18,300 cfm 

1 fan @ 9,000 cfm = 9,000 cfm

 Total = 295,300 cfm 

As shown above, the maximum airflow rate for each house is about 295,300 cfm. 

However, for more conservative calculations a maximum airflow rate of 212,000 will be 

assumed for this cost analysis. 

Capital Cost
B- 17 

The cost of the biofilter includes the costs of the fans, media, ductwork, plenum, and 

labor. The University of Minnesota publication gives a capital cost between $150 and 

$250 per 1,000 cfm. An average cost of $200 per 1,000 cfm will be assumed for this 

cost analysis. 

The capital cost of the biofilter is calculated as follows: 

$200/1,000 cfm x 212,000 cfm = $42,400 

Pursuant to District Policy APR 1305, section X (11/09/99), the cost for the purchase of 

the biofilter will be spread over the expected life of the system using the capital recovery 

equation. Although, the biofilter media (e.g., soil, compost, wood chips) must be 

replaced after 3-5 years, this does not constitute a significant cost of the system. 

Therefore, the expected life of the system (fans, media, ductwork, plenum, etc) is 

estimated at 10 years. A 10% interest rate is assumed in the equation and the 

assumption will be made that the equipment has no salvage value at the end of the tenyear cycle. 

 

A = [P x i(I+1)n

]/[(I+1)n-1] 

Where: A = Annual Cost 

 P = Present Value 

 I = Interest Rate (10%) 

 N = Equipment Life (10 years) 

 A = [$42,400 x 0.1(1.1)10]/[(1.1)10-1] 

 = $6,900/year 

VOC Emission Reductions

VOCs controlled = 0.0248 lb-VOC/bird-year x 33,120 bird/house x 0.80 

 = 657.1 lb-VOC/house-year 

Adjusted to industry standard = 657.1 lb-VOC/house-year x (1/0.85) 

= 773 lb-VOC/house-year 

 Cost of VOC Emission Reductions

 Cost of reductions = ($6,900/house-year)/((773 lb-VOC/yr)(1 ton/2000 lb)) 

 = $17,852/ton of VOC reduced 

As shown above, the capital cost alone for a biofilter would cause the cost of the VOC 

reductions to be greater than the $5,000/ton cost effectiveness threshold of the District 

BACT policy. Therefore, this option is not cost effective and is being removed from 

consideration at this time. 
B- 18 

The facility is proposing completely enclosed mechanically ventilated broiler housing 

with evaporative cooling pads, mixing fans, and a computer control system using 

thermostats, sensors, and timers to control environmental conditions (e.g. temperature, 

humidity, ventilation) within the houses. The facility is also proposing to feed all birds in 

accordance with National Research Counsel (NRC) or other District-approved 

guidelines and to remove all mortality from houses twice per day. Since there is not a 

more effective control option, no further cost analysis is required. 

Step 5 - Select BACT

BACT for VOC for this operation is determined to be completely enclosed mechanically 

ventilated broiler housing with evaporative cooling pads, mixing fans, and a computer 

control system using thermostats, sensors, and timers to control environmental 

conditions (e.g. temperature, humidity, ventilation) within the houses; feeding all birds in 

accordance with National Research Counsel (NRC) or other District-approved 

guidelines; and removal of all mortality from houses twice per day.25 

 BACT Analysis for NH3 Emissions: 

 Step 1 - Identify All Possible Control Technologies

 The control technology options include: 

 Option 1. Emissions from Broiler House controlled by Carbon Adsorption 

 Option 2. Emissions from Broiler House controlled by Thermal Incineration 

Option 3. Emissions from Broiler House controlled by Catalytic Incineration 

Option 4. Emissions from Broiler House controlled by a Biofilter capable of achieving 

80% control 

Option 5. Total house cleanout after two flocks (3 times per year) 

Option 6. Total house cleanout after one flock (6 times per year) 

Option 7. Animals fed in accordance with National Research Counsel (NRC) or 

other District accepted guidelines utilizing routine nutritional analysis for 

rations 

 Option 8. Broiler House Construction and Management Practices 

1. Insulated & mechanically ventilated poultry house + 

2. Mortality removed twice per day + 

3. Evaporative cooling pads to regulate house temperature + 

4. Mixing Fans 

 Step 2 – Eliminate Options

Option 1 (Emissions from Broiler House controlled by Carbon Adsorption) will be 

eliminated from consideration at this time. Although this option is technologically 

feasible, no uses of carbon adsorption to control broiler house ammonia emissions were 

identified. Since a cost effective threshold has not been established for ammonia, only 

achieved-in-practice options will be considered for ammonia at this time. 

 

25 Total control efficiency of management practices and feeding with NRC guidelines=1-[(1-0.15) x (1-0.09)] =22.7% 
B- 19 

Option 2 (Emissions from Broiler House controlled by Thermal Incineration) and Option 

3 (Emissions from Broiler House controlled by Catalytic Incineration) will be eliminated 

from consideration at this time. Although these options are technologically feasible, no 

uses of thermal or catalytic incineration to control broiler house ammonia emissions 

were identified. Since a cost effective threshold has not been established for ammonia, 

only achieved-in-practice options will be considered for ammonia at this time. It should 

also be noted that incineration is an oxidation process. The most likely by product of 

the oxidation of ammonia would be NOX. The following equation demonstrates the 

likely reaction: 

NH3 + 2.5O2 → NO2 + 3H2O 

The molecular weights of NH3 and NO2 are 17 and 46, respectively; therefore, for every 

pound of ammonia eliminated 2.7 pounds of NOX (a precursor for ozone, and according 

to modeling results, a more significant precursor of PM10 and PM2.5 than NH3) could be 

generated. This is an additional reason to eliminate incineration as a control for 

ammonia. 

Option 4 (Emissions from Broiler House controlled by a Biofilter) will be eliminated from 

consideration at this time. Biofiltration is widely used to control emissions from enclosed 

buildings where pigs are raised and have been used in Minnesota to control emissions 

from enclosed cow housing areas and composting facilities. At West Virginia University 

in 2003, a bench scale biofilter for 33 birds was evaluated for removal of ammonia from 

poultry house exhaust. The biofilter provided 95% control of ammonia emissions.26

However, biofilters have not yet been used for poultry facilities on a large scale and 

although this option is technologically feasible, no uses of biofiltration to control broiler 

house ammonia emissions were identified. Since a cost effective threshold has not 

been established for ammonia, only achieved-in-practice options will be considered for 

ammonia at this time. 

Option 5 (Total house cleanout after two flocks (3 times per year)) and Option 6 (Total 

cleanout after one flock) will be eliminated from consideration at this time. Although 

more frequent removal of litter from the broiler houses would result in less emissions 

from the house, it is likely that these emissions would merely be shifted to litter storage 

areas. Unless the litter storage areas were controlled, there would be no emission 

reductions. Additionally, one of the major reasons for regulating ammonia is that it is a 

precursor for PM10 and PM2.5. As a particulate matter control, the facility’s Conservation 

Management Practice (CMP) plan requires that the litter be used for at least two flocks. 

More frequent cleanouts would cause a greater amount of direct PM10 emissions to the 

atmosphere. 

Step 3 – Rank Remaining Control Technologies by Control Effectiveness

 

26 http://www.ncbi.nlm.nih.gov/entrez/query.fcgi?cmd=Retrieve&db=PubMed&list_uids=12602826&dopt=Abstract 
B- 20 

Control technologies for NH3: 

Acidifying Litter Amendments

The ammonia emission reductions caused by the usage of acidifying litter 

amendments are usually reported in terms ppmv inside the broiler house. Although 

these litter amendments have consistently shown significant reductions in ppmv 

levels in the house (50% reductions in average ppmv level over the grow-out period), 

it may not be possible to directly correlate these reductions to pounds of ammonia 

emitted since the house ventilation rate constantly changes. 

Arkansas research has shown that alum application rates of 130-260 lb per ton of 

litter reduced ammonia-N emissions from 28 lb per ton of litter to less than 1 lb per 

ton of litter over the grow-out period (96.4% control).27 However, this may be the 

result of an atypically high application rate.26

Brewer (1988) estimated that the total nitrogen release over the grow-out period from 

a poultry house with 20,000 broilers was 296 kg (as NH3) for an untreated house and 

131 kg (as NH3) for an alum-treated house (55.7% control). It is estimated that there 

are about 6.7 grow-out cycles per year (used to develop CARB emission factor). The 

resulting emission factor for an alum-treated house is calculated as follows: 

(131 kg-NH3/growout-house) x (2.2 lb/kg) x (6.7 growout/year) ÷ (20,000 bird/house) 

= 0.0965 lb-NH3/bird-year 

Moore states that a typical poultry house will lose about two tons of nitrogen each 

year as ammonia but an alum-treated house will only lose about 1,000 lb of nitrogen 

as ammonia (75% control).28 The resulting emission factor for an alum-treated house 

is calculated as follows: 

(1,000 lb-NH3/house-year) ÷ (20,000 bird/house) = 0.05 lb-NH3/bird-year 

Mcward and Taylor found similar ammonia emission reductions when comparing 

acidic, granular litter amendments such as sodium bisulfate, alum, and Poultry 

Guard.29

The emission reductions for acidifying litter amendments will be conservatively 

estimated at 0.0965 lb-NH3/bird-year and 50% control 

Broiler House Construction and Foster Farms Management Practice

 

27 Alabama Cooperative Extension, Agronomy Series – Alum in Poultry Litter (May, 2005) 28 U.S. Water News Online – Aluminum Sulfate found to reduce ammonia, phosphorus in Poultry litter (February 2002) 29 McWard, G. W. and D. R. Taylor, Acidified Clay Litter Amendment, Journal of Applied Poultry Research (2000) 
B- 21 

The California Air Resources Board (CARB) has performed a source test on the Foster 

Farms Broiler operation that resulted in an ammonia emission factor of 0.0958 lbNH3/bird-year. This emission factor falls within the range of emission factor estimates 

when acidifying litter amendments are used. Therefore, the two options will be 

considered equivalent. 

NH3 Emission Control Technology Rankings 

Rank Control 

Efficiency Status 

3) Acidifying Litter Amendments 50% Achieved in Practice 

4) Broiler House Construction and Foster 

Farms Management Practices 50% Achieved in Practice 

5) Animals fed in accordance with National 

Research Counsel (NRC) or other District 

accepted guidelines utilizing routine nutritional 

analysis for rations 

17%30 Achieved in Practice 

Step 4 - Cost Effectiveness Analysis

All of the above options are achieved-in-practice; therefore a cost analysis is not 

required. 

The facility is proposing completely enclosed mechanically ventilated broiler housing 

with evaporative cooling pads, mixing fans, and a computer control system using 

thermostats, sensors, and timers to control environmental conditions (e.g. temperature, 

humidity, ventilation) within the houses. The facility is also proposing to feed all birds in 

accordance with National Research Counsel (NRC) or other District-approved 

guidelines and to remove all mortality from houses twice per day. Since there is not a 

more effective control option, no further cost analysis is required. 

Step 5 - Select BACT

BACT for NH3 for this operation is determined to be completely enclosed mechanically 

ventilated broiler housing with evaporative cooling pads, mixing fans, and a computer 

control system using thermostats, sensors, and timers to control environmental 

conditions (e.g. temperature, humidity, ventilation) within the houses; feeding all birds in 

accordance with National Research Counsel (NRC) or other District-approved 

guidelines; and removal of all mortality from houses twice per day. 31 

 

30 Assuming that nitrogen excretion, which leads to ammonia volatization, can be reduced by 15% by feeding with NRC guidelines 31 Total control efficiency of management practices and feeding with NRC guidelines=1-[(1-0.50) x (1-0.17)] =58.5% 
 

San Joaquin Valley Unified Air Pollution Control District

 Best Available Control Technology (BACT) Guideline X-XX*

Emission Unit: Broiler House 

Equipment Rating: 33,120 birds/house 

Industry Type: Agriculture (poultry) 

Determination Date: 

Pollutant Achieved in Practice or contained in 

SIP 

Technologically 

Feasible Alternate 

Basic 

Equipment

VOC 

1. 22.7% control (completely enclosed 

mechanically ventilated broiler housing with 

evaporative cooling pads, mixing fans, and a 

computer control system using thermostats, 

sensors, and timers to control environmental 

conditions; all birds fed in accordance with 

NRC or other District-approved guidelines; 

and all mortality removed from houses twice 

per day) 

2. 22.7% control (acidifying litter 

amendments; all birds fed in accordance 

with NRC or other District-approved 

guidelines; and all mortality removed from 

houses twice per day) 

1. 98% control (Capture 

and Thermal 

Incineration) 

2. 95% control (Capture 

and Catalytic 

Incineration) 

3. 95% control (Capture 

and Carbon 

Adsorption) 

4. 80% control (Capture 

and Biofiltration) 

NH3

1. 58.5% control (completely enclosed 

mechanically ventilated broiler housing with 

evaporative cooling pads, mixing fans, and a 

computer control system using thermostats, 

sensors, and timers to control environmental 

conditions; all birds fed in accordance with 

NRC or other District-approved guidelines; 

and all mortality removed from houses twice 

per day) 

2. 58.5% control (acidifying litter 

amendments; all birds fed in accordance 

with NRC or other District-approved 

guidelines; and all mortality removed from 

houses twice per day) 

1. 80% control (Capture 

and Biofiltration) 

BACT is the most stringent control technique for the emissions unit and class of source. Control 

techniques that are not achieved in practice or contained in a state implementation plan must be cost 

effective as well as feasible. Economic analysis to demonstrate cost effectiveness is required for all 

determinations that are not achieved in practice or contained in an EPA approved State Implementation 

Plan. 

*This is a Summary Page for this Class of Source - Permit Specific BACT Determinations on Next 

Page(s) 
 

DRAFT X-XX 3rd Qtr. '05

 

 San Joaquin Valley 

 Unified Air Pollution Control District 

 Best Available Control Technology (BACT) Guideline X-XXA

Emission Unit: Broiler House 

Facility: Foster Farms, El Dorado Ranch 

Location: 1324 South El Dorado Ave. 

Tranquility, CA.

Equipment Rating: 250 ton-onion/day 

References: ATC #: C-5439-1-1 

 Project #: C-1051505 

Date of Determination: 

Pollutant BACT Requirements

NOX 

SOX 

PM10

CO 

VOC 

22.7% control (completely enclosed mechanically ventilated broiler housing with 

evaporative cooling pads, mixing fans, and a computer control system using 

thermostats, sensors, and timers to control environmental conditions; all birds fed in 

accordance with NRC or other District-approved guidelines; and all mortality removed 

from houses twice per day) 

(Achieved in Practice) 

NH3

58.5% control (completely enclosed mechanically ventilated broiler housing with 

evaporative cooling pads, mixing fans, and a computer control system using 

thermostats, sensors, and timers to control environmental conditions; all birds fed in 

accordance with NRC or other District-approved guidelines; and all mortality removed 

from houses twice per day) 

(Achieved in Practice) 

BACT Status: X Achieved in practice Small Emitter T-BACT 

 Technologically feasible BACT 

 At the time of this determination achieved in practice BACT was equivalent to 

technologically feasible BACT 

 Contained in EPA approved SIP 

 The following technologically feasible options were not cost effective: 

 Alternate Basic Equipment 

 The following alternate basic equipment was not cost effective: 

 

3rd Qtr. '05 X-XXA DRAFT
 

Mail to: CAPCOA BACT Clearinghouse Project 

Assessment Branch 

 P.O. Box 2815 

 Sacramento, CA 95812 

 For CAPCOA use only 

Record No.: ;Form No.: ;BLIS District Code: 

Codes - EPA Source: ;SCAQMD: ;EPA ID No.: 

ARB Sc: ,Ctrl: ;BLIS Process: ;AIRS Facility No.: 

 CAPCOA BACT DETERMINATION REPORTING FORM 

Instructions: Complete this form when issuing an authority to construct. Please use on form per determination (i.e. pollutant). Please use 

one form per determination (i.e. pollutant) Section A need only be completed on one form in the case of a source with multiple 

determinations. See the reverse side for descriptions of the field identifiers used below. Please attach a copy of the permit or permit 

conditions if practical. Please call (916)327-5601 for clarification of any questions. (1/5/94) 

SECTION A. Source Information 

Company and Project Name: Harris Fresh, LLC 

Facility Address: PO Box 497 21960 S. Fresno-Coalinga Hwy. SIC Code: 723 

 Coalinga, CA 93210 

 Authority to Authority to 

Application No.: C-1044198 ; Construct No.: C-6188-1-0 Construct Issue Date: June ?, 2005 

District: SJVUAPCD ; District Contact: David Warner; Phone No.: (559) 230-5900 

Est. Startup Date: June 2005 ; Today's Date: June 1, 2005 Permit Unit Status: New

Basic Equip./Process (include make and model): Fresh Onion grading and packing 

Rated Capacity: 250 ton-onion/day ; Output: N/A ; SCC Code: 

 

Fuel Type: n/a ; Backup Fuel(s): N/A ; Project Cost: $ 

 

SECTION B. Control Data Pollutant: PM10 

Control Equip. none 

Emissions: Uncontrolled: 150 lbm/day Controlled Limit: 4.5 lbm/day 

Enforceable Permit Emissions Limit(s): 250 ton-onion/day, 0.018 lb-PM10/ton 

Emission Type: point; Cost of Control Equipment: $5,000 for filter assembly 

Regulatory Requirement: District-Defined BACT District-Defined LAER Other: N/A 

 

BACT/LAER Specification: Reference or Basis: SJVUAPCD 

 Mass Emission Rate: ; Destruction efficiency (%): N/A 

 Normalized Mass Emission Rate: N/A lbm/MMBtu; N/A g/bhp-hr; 0.018 lbm per ton input 

 Emission Concentration: 0.005 gr/dscf at 9,240 scfm 

 Other: N/A 

 Method of Compliance Verification: recordkeeping 

Other Relevant Permit Limits: Time of Operation: N/A 

 Fuel use: N/A Percent Capacity/Use: Seasonal 

 Throughput: N/A 

 Other: N/A 

Remarks: 
San Joaquin Valley Unified Air Pollution Control District April 16, 2009

 

APPENDIX A 

Foster Farms Management Practices 

 

San Joaquin Valley Unified Air Pollution Control District April 16, 2009

 

APPENDIX B 

Chemistry of Some Commercially Available Litter Amendments