AIR RESOURCES BOARD

VENTURA COUNTY APCD RULE EVALUATION FORM - Page 1

0 I. GENERAL INFORMATION

District: Ventura County APCD Rule Nos.: 74.13, 74.20 and 74.24 Date Amended: Sept 11, 2012

Rule Titles: Aerospace Assembly and Component Manufacturing Operations (74.13), Adhesives and Sealants (74.20), and Marine Coating 

Operations (74.24)

Date Submitted to ARB: October 29, 2012 If an Amended Rule, Date Last Amended: Rule 74.13 on 11/11/2003, Rule 74.20 on 

1/11/2005, and Rule 74.24 on 11/11/2003

Is the Rule Intended to be Sent to the U.S. EPA as a SIP Revision? (X) Yes ( ) No If NO, do not complete remainder of form.

District Contact: Stan Cowen Phone No.: 805/645-1408

Narrative Summary of New Rule or Rule Changes: ( ) New Rule (X) Amended: Revisions to Rule 74.20 and 74.24 will amend the solvent 

cleaning requirements by replace the vapor pressure limits with the ultra-low ROC content limit of 25 grams per liter. The revision to Rule 74.13 will 

instead lower the partial ROC vapor pressure limit requirement for spray gun cleaning from 45 to 5 mm Hg. 

Pollutant(s) Regulated by the Rule (Circle): ROG NOx SO2 PM10 CO TAC

II. EFFECT ON EMISSIONS

Complete this section ONLY for rules that, when implemented, will result in quantifiable changes in emission. Attach reference(s) for emission factor(s) and other 

information. Attach calculation sheet showing how the emissions information provided below was determined. See staff report Appendix A for emission calculations.

Net Effect on Emissions: ( ) Increase(X) Decrease ( ) N/A No impact on emissions. See attached staff report for emission reduction 

calculations. The net effect of the three rules is to reduce ROC emissions by 9 tons per year.

II. EFFECT ON EMISSIONS

Emission Reduction Commitment in SIP (Control Measure ) for this source category: 2011 Triennial Assessment: New control measure and 

ROC emission reductions estimated at 10 tons per year. 

Inventory Year Used to Calculate Changes in Emissions: 2012 Area Affected:County

Future Year Control Profile Estimate:

Year

Tons/year 

Reductions 

2012 Baseline 

Tons/year 

Subject to Rule

Control 

Level

Percent 

Control

Control 

Level

Control Factor

2013 9 / 18 = 0.5 * 100 = 50% 1.00 - 0.5 = 0.5
AIR RESOURCES BOARD

VENTURA COUNTY APCD RULE EVALUATION FORM - Page 2

III. SOURCES/ATTAINMENT STATUS

District is: ( ) Attainment(X) Nonattainment ( ) Split

Approximate Total Number of Small (<100 TPY) Sources Controlled by Rule: 17

Percent in Nonattainment Area: 100 %

Number of Large (>100 TPY) Sources Controlled: None Percent in Nonattainment Area: Not Applicable

IV. EMISSION REDUCTION TECHNOLOGY

Do the Rules Include Emission Limits that are Continuous? Yes.

V. OTHER REQUIREMENTS

RULE 74.13 (Aerospace Coatings) Requirements include: RULE 74.20 (Adhesives) Requirements include:

Emission Limits: Section B Emission Limits: Section B

Recordkeeping Requirements: Section D Prohibition of Sale: Section B

Reporting Requirements: Not Applicable. Recordkeeping: Section D

Test Methods: Section E Test Methods: Section E

Exemptions: Section C. Exemptions: Section C

RULE 74.24 (Marine Coatings) Requirements include:

Emission Limits: Section B

Recordkeeping Requirements in Section(s): Section D

Reporting Requirements Not Applicable

Test Methods: Section E

Exemptions: Section C.
AIR RESOURCES BOARD

VENTURA COUNTY APCD RULE EVALUATION FORM - Page 3

VI. IMPACT ON AIR QUALITY PLAN

(X) No Impact( ) Impacts RFP ( ) Impacts attainment

Discussion: Amendments to Rule 74.13, Rule 74.20 and Rule 74.24 will reduce ROC emissions for Ventura County’s efforts 

toward achieving attainment of the ozone standard. Therefore, RFP will be furthered by amendments to both rules.