UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX AIR DIVISION

Technical Support Document

for EPA ' s Notice of Proposed Rulemaking

for the California State Implementation Plan

EPA’s Evaluation of Ventura County Air Pollution Contro l Dis trict

, 2014 R easonably Available Control Technology (RACT) State Implementation Plan (SIP) Revision

Dated June 10, 2014

Adopted June 10, 2014

Prepared by: Stanley Tong

October 201 4- 2

-

RULE IDENTIFICATION

-

Agency: Ventura Count y Air Pollution Control District ( VCAPCD )

SIP Approved Version : Ventura County Air Pollution Control District 2009 Reasonably Available Control Technology State Implementation Plan (2009 RACT SIP) Revision Adopted September 15, 2009 Submitt ed November 17 , 200 9 SIP Approved May 15, 2014 ( 79 FR 27761 )

Subject of this TSD: VCAPCD 2014 Reasonably Available Control Technology (RACT) State Implementation Plan (SIP ) Revision

– Dated June 10, 2014 (“20 14 RACT SIP”) Adopted June 10, 2014 Submitted July 18, 2014

BACKGROUND

Volatile organic compounds (VOCs) and nitrogen oxides (NOx) in the presence of sunlight can lead to the formation of ground

- leve l ozone or “smog” which can result in significant impacts to human health and the environment. Section 182 of the Clean Air Act (CAA) requires areas that are classified as moderate or above for ozone nonattainment to implement reasonably available control technology (RACT) for specific types of sources.

The Ventura County Air Pollution Control District (VCAPCD) falls under this requirement as it is classified as a serious ozone nonattainment area for the 2008 8

- hour national ambient air quality standard ( “NAAQ S”) for ozone (40 CFR 81.305). Under CAA § § 182(b)(2) and (f), VCAPCD must, at a minimum, adopt RACT level controls for sources covered by a Control Techniques Guidelines (CTG) document and for any other major stationary source of VOCs or NOx.

EPA d efines RACT as the “lowest emissions limitation that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility.” See 78 FR 34178, 34192 , n. 33 (June 6

, 2013) (citing 44 FR 53761 (September 17, 1979) ) . A RACT analysis should, therefore, take into account the technological and economic impacts of controls, and may differ from source to source and location to location.- 3

-

VCA PCD previously submitted certifica tions that its rules satisfied RACT for the 1997 8

- hour ozone standard and CTGs which were issued between 2006 and 2008. 1

SUBMITTAL SUMMARY and EPA EVALUATION

The District adopted its 2014 RACT SIP on June 10, 2014 and the California Air Resources Board (CARB) submitted it to EPA on July 18, 2014. On September 18, 2014, EPA determined that the submittal met the completeness criteria in 40 CFR Part 51 Appendix V, which must be met before formal EPA review.

Ventura performed its 20 14 RACT SIP analysis ba sed on an ozone non attainment classification of “serious” . This classification defines a major source as a stationary source that emits, or has the potential to emit, at least 50 tons per year of VOCs or NOx (CAA § § 182(c) and (f)).

VCAPCD ’ s submittal i ncluded the following documents:

a. Final Ventura County Air Pollution Control District 20 14 Reasonably Available Control Technology State Implementation Plan Revision, June 10, 2014

. b. Resolution of the Ventura County Air Pollution Control Board approving and adopting the 20 14 Reasonably Available Control Technology State Implementation Plan Revision

– adopted on June 10, 2014

.

VCAPCD ’ s analysis evaluated the following areas. Further discussion is provided below.

 VOC and NOx rules subject to CTG source catego ries

 Negative declarations

 Major non

- CTG sources of VOC or NOx

EPA evaluated the following elements of VCAPCD ’s 2014 RACT SIP submittal :

 Efforts to identify all source categories within the District requiring RACT

 N egative declarations where there are no facilities subject to a CTG

 List of the State/local regulations that implement RACT

 T h e bases for concluding that all referenced regulations fulfill RACT

The following documents were also used to support our review:

 “ Final Rule to Implement the 8

- Hour Ozo ne National Ambient Air Quality Standard

– Phase 2 ” (70 FR 71612; November 29, 2005).

 “Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State Implementation Plan Requirements”

– Proposed Rule ( 78 FR 34178; June 6, 2013).

 “ State Implementation Plans, General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990 ” (57 FR 13498; April 16, 1992).

1 EPA approved VCAPCD’s RACT SIP for the 1997 8

- hour standard in 74 FR 18148 (April 21, 2009). EPA approved VCAPCD’s RACT SIP Revision in 79 FR 27761 (May 15, 2014) in which the District certified its rules met the applicable recommendat ions in 1 1 new or revised CTGs issued between 2006 and 2008

, adopted negative declarations where it did not have sources subject to a CTG

, and reviewed its databases for any additional major sources of VOC or NOx to ensure they were covered by RACT rules.- 4

-

 Enforceability

- Section 110(a) of the CAA requires enforceable emission limitations and other control measures . Several EPA guidance documents are used to evaluate rule enforceability, including Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations: Clarification to Appendix D of November 24, 1987 FEDERAL REGISTER, May 25, 1988 , Revised January 11, 1990 ("The Blue Book"), and EPA Region IX’s Guidance Document for Correcting Common VOC and Other Rule Deficiencies

, August 21, 2001 (the "Little Bluebook").

 “ State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for Implemen tation of Title I of the C lean Air Act Amendments of 1990 ” (57 FR 55620, November 25, 1992) ("the NOx Supplement").

 Memorandum from William T. Harnett to Regional Air Division Directors, (May 18, 2006), “RACT Qs & As

– Reasonably Available Control Technolo gy (RACT) Questions and Answers”.

 RACT SIPs, Letter dated March 9, 2006 from EPA Region IX (Andrew Steckel) to CARB (Kurt Karperos) describing Region IX’s understanding of what constitutes a minimally acceptable RACT SIP.

 EPA's CTGs http://www.epa.gov/groundlevelozone/SIPToolkit/ctgs.html

 CARB’s emissions inventory database http://www.arb.ca.gov/app/emsinv/facinfo/fac info.php

 VCAPCD, CARB and EPA Region IX databases of VCAPCD rules VCAPCD: http://vcapcd.org/Rulebook/RuleIndex.htm CARB: http://www.arb.ca.gov /rldb/rldb.htm EPA: http://epa.gov/region09/air/sips/index.html

1. VOC and NOx R ules S ubject to CTG Source C ategories

Ventura County Action :

VCAPCD’s 2014 RACT SIP states that “All rules appli cable to CTG source categories were determined to meet or exceed the CTG requirements during the 2006 and 2009 RACT SIP updates, so the rules were not compared to CTG requirements again.” The District’s RACT SIP goes on to further state that since many CTG s have not been updated for many years, VCAPCD compared its rules to rules adopted by other air districts with hig her or more stringent ozone non attainment classifications. 2

VCAPCD also applied a cost effectiveness evaluation to determine whether certain controls implemented in other air districts were cost effective and therefore could represent reasonably available controls. For VOC sources , the District applied a Best Available Control Technology threshold of $18,000 per ton of VOC reduced as representi ng “beyond RACT”. For NOx sources, it applied an inflation adjusted cost effectiveness threshold of $1,990 per ton of NOx reduced based on EPA’s Phase 2 Implementation Rule. 3

2 VCAPCD 2014 RACT SIP, page 5.

3 Id. (citing "Final Rule to Implement the 8

- Hour Ozone National Ambient Air Quality Standard

– Phase 2" (70 FR 71612; 71654 November 29, 2005) )

.- 5

-

VCAPCD’s evaluation determined that all applicable District rules fulfill RACT.

EPA Evaluation

EPA reviewed a draft version of VCAPCD ’s 2014 RACT SIP and provided suggestions for improvement. We believe VCA PCD adequately addressed our comments in the submitted 2014 RACT SIP. Below is a summary of our more significant comments.

Rule 70: Storage and Transfer of Gasoline (last revised 4/1/2009)

EPA recommended that the District investigate a lower emissions limit adopted by the Bay Area AQMD in Rule 8

- 33 Gasoline Bulk Terminals and Gasoline Cargo Tanks . Rule 8

- 33 requires that , effect ive January 10, 2011, bulk terminals shall not emit non

- methane organic compounds exceeding 0.04 lb per 1000 gallons of organic liquid loaded (vs. 0.08 lb / 1000 gallons loaded in VCAPCD Rule 70) from a vapor recovery system.

VCAPCD determined that the o verall cost effectiveness of the emission reductions from BAAQMD R ule 8

- 33 amendments is $13,200 per ton of ROC reductions. The VCAPCD concluded that this cost is relatively high to be considered RACT.

Since the Bay Area VOC limit only recently took effec t , and we were unable to find this limit in other air districts’ rules , we agree th e 0.04 lb VOC / 1000 gallons loaded could be considered beyond RACT at this time

. We recommend VCAPCD revisit the feasibility of this limit for a future rule amendment . A fu ture RACT analysis should include a review of actual test results at VCAPCD bulk terminals to evaluate whether the terminals are able to achieve a limit of 0.04 lb VOC / 1000 gallons loaded.

Rule 74.6 Surface Cleaning and Degreasing (last revised 11/11/20 03)

EPA recommended VCAPCD re

- evaluat e Rule 74.6’s solvent cleaning limit for electrical devices . Rule 74.6 limits the VOC content of solvents used in the repair of electrical devices to 33mm Hg and 900 g/l whereas S outh Coast Rule 1171 Solvent Cleaning O perations has a 100 g/l limit effective 7/2005

.

VCAPCD’s 2014 RACT SIP points out that Rule 74.6 has a more stringent general solvent cleaning limit of 25 g/l compared to the 50 g/l recommend ed limit in EPA’s 2006 Industrial Cleaning Solvents CTG

. The Dis trict also points out that several categories

, including electrical and electronic components and medical devices

, are excluded from the CTG and therefore RACT does not apply to solvent cleaning for the electrical and electronic cleani ng category and the m edical devices category.

We agree that the electrical and electronic cleaning and medical devices categories are not covered under the 2006 Industrial Cleaning Solvents CTG and that a solvent cleaning limit- 6

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of 100g/l for electrical devices could be consid ered beyond RACT at this time

. Nonetheless, we recommend that VCAPCD consider re

- evaluating Rule 74.6’s solvent cleaning limit for electrical devices in the future. 4

Rule 74.9 Stationary Internal Combustion Engines (last revised 11/8/2005)

VCAPCD’s 2014 RACT SIP states that agricultural (AG) engines are exempted from the rule, but “...the District requires registration of AG engines to track compliance with the Air Resources Board Air borne Toxic Control Measure (ATCM) for diesel particulates and documents s park ignited engines for emissions inventory purposes. District staff evaluated the inventory of AG engine s and found no major sources of NOx.

Our original comment recommended VCAPCD consider removing the AG engine exemption from Rule 74.9 . We noted that

, while the ATCM may control diesel and particulate emissions, the ATCM regulates compression ignition engines (not spark ignited) and the ATCM is not submitted for SIP approval and could therefore change without EPA approval. VCAPCD’s clarification that i t has no AG engines that are major sources of NOx

means these engines are not subject to RACT.

2. Submit N egative D eclarations W here T here are no F acilities S ubject to a CTG

Ventura County A ction :

Table B

- 2 of the VCAPCD 2014 RACT SIP lists CTG source cate gories where the District did not have a corresponding rule , and for which the District has no stationary sources subject to the CTGs . VCAPCD compiled this list by comparing their source specific rules against EPA’s list of CTGs and ACTs and reviewing thei r permits, emissions inventory, and consulting with knowledgeable staff of the District’s permit and enforcement divisions to determine if it had any stationary sources subject to the CTGs . For the negative declarations listed in VCAPCD’s 2014 RACT SIP Tab le B

- 2, the District indicated it does not anticipate sources in t hese categories in the future.

EPA E valuation :

VCAPCD’s 2014 RACT SIP, Table B

- 2

, lists CTGs, ACTs, and other documents help establish RACT at major sources. Negative Declarations are onl y required for CTG source categories where the District has no sources subject to a CTG . A negative declaration is not required for ACTs or for other non

- CTG source categories. Table 1 below lists the CTG source categories that remain after excluding the A CTs and non

- CTG source categories from VCAPCD’s Table B

- 2. EPA is acting on the negative declarations listed in Table 1 below instead of VCAPCD’s Table B

- 2.

4 The District’s 2007 Air Quality Management Plan includes Rule 74.6 as a potential candidate for additional emission reductions. See Tables 3

- 3 Further Study Control Measures and 8

- 5 Every Feasible/Further Study Control Measures

- Detail ww w.vcapcd.org/pubs/Planning/AQMP/FinalVenturaCounty2007AQMP.pdf- 7

-

We searched CARB’s emissions inventory database to verify there are no facilities in VCAPCD that m ight be subject to the below CTGs. We agree with the District’s negative declaration s

.

Table 1

– VCAPCD Negative Declarations

CTG Source Category CTG Reference Document Aerospace EPA

- 453/R

- 97

- 004 , Aerospace CTG and MACT Automobile and Light

- duty Trucks , Surface Coating of EPA

- 450/2

- 77

- 008

, Control of Volatile Organic Emissions from Existing Stationary Sources

– Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light

- Duty Trucks

EPA 453/R

- 08

- 006, Control Techniques Guidelines f or Automobile and Light

- Duty Truck Assembly Coatings Cans and Coils, Surface Coating of EPA

- 450/2

- 77

- 008

, Control of Volatile Organic Emissions from Existing Stationary Sources

– Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light

- Duty Trucks Flat Wood Paneling, Surface Coating of EPA

- 450/2

- 78

- 032, Control of Volatile Organic Emissions from Existing Stationary Sources

– Volume VII: Factory Surface Coating of Flat Wood Paneling

EPA

- 453/R

- 06

- 004, Control Techniques Guideline s for Flat Wood Paneling Coatings Flexible Packaging Printing EPA

- 453/R

- 06

- 003, Control Techniques Guidelines for Flexible Package Printing Large Appliances, Surface Coating of EPA

- 450/2

- 77

- 034, Control of Volatile Organic Emissions from Existing Statio nary Sources

– Volume V: Surface Coating of Large Appliances

EPA 453/R

- 07

- 004, Control Techniques Guidelines for Large Appliance Coatings Magnet Wire, Surface Coating for Insulation of EPA

- 450/2

- 77

- 033, Control of Volatile Organic Emissions from Existin g Stationary Sources

– Volume IV: Surface Coating of Insulation of Magnet Wire Metal Furniture Coatings EPA

- 450/2

- 77

- 032, Control of Volatile Organic Emissions from Existing Stationary Sources

– Volume III: Surface Coating of Metal Furniture

EPA 453/R

- 07

- 005, Control Techniques Guidelines for Metal Furniture Coatings Paper, Film and Foil Coatings EPA 453/R

- 07

- 003, Control Techniques Guidelines for Paper, Film, and Foil Coatings Petroleum Refineries EPA

- 450/2

- 77

- 025, Control of Refinery Vacuum Producing Systems, Wastewater Separators, and Process Unit Turnarounds

EPA

- 450/2

- 78

- 036, Control of Volatile Organic Compound Leaks from Petroleum Refinery Equipment Fiberglass Boat Manufacturing EPA 453/R

- 08

- 004, Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials I ndustrial Adhesives EPA 453/R

- 08

- 005, Control Techniques Guidelines for Miscellaneous Industrial Adhesives Pharmaceutical Products EPA

- 450/2

- 78

- 029, Control of Volatile Organic Emissions from Manufacture of Synthesized Pharmaceu tical Products Pneumatic Rubber Tires, Manufacture of EPA

- 450/2

- 78

- 030, Control of Volatile Organic Emissions from Manufacture of Pneumatic Rubber Tires- 8

-

CTG Source Category CTG Reference Document Polyester Resin EPA

- 450/3

- 83

- 008, Control of Volatile Organic Compound Emissions from Manufacture of High

- Density Polyethylene, Polypropylene, and Polystyrene Resins

EPA

- 450/3

- 83

- 006, Control of Volatile Organic Compound Leaks from Synthetic Organic Chemical Polymer and Resin Manufacturing Equipment Synthetic Organic Chemical Manufacturing EPA

- 450/3

- 84

- 015, Control of Volatile Organic Compound Emissions from Air Oxidation Processes in Synthetic Organic Chemical Manufacturing Industry

EPA

- 450/4

- 91

- 031, Control of Volatile Organic Compound Emissions from Reactor Processes and Distillation Operations in Sy nthetic Organic Chemical Manufacturing Industry Petroleum Solvent Dry Cleaners EPA

- 450/3

- 82

- 009, Control of Volatile Organic Compound Emissions from Large Petroleum Dry Cleaners

3. Major non

- CTG Sources of VOC or NOx

CAA § 182(b)(2) requires RACT for sta tionary source categories covered by CTG document s and all other major st ationary sources of VOCs or NOx. For o zone nonattainment areas designated as “serious”, such as VCAPCD, 5 a major source is defined as a stationary source that emits, or has the potent ial to emit, at least 50 tons p er year of VOCs or NOx.

Ventura County Action :

VCAPCD’s 2014 RACT SIP lists all stationary sources with the potential to emit 50 tons per year of VOC or NOx and the associated District rules applicable to the stationary so urce. (See 2014 RACT SIP, Table B

- 3).

EPA Evaluation :

We searched CARB’s emissions inventory database and reviewed VCAPCD’s 2006 RACT SIP and did not identify any additional major sources that were not already listed in VCAPCD’s 2014 RACT SIP Table B

- 3. The District’s listing of major sources in Table B

- 3 appears to be complete.

RECOMMENDATIONS

The following recommendation is provided for future consideration the next time Rule 70 is open for amendment.

5 See 40 CFR § 81.305 ( California

— 2008 8

- Hour Ozone NAAQS)

.- 9

-

Rule 70 Storage and Transfer of Gasoline

– Con sider r evisit ing the 0.04 lb VOC / 1000 gallons loaded limit in Bay Area AQMD Rule 8

- 33 Gasoline Bulk Terminals and Gasoline Cargo Tanks to determine whether this limit has been more widely adopted in other ozone nonattainment areas in California and how a ctual bulk terminal test results in VCAPCD compare to this lower limit.

SUMMARY

We concur with VCAP C D’s 2014 RACT SIP certification that it fulfills the requirements for RACT for the 2008 8

- hour ozone standard and recommend it be approved.

REFERENCES 1. Ventura County Air Pollution Control District, 2014 Reasonably Available Control Technology (RACT) State Implementation Plan (SIP) Revision

, Dated June 10, 2014

, Adopted June 10, 2014 ; s ubmitted July 1 8 , 20 14.

2. Ventura County Air Pollution Control District, DRAFT 2014 RACT Analysis, EPA comments.

3

. “ Final Rule to Implement the 8

- Hour Ozone National Ambient Air Quality Standard

– Phase 2” 70 FR 71612; November 29, 2005). h ttp://www.gpo.gov/fdsys/pkg/FR

- 2005

- 11

- 29/pdf/05

- 22698.pdf

4 . “Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State Implementation Plan Requirements”

– Proposed Rule (78 FR 34178; June 6, 2013). http://www.gpo.gov/fdsys/pkg/FR

- 2013

- 06

- 06/pdf/2013

- 13233.pdf

5

. “ State Implementation Plans, General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990 ” (57 FR 13498; Apri l 16, 1992).

6

. Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations: Clarification to Appendix D of November 24, 1987 FEDERAL REGISTER, May 25, 1988 , Revised January 11, 1990 ("The Blue Book")

.

7

. EPA Region IX’s Guidance Documen t for Correcting Common VOC and Other Rule Deficiencies

, August 21, 2001 (the "Little Bluebook").

8

. “ State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990 ” (57 FR 55620, November 25, 1992) (“the NOx Supplement” ).

9

. RACT Qs & As

– Reasonably Available Control Technology (RACT): Questions and Answers, May 18, 2006 Memorandum from William T. Harnett, Director, Air Quality Policy Division, to Regional Air Di vision Directors. http://www.epa.gov/ttn/caaa/t1/memoranda/ractqanda.pdf- 10

-

10

. RACT SIPs, Letter dated March 9, 2006 from EPA Region IX (Andrew Steckel) to CARB (Kurt Karperos) describ ing Region IX’s understanding of what constituted a minimally acceptable RACT SIP.

11

. EPA's CTGs and ACTs http://www.epa.gov/groundlevelozone/SIPToolkit/ctgs.html

.

12

. CARB’s em issions inventory database http://www.arb.ca.gov/app/emsinv/facinfo/facinfo.php

.

13

. VCAPCD, CARB and EPA Region IX databases of VCAPCD rules VCAPCD: http://vcapcd.org/Rulebook/RuleIndex.htm CARB: http://www.arb.ca.gov/rldb/rldb.htm EPA: http://epa.gov/region09/air/ sips/index.html

.