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 Control District, 

2014 Reasonably Available Control Technology (RACT)

State Implementation Plan (SIP) Revision

Dated June 10, 2014

Adopted June 10, 2014

Prepared by: Stanley Tong

October 2014
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RULE IDENTIFICATION -

Agency: Ventura County 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

Submitted November 17, 2009

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 

(“2014 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-level 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 (“NAAQS”) 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 defines 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.
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VCAPCD previously submitted certifications 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 2014 RACT SIP analysis based on an ozone nonattainment 

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 included the following documents:

a. Final Ventura County Air Pollution Control District 2014 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 2014 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 categories

 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

 Negative declarations where there are no facilities subject to a CTG

 List of the State/local regulations that implement RACT

 The 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 Ozone 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 recommendations in 11 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.
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 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 

Implementation of Title I of the Clean 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 Technology (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/facinfo.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 Rules Subject to CTG Source Categories

Ventura County Action:

VCAPCD’s 2014 RACT SIP states that “All rules applicable to CTG source categories were 

determined to meet or exceed the CTG requirements during the 2006 and 2009 RACT SIP 

updates, so the rules were not compared to CTG requirements again.” The District’s RACT 

SIP goes on to further state that since many CTGs have not been updated for many years, 

VCAPCD compared its rules to rules adopted by other air districts with higher or more 

stringent ozone nonattainment 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 representing “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)).
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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 VCAPCD 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, effective 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 overall cost effectiveness of the emission reductions from 

BAAQMD Rule 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 effect, and we were unable to find this limit 

in other air districts’ rules, we agree the 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 future 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 11/11/2003)

EPA recommended VCAPCD re-evaluate 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 South Coast Rule 1171 Solvent Cleaning 

Operations 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 recommended limit in EPA’s 2006 Industrial 

Cleaning Solvents CTG. The District 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 cleaning 

category and the medical 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 

 
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of 100g/l for electrical devices could be considered 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 Airborne Toxic Control Measure (ATCM) for diesel particulates and 

documents spark ignited engines for emissions inventory purposes. District staff evaluated 

the inventory of AG engines 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 it has no AG engines that are major sources of NOx 

means these engines are not subject to RACT.

2. Submit Negative Declarations Where There are no Facilities Subject to a CTG

Ventura County Action:

Table B-2 of the VCAPCD 2014 RACT SIP lists CTG source categories 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 their 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 Table B-2, the District indicated it does not anticipate sources in these 

categories in the future. 

EPA Evaluation:

VCAPCD’s 2014 RACT SIP, Table B-2, lists CTGs, ACTs, and other documents help establish 

RACT at major sources. Negative Declarations are only 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 ACTs 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 www.vcapcd.org/pubs/Planning/AQMP/FinalVenturaCounty2007AQMP.pdf
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We searched CARB’s emissions inventory database to verify there are no facilities in 

VCAPCD that might be subject to the below CTGs. We agree with the District’s negative 

declarations.

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 for 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 Guidelines 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 

Stationary 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 Existing 

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

Industrial 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 Pharmaceutical Products

Pneumatic Rubber Tires, 

Manufacture of

EPA-450/2-78-030, Control of Volatile Organic Emissions from 

Manufacture of Pneumatic Rubber Tires
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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 Synthetic 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 stationary source categories covered by CTG documents 

and all other major stationary sources of VOCs or NOx. For ozone nonattainment areas 

designated as “serious”, such as VCAPCD,5 a major source is defined as a stationary source 

that emits, or has the potential to emit, at least 50 tons per 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 source. (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).
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Rule 70 Storage and Transfer of Gasoline – Consider revisiting 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 actual bulk terminal test results in VCAPCD compare to this lower 

limit.

SUMMARY

We concur with VCAPCD’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; submitted July 18, 2014.

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). http://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; April 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 Document 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 Division Directors. 

http://www.epa.gov/ttn/caaa/t1/memoranda/ractqanda.pdf
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10. RACT SIPs, Letter dated March 9, 2006 from EPA Region IX (Andrew Steckel) to CARB 

(Kurt Karperos) describing 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 emissions 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.