Ventura County 669 County Square Drwe tel 805/645 -1400 Richard H. Baldwin Air Pollution Ventura, Cal~forn~a 93003 fnx 805/645-1444 Air Pollution Control Officer Control District

June 27,2006

Air Pollution ControlBoard 800 South Victoria Avenue Ventura, CA 93009 SUBJECT: PUBLIC 

### HEARING TO APPROVE THE 2006REASONABLY A VAILABLECONTROL TECHNOLOGYSTATE IMPLEMENTATION PLAN

### RE VISION(2006 RACT SIP REVISION) RECOMMENDED ACTION: 1. Approve District stafrs determination that the draft 2006Reasonably Available Control Technology StateImplementatzon Plan Revzszon is not aproject subject to the California Environmental QualityAct (CEQA), pursuant to CEQA Guidelines Sectlon 15378(a).
2. Approve, adopt, and authorizethe Chair to sign a resolution (Attachment 

### 1) adopting the draft 2006Reasonably Available Control Technology State ImplementationPlan Revision (Attachment 2) as the final 2006Reasonably Available Control Technology State ImplementationPlan Revuzon. 3. Direct the clerk of the board to forward two certified minute orders and an affidavit ofpublication of the public hearing notlce for the proposed action to the Air Pollution Control District.
4. Direct staffto forward the signed resolution and the final 2006Reasonably Avazlable Control Technology StateImplementatzon Plan Revzszon to the CaliforniaAir Resources Board for transmittal to the U.S. Environmental ProtectionAgency as a proposed revision to the California State Implementation Plan for ozone FISCAL IMPACT: Mandatory: Yes Fiscal impacts: None2006 RACT SIP June 27,2006 Page 2 STATEMENT OF MATTER FOR BOARD CONSIDERATION: General Background The federal CleanAir Act Amendments (CAAA) of 1990give the states primary responsibilityfor achieving the national ambient air quality standards (NAAQS). The NAAQS are set by the U.S. Environmental Protection Agency (EPA) as the maximum concentrationsin the atmosphere for specific air contaminants in order to protect public health and safety. 

### CAAA Sections 182(b)(2)and 182(f)require ozonenonattainment areas to implement Reasonably AvailableControl Technology (RACT) for sourcesthat are subject to EPA Control Techniques Guideline(CTG) documents and for "major sources" of ozone precursor emissions, or volatile organic compounds (VOCs) and oxides ofnitrogen (NOx). 42 U.S.C. 751la, subdivisions (b)(2) and 

### (f). RACT is defined as the lowest emissions limitationthat a particular source is capable ofmeeting by the application of controltechnology that is reasonably available considering technological and economic feasibility (44 

### FR 53762; September 17, 1979). CTGs are EPA documentsthat define RACT for existing sources of volatile organic compounds, which are precursorsto ozone. Emission sources covered by CTGs are known as CTG sources. RACT requirementsare included in the Clean

### Air Act to assure that significant source categories at major sources of ozone precursor emissions are controlledto a "reasonable" extent,but not necessarily to Best Available Control Technology (BACT) or "maximum achievable control technology" (MACT) levels expected ofnew sources. Pursuant to the EPA's Final Rule to Implement the 8-Hour Ozone NAAQS (70 FR 71612; November 29,2005), an area classified as moderate ozone nonattainment or higher must submit a demonstration that their current rules fulfill 8-hour ozone RACT for all CTG categories and all major, non-CTG sources as a revision to their respective state implementation plans 

### (SIP). Such demonstrations can be made with either a new RACT determination or a certification that previously required/existingRACT controls represent RACT for the 8-hour ozone standard. Alternatively, an area may adopt "negative declarations" documenting that the area has no stationary source or emitting facilities subject to EPA CTG documents. A subject nonattainment area may rely on previous analyses prepared for the one-hour ozone NAAQS plans and related EPA guidance documents. This RACT SIP submittal is in addition to the nonattainment area's 8-hour ozone attainment demonstrationplan, which is also a SIP submittal. The RACT SIP must be submitted to EPA by September 15,2006.2006 RACT SIP June 27,2006 Page 3 Description ofthe Draft 2006 RACT SIP Revision District staff started its 2006 RACT SIP Revision evaluation by reviewing all available CTGs and AlternativeControl Technique (ACT) guidelines and comparing them to applicable Distnct rules and sources. For each sourcecategory, Distnct staffIdentified applicable sources and corresponding District rules. Following identification ofDistrict rules to be evaluated for the 2006 RACT SIP Revision, District staff made determinations as to whether the rules meet RACT. The determinationswere based on two criteria. (1) Local air pollution control rule approvalby the 

### U.S. EnvironmentalProtection Agency; and, (2) RACTBARCT determinations issued by the CaliforniaAir ResourcesBoard. BARCT (Best AvailableRetrofit Control Technology) is an emission limitationthat is based on the maximum degree ofreduction achievable, taking into account environmental, energy, and economic impacts by each class or category of sources. EPA rule approval is an appropriatebasis for RACT findings because EPA must evaluate the rules to determineifthey fulfillRACT requirements prior to approval. RACTBARCT determinations are an appropriate basis for thsanalysis because they are more current and stringent than RACT. Moreover, the District must implement RACTBARCT determinations as a requirement ofthe California Clean Air Act, whch is generally more stringent than the federal CAAA. Based on the foregoing,Distnct staff found that all District rules applicable to ozone precursor emissions fulfillRACT requirements for the 8-hour ozoneNAAQS. At a minimum, the rules meet RACT or, more commonly, significantly exceed RACT because they complywith more current and stnngent control requirements of the California Clean Air Act. District staff also found that all CTG sources and major, non-CTG sourcesunder its jurisdiction are controlled to RACT or better standards. There are several CTG source categories (listed in Table A-2 ofthe draft 2006 RACT SIP) for which there are no sourceswithin Districtboundaries. Moreover, the District does not anticipatethese sourcesin the fbture. Therefore, District staffdetermined that negative declarations documenting that there are no sources

### in the county subject to those CTGs are appropriate. Moreover, any new sourceswould be subject to best available control technology (BACT) requirements, pursuant to the District's New SourceReview (Rule 26) regulation. BACT is more stnngent than RACT.T J 2006 RACT SIP June 27,2006 Page 4 Distnct's Draft 2006 RACT SIP and CEQA The 2006 RACT SIP Revision was an evaluationof current Distnct air pollution rules and will not result in new or revised District regulations or anyphysical change in the environment. Therefore, adoption of the proposed 2006 RACT SIP Revision is not a "Project" as described in Section 15378(a)ofthe CEQA Guidelines. Public Review The public review penod for the 2006 RACT 

### SIP Revision began on May 9,2006, and ran through June 9,2006. The District mailed out 205 notices of availability ofthe draft 2006 RACT SIP to representatives of public and private organizations. The District also placed a public notice on the District's website and in the Ventura County Star. During the public review period, written comments on the draft 2006 RACT SIP were received from EPA. No other public or agency comments were received. EPA's comments and District responses are provided in Attachment 

### 3. Additionally, the District held a publ~c workshop on May 23,2006, to discuss and take public comments on the draft 2006 RACT SIP. No one attended the public workshop. The Auditor-Controller's office, County Counsel, and Human Resources have reviewed this letter. 

### Ifyou have any questions, please contact Chuck Thomas at 645-1427.

Air Pollution Control Officer
Attachment 1 Resoluhon Approvmg and Adoptmg the 2006ReasonablyAvazlable Control Technology State Implementafton Plan Revzs~on Attachment 2 Draft 2006ReasonablyAvazlable Control Technology State Zmplementatzon Plan Revzszon Attachment 3 Public Comments and DistnctResponses to CommentsAttachment 1


### RESOLUTIONAPPROVING AND ADOPTING 

### THE 2006 

### REASONABLY AVAILABLE CONTROL TECHNOLOGY STATEIMPLEMENTATIONPLAN REMSION

### A RESOLUTION OF THE VENTURA COUNTY AIR POLLUTION CONTROL BOARD APPROVING AND ADOPTING THE 2006 

### REASONABLY AVAILABLE CONTROL TECHNOLOGY STATE IMPLEMENTATION PLAN REVISION
WHEREAS, Ventura County is classified as a "moderate" nonattainment area with regard to the national ambient air quality standard (NAAQS) for the eight-hour ozone in accordance with the federal Clean Air Act (42 U.S.C. !j 7401 et seq.); and, WHEREAS, both the federal Clean An-Act and the California Clean Air Act (Health & Safety Code !j 39000 et seq.) require the Ventura County Air Pollution Control District (District) to adopt air pollution controlplans, rules and regulations for volatile organic compounds (VOC) and nltrogen oxides (NOx)to bnng Ventura County into attainment of the federal and state ambient ozone standards as expeditiouslyas practicable; and, WHEREAS, Section 182(b) of the federal Clean Air Act requires states with ozone nonattainment areas designated as "moderate" to submit a State Implementation Plan (SIP) as descnbed in Section 182(a)(relatingto Marginal Areas), and to also submit revisions to the applicable SIP describedunder Section 182(b) (relatingto Moderate Areas) for the purpose of showing progress towards the attainment ofthe ozoneNAAQS; and, WHEREAS, Section 182(a)(2)(A)of the federal Clean 

### Air Act requires states

### with ozone nonattanment areas designated as "marginal" or greater to submit a revision to the State Implementation Plan for ReasonablyAvailable Control Technology (RACT) corrections; and, WHEREAS, Section 182(b)(2)ofthe federal Clean Air Act requires states with ozone nonattainment areas designatedas "moderate" or greater to submit a revision to the State Implementation Plan for implementation ofRACT under Section 172(c)(l)of the federal Clean Air Act; and, WHEREAS, the United StatesEnvironmental Protection Agency (EPA) promulgated, through Federal Register, Volume 70,page 71612 et seq.,November 29,2005, the requirement that the State of Californiamust submit a RACT SIP analysis to EPA by September 15,2006; and, WHEREAS, the Distnct complied with this EPA requirement by preparing the 2006 

### Reasonably Available Control Technology State Implementation Plan Revzsion (2006 RACT SIP) in accordance to the terms and conditions of applicable federal law and regulations, and, WHEREAS, District staffevaluated the District's VOC and NOx rules subject to EPA's Control Technologies Guidelines(CTGs) and found that they all meet or exceed RACT requlrements; and, WHEREAS, District staff also found that all CTG sources and major, non-CTG sources under District jurisdiction are controlledto RACT or better standards; and,
1 Attachment 1WHEREAS, District stafffound that RACT analyses for the CTG sources listed in Table A-2 ofthe District's staffreport for the 2006 RACT SIP, which is incorporated herein by reference, are not necessary because there are no sources within District boundanes subject to the CTGs, nor does District staff anticipate such sources in the future; and, WHEREAS, each DistrictVOC or NOx rule into the SIP must meet the RACT standard for air pollution control in order for the California Air Resources Board and EPA to approve the use of such rules forpurposes ofmeeting both the federal and state ambient air quality ozone standards as expeditiously

### as practicable; and, WHEREAS, on May 11,2006, the Ventura CountyAir Pollution Control Distnct ("District") published a notice of the public hearing on the draft2006ReasonablyAvadable Control Technology State Implementation Plan Revision (2006 RACT SIP) in a newspaper of general circulationwithin Ventura County; and, WHEREAS, the Ventura County Air Pollution Control Distnct held a public workshop on May 23, 2006, to discuss take public comments on the draA 2006 RACT SIP; and, WHEREAS, the Air Pollution Control Board (Board) held a public hearing on June 27, 2006, to accept public testimony on the draft 2006 RACT SIP; and, WHEREAS, the Board has considered the information and testimonypresented at the public hearing, written comments, and Districtresponses to those comments; 

### and, WHEREAS, the Board has reviewed the draft 2006 RACT SIP; and, WHEREAS, the 2006 RACT SIP is not a "project" as defined by CEQA Guidelines Section 15378 and accordingly is not subject to CEQA review pursuantto CEQA Guidelines Section 1506O(c)(3). NOW, THEREFORE BE ITRESOLVED, the Board adopts the draft 2006 RACT SIP as the final 2006 RACT SIP; and, 

### BE ITFURTHER RESOLVED, the Board finds that information and analyses presented in the final 2006 RACT SIP fulfills the requirements for RACT for a "moderate" ozone nonattainment area with regard to the eight-hour ozoneNAAQS in accordancewith the federal Clean Air Act; and, BE ITFURTHER RESOLVED, the Board directs staffto forward this Resolution and the final 2006 RACT SIP to the California Air Resources Board for transmittalto the U.S. Environmental ProtectionAgency by September 15,2006 as a revision to the California SIP for ozone; and, FINALLY, BE ITRESOLVED, that in the event the CaliforniaAir ResourcesBoard is unable to submit the final 2006 RACT SIP to the Environmental Protection Agency by September 15,2006,the Board authorizes staffto submit this Resolution, the final 2006 RACT SIP directlyto the U.S. Environmental ProtectionAgency. 2 Attachment 1

### APPROVEDAND ADOPTED this 

### June 27,2006. VENTURA COUNTY AIR POLLUTION CONTROL DISTRICT

Chair, Air Pollution Control Board

ATTEST: Clerk ofDistrictBoard

BY Deputy Clerk



### 3 Attachment 1

### Attachment 2

DRAFT 2006 REASONABLYAVAILABLE CONTROL TECHNOLOGY STATE IMPLEMENTATION PLAN REVISIONVENTURA COUNTY AIR POLLUTION CONTROL DISTRICT 2006 REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) STATE IMPLEMENTATION PLAN (SIP) REVISION JUNE 27,2006

BACKGROUND The federal Clean Air Act Amendments (CAAA) of 1990 gives the states primary responsibility for achieving the national ambient air quality standards (NAAQS). The NAAQS are set by the U.S. Environmental Protection Agency (EPA) as the maximum concentrations in the atmosphere for specific air contaminants to protect public health and welfare. The principal mechanism at the state and local level for complyingwith the CAAA is the State Implementation Plan (SIP). A SIP outlines the programs, actions, and commitments a state will cany out to implement its responsibilities under the CAAA. The EPA must approve all SIPS before they can be implemented by state and local governments. Once approved by the EPA, a SIP becomes a legally binding document under both state and federal law, and may be enforced by either government. Since its formation in 1968, the Ventura County Air Pollution Control District has prepared numerous air quality planning documents to meet state and federal clean air mandates. The most important of these are the air quality management plans (AQMPs) and related documents, such as the rate of progress (ROP) plans. These documents outline the District's long-range strategy for providing clean, healthful air to the citizens and businesses of Ventura County and, once approved by EPA, become components of the California SIP. A central component of Ventura County's AQMPs is the stationary source control measures. Stationary source control measures are techniques and equipment for reducing ozone precursor emissions, reactive organic compounds (ROC), and nitrogen oxides (NOx) from stationary sources in the county. Examples of stationary source control measures include gasoline station vapor recovery systems, landfill gas recovery systems, and catalytic emission control systems on various combustion devices. Stationary source control measures provide the framework from which enforceable rules are developed that reduce harmful air emissions. The District's rules apply to many activities including open burning, incineration, gasoline storage, paint solvent use, dry cleaning, screen printing, asphalt paving, chrome platmg, fuel combustion,and landfills. The AQMPs are not one-time documents, but periodically are updated and revised in accordance with changes in governing law and air pollution control science and technology. Moreover, each successiveAQMP builds on its predecessor. The last major Ventura County AQMP was the 1994 AQMP. It was prepared to satis@ several requirements of the CAAA and the California Clean Air Act of 1988 pertaining to attainment of the federal and state one-hour ozone standards, respectively. That plan was followed by the 1995 AQMP Revision, the 1997 AQMP Revision, and the 2004 AQMP Revision.

Attachment 22006 

### RACT SIP June 27,2006 Page 2 of 26 The 1995 AQMP Revision updated information, control measures, and air quality modeling that had changed since the 1994 AQMP. The 1997 AQMP Revision updated proposed adoption and implementation dates of several control measures in the 1995 AQMP Revision. The 2004 AQMP Revision updated the on-road motor vehicle emissions forecasts. The CAAA require that states achieve the NAAQS by specified dates, based on the severity of an area's air quality problem. Ventura County is currently designated a moderate ozone nonattainment area for the new federal 8-hour ozone standard, which replaced the federal one-hour ozone standard. As a moderate nonattainment area, Ventura County is required by the CAAA to attain the federal 8- hour ozone standard by June 15, 2010. The 2007 Ventura County AQMP is being developed to meet this new, more stringent federal clean air mandate. Sections 182(b)(2) and 182(f) of the federal Clean Air Act (42 U.S.C. 57511a) require ozone nonattainment areas to implement reasonably available control technology (RACT) for sources that are subject to Control Techniques Guidelines (CTG) issued by EPA and for "major sources" of VOC and NOx, which are ozone precursors. RACT is defined 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 (44 FR 53762; September 17, 1979). RACT requirements are included in the Clean Air Act to assure that significant source categories at major sources of ozone precursor emissions are controlled to a "reasonable" extent, but not necessarily to the more stringent Best Available Control Technology (BACT) or "maximum achievable control technology" (MACT) levels expected for new or modified major stationary sources. CTGs define RACT for existing sources of air pollution. Emission sources covered by CTGs areknown as CTG sources. According to the EPA's Final Rule to Implement the 8-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 8-hour ozone RACT for all CTG categones and all major, non-CTG sources as a revision to their SIPS. RACT demonstrationscan be made with either a new RACT detenninat~on,and with final implementation dates no later than the first ozone season that occurs thirty months (30) later; or by a certification that previously required RACT controls represent RACT for the 8-hour ozone standard. Alternatively, air pollution control agencies in nonattainment areas may adopt "negative declarations" documenting that the area has no stationary sources subjectto RACT requirements. Air pollution control agencies in nonattainment areas may rely on previous analyses prepared for the one-hour ozone plans and EPA guidance documents. The RACT SIP submittal is in addition to the area's 8-hour ozone attainment demonstration plan, which is also a SIP submittal. The RACT SIP must be submittedto EPA by September 15,2006.

Attachment 2I 2006 

### RACT SIP June 27,2006 Page 3of 26



### DISTRICT'S RACT SIP EVALUATION INTRODUCTION EPA Headquarters released official guidance for preparing RACT SIPs on May 18, 2006. The guidance is in a question and answer format and IS titled Questzons Related to 

### RACT in 8-hour Ozone Implementation (May 18,2006). In addition, EPA Region 9 has provided a basic framework for the RACT SIPs. That framework was contained in a letter (March 9,2006) from EPA Region 9 to the California Air Resources Board (CARB) and is presented below: Describe efforts to identify all source categories within the District requiring RACT, including CTG sources (i.e., covered by an EPA Control Techniques Guideline document) and major non-CTG sources. Submit negative declarations where there are no facilities (major or minor) within the District subject to a CTG. For all categories needing RACT, list the statellocal regulation that implements RACT. It may also be helpful to list the date EPA approved these regulations as fulfillingRACT. Describe the basis for concluding that the regulations fulfill RACT. Documents useful in establishing RACT include CTGs, Alternative Control Techniques guidance (ACT), Maximum Achievable Control Technology (MACT) standards, New Source Performance Standards (NSPS), California Suggested Control Measures (SCM) and RACTIBest Available Retrofit Control Technology (BARCT) determinations, regulations adopted in other Districts, and guidance and rules developed by other state and local agencies. Some Districts may use the California Air Pollution Control Officers Association (CAPCOA) September 2003 Potential All Feasible Measures (AFM) Report to help demonstrate RACT. If so, the RACT SIP should certifl that local regulations are equivalent to AFM, justify the assumption that the AFM fulfilled RACT in 2003, and include some sort of certification or demonstration that no additional controls have become more reasonably available since then. DETERMINATIONOF RACT SIP CTG Sources The EPA has issued CTGs defining RACT for existing facilities that emit air pollutants. Emissions sources covered by CTGs are referred to as CTG sources. EPA Headquarters included a list of source categories and applicable CTGs in their May 18,2006 RACT SIP Guidance. District staff reviewed that list and, for those source categories with a CTG, compared the sources covered by the CTG to each District rule. Table A-1 presents the source categories, reference documents, applicable District rules, and the date EPA approved the corresponding District rule. Table A-2 presents source categories without corresponding District rules. 

### In most such cases, there are no corresponding District rules because there are no sources in the county. This was determined through the District's permit system and emissions inventory

Attachment 22006 

### RACT 

### SIP June 27,2006 Page 4 of 26 systems, and knowledgeable staff of the District's permit and enforcement divisions. There is one source category listed in Table A-2 that is a special case: Agricultural Pesticides. Ventura County has a substantial agricultural industry and agricultural pesticide use is a substantial source of ROCs in the county. However, agricultural pesticide use is not defined 

### as a stationary source. Moreover, agricultural pesticide usage is regulated by the State of California and therefore not under the District's jurisdiction. 

### Maior Non-CTG Sources Sources not subject to CTGs, but for which RACT may still be required, are referred to as non-CTG sources. For this evaluation, District staff examined only non-CTG sources that have the potential to emit 25 tons or more per year of either NOx or VOC. Twenty-five tons per year is the District's current definition of "major source" in District Rule 26.1 (New Source Review). However, under EPA's 8-hour ozone regulations for moderate ozone nonattainment areas, the District's new source review threshold is 100tons per year of either ROC or NOx for major stationary sources. Table B lists all of the 25 tons per year or greater "major source'' facilities within Ventura County. There are 27 "major source" facilities in the District. Of those, only eight are 100 tons per year or greater major sources. Those are denoted with an asterisk. Table B gives each facility's permit number and facilityname. Moreover, Table B presents each District rule evaluated for the RACT SIP that applies to each facility with emphasis placed on those major sources of 100 tons per year or more. HOW DISTRICT RULES WERE DETERMINED TO MEET RACT REQUIREMENTS To determine if Distnct rules meet RACT requirements, District staff relied on the following criteria: District rules that have been approved by EPA are considered as fulfilling RACT requirements because EPA must evaluate the rules to determine if they fulfill RACT requirements, and EPA guidelines and policies. Therefore, any EPA SIP-approved District rules are said to have met RACT requirements. The California Clean Air Act (Health & Safety Code Section 39000 et seq.) requires air districts designated as serious and severe ozone nonattainment areas for the state ozone standard, which is more stringent that its federal counterpart, to apply RACT and Best Available Retrofit Control Technology (BARCT) to existing sources of ozone precursor emissions. This requirement applies to the District since the CARB has designated Ventura County a severe ozone non-attainment area for the state ozone standard. BARCT is 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 sources. To aid air disbxts in developing regulations to meet and maintain the state ambient an-quality standards, the CARB has developed a series of RACTfBARCT determinations for specific emission source types. These determinations also promote consistency of controls for similar emission sources among districts with the same air quality attainment designations. BARCT is widely recognized to exceed RACT.

Attachment 22006 

### RACT SIP June 27,2006 Page 5 of 26 

### The District routinely implements BARCT through its rule development, enforcement, and permit review programs. District staffperforms assessments of BARCT when proposing new rules or rule revisions and the CARB reviews District rules and proposed rule revisions to ensurethat BARCT standards are implemented. Finally, District staff evaluates existing sources during the annual permit review process to ensure that all existing rule requirements are being met. As part of the District's CAAA Section 105 grant objectives, the District has committed to adopt rules to implement all applicable RACTIBARCT determinations and rules to implement control measures in the District's 2004 Triennial Plan Assessment and Update - All Feasible Measures Analyses 

### that was prepared to satisfl requirements of the California Clean Air Act. For that analysis, District staff assessed District rules by comparing them to the Most Stringent All Feasible Measures List 

### contained in the CAPCOA Rules Subcommittee Potential All Feasible Measures Report. 

### Moreover, copies of all draft and proposed rules and all notices of workshops 

### and hearings are sent to EPA Region 9 

### on 

### an ongoing basis. The District also submits a 12-month rulemaking schedule each quarter to EPA Region 

### 9. This schedule contains the status of all new or revised rules, planned or in progress, including tentative and final workshop dates. Lastly, the District submits quarterly status reports on the District's Section 105 grant objectivesto EPA Region 9. 

### District staff reviews the corresponding requirements of CTGs, ACTs, federal New Source Performance Standards (NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAPS), and MACT standards for the applicable source category as part of the rule development process. Since the District has been a state and federal ozone nonattainment area for many years, CTG or ACT emission limits tend to be less stringent than current Districtrulerequirements. In 

### addition to the EPA finding that a rule fulfills RACT when submitted for inclusion in a state's SIP, the California state law requires District staff to perform analyses for each rule similar to a RACT evaluation. Each District rule adopted by the District is evaluated against applicable CTGs and ACTs, as well as against current California rules and regulations, and found to fulfill RACT for the applicable source category at that time. When adopted or modified, rule provisions are also compared against the California "all feasible measures" requirements. District Rule 26, New Source Review, specifies requirements for new, replacement, modified or relocated emissions units in Ventura County. It requires that such units be constructed using Best Available Control Technology (BACT) if they may emit increased amounts of ROC or NOx. BACT is an emission limitation based on the maximum degree of emission reduction (considering energy, environmental, and economic impacts) achievable through application of production processes and available methods, systems, and techniques. BACT does not permit emissions in excess of those allowed under any applicable federal Clean Air Act provision. BACT requirements in California are also widely recognized to exceed RACT. RACT SIP EVALUATION FINDINGS 

### Table C presents all of the Districtrules District staff evaluated for the RACT SIP. Given for each rule is the rule name, whether there is a

Attachment 22006 

### RACT 

### SIP June 27,2006 Page 6of 26 corresponding CTG or ACT that appears applicable to each rule, original rule adoption date, date of last rule amendment, Federal Register citation for EPA approval, and the corresponding Federal Register publication date. Table 

### D presents summaries of the RACT evaluations for those District rules covered by a CTG or ACT. Table D does not include Distnct rules for which there are no corresponding CTGs or ACTS. Table D includes the basis for concluding that each District rule evaluated for RACT meets or exceeds RACT. District staff found that EPA rule approvals certified that District rules meet RACT and that the EPA RACT certifications are still valid. In many cases, the EPA RACT certification findings were augmented by corresponding ARB RACTIBARCT determinations, which tend to be more current and stringent than RACT. Therefore, in addition to the EPA rule approvals, District concluded that the RACTIBARCT determinations were an appropriate basis for findingthat District rules meet RACT. Furthermore, as recommended by EPA in their June 5,2006 comments on the RACT SIP, staff reevaluated several rules that were adopted many years ago, and have not been revised since, to ensure that they still meet RACT. Those rules are listed in the District's June 14,2006 response to EPA's June 5,2006 comment letter (Attachment 

### 3 to the Air Pollution Control Board letter 

### - Public Comments and District Responses to Comments). The District's reevaluation of those rules indicates that either the District no longer has sources subject to the rules, or the rules stillmeet RACT. Distnct staff did not rely on the District's "all feasible measures" analysis outlined above for the RACT SIP analyses. However, the District's periodic "all feasible measures" analysis was mentioned because it is a mechanism that helps to keep District rules current with similar rules in other California air districts. CTG Sources There are several CTG source categories for which there are no sources in Ventura County. This was determined through the District's permit system and emissions inventory systems, and knowledgeable staffof the District's permit and enforcement divisions. These sources are indicated in Table A-2 under the column titled "Ventura County Sources." Moreover, the District does not anticipate these sources in the future. Therefore, RACT determinationsfor those CTG source categories are not necessary and the District concludes that RACT rules for these sources are not applicable. If such sources locate in the county in the future, they will be subject to the District's NSR requirements, which are more stringent than RACT. This constitutes the District's negative declarations for the sources listed in Table A-2. Ma-iorNon-CTG Sources District staff evaluated all facilities with the potential-to-emit of 25 tons per year of 

### NOx or VOC, the District's current major source threshold under Rule 26, New Source Review. Those facilities are listed in Table 

### B, along with applicable District rules. Of those, only eight are 100 tons per year or greater sources, the NSR threshold for moderate 8-hour ozone nonattainment areas. Those sources are denoted with an asterisk. The evaluation considered all sources listed in Table B, but focused on the 100 tons per year or greater sources. District rules cover all of

Attachment 22006 

### RACT SIP June 27,2006 Page 7of 26 

### the processes at the facilities in Table B, including those of 100 tons per year or greater. Some of the facilities listed in Table B have undergone modifications, which made them subject to even more stringent BACT requirements under District Rule 26, New Source Review. Therefore, all of the major non-CTG VOC and NOx sources are subject to District rules, which meet or exceed RACT. SUMMARY AND CONCLUSIONS District staff started its RACT SIP evaluation by reviewing all availableCTGs and ACTS and compared them 

### to District rules and sources. For each source category, District staff identified applicable sources and District rules. This was accomplished through the District's permit system and emissions inventory systems, and knowledgeable staff of the District's permit and enforcement divisions. There are twenty-eight (28) major stationary sources in the District under the District's current major source threshold. Of those, only eight (8) are 100tons per year or greater major sources, which are composed of four (4) ROG sources, and four (4) NOx sources. Following identification of District rules to be evaluated for the RACT SIP, 

### District staff made determinations as to whether the rules meet RACT. The determinations were based on: 1) 

### EPA rule approval; and, 2) RACTIBARCT determinations issued by the California Air Resources Board. EPA rule approval is an appropriate basis for RACT findings because EPA must evaluate the rules to determine if they fulfill RACT requirements prior to approval. RACTBARCT determinations are an appropriate basis because they are more sttlngent than RACT and the District must implement RACTBARCT determinations as a requirement of the California Clean Air Act. Furthermore, as recommend by EPA in their June 5,2006 comments on the District's RACT SIP, staff reevaluated several rules that were adopted many years ago, and have not been revised since, to ensure that they still meet RACT. The District's reevaluation of those rules indicates that either the District no longer has sources subjectto the rules, or the rules still meet RACT. The reevaluations are contained in the District's response to EPA's comments on the RACT SIP (see Attachment 3 

### to the Air Pollution Control Board letter - 

### Public Comments and District Responses to Comments). Findinas 

## - CTG Sources 

### & Maior Non 

## - CTG Sources Based on the foregoing, District staff finds that all District rules that apply to ozone precursor emissions fulfill RACT requirements for the 8- hour ozone NAAQS. At a minimum, the rules meet RACT or, more commonly, significantly exceed RACT because they comply with more current and stringent control requirements of the California Clean Air Act. Moreover, District staff finds that all CTG sources and major non-CTG sources under its jurisdiction are controlled to RACT orbetter standards. RACT Findinas 

### - Negative Declarations The District has reviewed its permit and emissions inventory systems for its federal Clean Air Act Plan, and consulted with knowledgeable District staff, and has determined that there are no stationary sources or emitting facilities within the District for the CTG 

### categories listed in Table A-2. Moreover, the District does not anticipate these sources in the future. If such sources locate in the county in the future, they will be subject to the

Attachment 22006 

### RACT SIP June 27,2006 Page 8of 26 District's New Source Review requirements, which are more stringent than RACT. This constitutes the District's negative declarations for the 2006 RACT SIP. 

### CALIFORNIA ENVIRONMENTAL QUALINACT (CEQA) The 2006 RACT SIP Revision is an evaluation of current District air pollution rules and will not result in new or revised District rules or any physical change in the environment. Therefore, adoption of the proposed 2006 RACT SIP Revision is not a "Project" as defined in Section 15378(a) of the CEQA Guidelines and therefore is not subject to CEQA review pursuant to CEQA Guidelines Section 15060(c)(3).

Attachment 2

### Table 

### A-I 

# - Source Categories, CTGIACT List, and Applicable District Rules

Aerospace Manufacturlng and Rework Operations & Coating Operations

Refinishing

Cans, Coils, Paper. Fabrics, Automobiles, and Light DutyTrucks, Surface Coating of

Graph~c Arts Coating Operatrons at Aerospace Manufactunngand Rework Operatrons (EPA453lR-97-004, 12/97) 4b

Automob~le Body Refinishmg

Automobile Refin~sh~ng(EPA45013-88-009)

Control of Volatile Organlc Em~ss~ons from Exlstlng Stationary Sources - Volume II Surface Coatingof Cans, Coils, Paper, Fabncs, Automobiles, and Light-Duty Trucks (EPA45012-77-008, 5/77) Control of Volattle Organ~c Em~ss~ons from ~xlst~n~ StabonarySources, Volume Vlll Graphic Arts - Rotogravure and Flexography (EPA-45012-78-033, 12/78) 1 ga Offset L~thography(EPAsolvents use at aerospace manufactunng and rework operatrons ~ncluding contractors and subcontractors Supersedesthe applicable parts of the M~scellaneous Metal Part and Products CTG Does not apply to manufactunng or rework operat~ons involv~ng spacevehdes, rework operations performed on antique aerospace veh~cles or components, or research and development, quality control, laboratorytestlng, and electronic Darts and assembhes (except for
Applies to automob~le refin~shmg operat~ons

Applies to automob~le refin~shing operations

For fabnc and paper coating, appl~es to all coatings put on paper, fabric, or plasticfilm, and includesdecoratwe coatings on metalfo~l such as giftwap and packagng

b" """* 

## 1 Applies to graphic arts operations that use the flexograph~c and rotogravure pnntrng processes as appliedto both publication and packagmg pnnt~ng
AppKs to graphlc arts operations that use the offset lithoara~hlc ~nnt~na Drocess Aerospace Assembly and Component Manufactunng Operations Rule 74 12

### - Surface Coatmg of Metal Parts and Products

Motor Veh~cle and Mobile Equ~pment Coastmg 0 eratlons Rule74.18 - MotorVeh~cle and Mob~le Equipment Coasting 

# L

Fabnc and F~lm Coating Operat~ons

Rule 74 19

### - Graphic Arts
9 of 26 Attachment 2--- - - - - - -



### Table A-1 

# - Source Categories, CTGIACT List, and Applicable District Rules (cont'd)

Surface Coating of

Products, Surface Coating of Miscellaneous I For fabnc coatmg, applres to all types of coatrngs applled to fabncand any decora6veor protect~ve topcoat applred over vmyl coated fabnc or vlnyl sheets Does not apply to the appl~cation of vmyl plashsol to the fabnc For paper coatrngs, appl~es to all coatrngs put on paper, pressuresensltwe tapes regardless of substrate (e g ) paper fabnc or plasbc film), and relatedweb coatmg processes on plashfilm such as typewriter nbbons, photographrc film, or magnehctape. Also lncludes decorativecoatmgs
Control of Volatde Organlc I Apphes to surface coabng of metalfurniture by Em~ss~ons from ~xisth~ metalfurn~ture manufacturers Stationary Sources, Volume Ill. Surface Coabng of Metal Furniture (EPA-45012-77-032,

Em~ss~ons from Ewseng Stabonary Sources, Volume VI. Surface Coatmg of M~scellaneous Metal Parts and Products (EPA45012-78-015, 6/78) 14" spec~fic CTG documents (Speafic CTGs have been publ~shed for can, cod, automob~le and l~ght duty truck, metalfurn~ture, magnet we,and large appl~ances )

Sh~~bulldlna and S~ID Re~alr I Aml~es to coatinas and solvents usedfor bu~ld~na oimalntalnlng metal manne or fresh-water metai hulledvessel used for rn~l~tary or commerc~al operations, lncludlngself-propelled vessels and those towed by other craft (barges) Th~s definlhon ~ncludes, but IS not llmrtedto, all mrlltary vessels, commercial cargo and passenger (cruse) shlps, femes, barges, tankers, container sh~ps, patrol and pilot boats, and dredges Fabnc and FII~ Coabng Operatlons
I Rule 74 3 - Paper, 512911979 Fabnc and Film Coatlng Operatlons

Surface Coatmg of Metal Parts and Products

Surface Coatmg of Metal Parts and Products

Manne Coattng Operatlons

Pleasure Craft Coat~ng and Commerc~al Boatyard

1Oof 26 Attachment 2

### Table 

### A-I 

# - Source Categories, CTGlACT List, and Applicable District Rules (cont'd)

External Floating 1 Control of Volatile Organic RoofTanks,


## - 

# I Emlssronsfrom petroleum Petroleum Liquid Liqurd Storage In External Storage in Floating Roof Tanks (EPA-450- 

### 1 2178-047, 12178) 20'

Volatrle Oraan~c Lraurd Storage in ~loatrn~and FIX&! Roof - Tanks (EPA 453 R-94-001, 1/m\llC
Storage of Emiss~ons from Storage of Petroleum Liquids Petroleum L~qu~ds In Fixed ln Roof Tanks (EPA-45012-77- 036, 12177) 11'
In Floating and Frxed Roof Tanks (EPA-4531R-94-001, 150,000 liters (-40,000 gal or 950 bbls )storing petroleum lrqurds

%~lres to storaae vesselskth caDacltiesareater &in 150,000 lit& contalnlng petrheum lr&lds wth a true vapor pressuregreater than 10 5 KPa Exemptsfixed roof tanks wth capacities less than 1,600,000 lrters used to store produced crude or condensate pnor to lease custody transfer Apphes to storage tanks In all ~ndustnes, but pnmanly in the petroleum refineries, pipelrnes, chemrcal plants, liquid termrnals

ADplles to facrlltles enaaaed in the separatron of natural gas liqu~ds from celd gas and/or fractlon of the lrqu~ds into natural gas products, such as ethane, propane, butane and naturalgasolrne It is not applrcableto compressor stations, dehydratron unrts, sweetening unlts,field treatment, undergroundstoragefac~l~t~es, liquefied natural gas units and field gas gathenngsystems
Apphes to gasolme drspensmg rnto motor vehicles at gasolrne dispensing facilities
Applres to filling of gasolme storage tanks from gasolme tanker trucks of Reactwe Organrc Compound Llquid

011 Storage Tank Degassmg O~erations

of Reactwe Organ~c Compound Liquids

of Reactive Organtc Compound

011 Storage Tank Degassing

Componentsat C~de 011 and Natural Gas Product~on and Processmg Fac~l~ties NIA

912611989

912611989

120f 26 Attachment 2--- -- - - --- --



### Table A-1

# - Source Categories, CTGIACT List, and Applicable District Rules (cont'd)

Equipment, Leaks from

producing Systems, Wastewater Separators, and Process Unit Turnarounds

Synthetic Organ~c chemical ani Polymer Manufacturing Equipment, Equ~pment Leaks from m ~loatmg and FIX& Roof - Tanks (EPAl453 R-94-001, 1194) 11' Control of VOC Leaks from Petroleum Refinery Equipment (EPA-45012-78-036,6178) 16~

Control of RefinewVacuum Produungsystems, Wastewater Separators, and Process Un~t Tumarounds (EPA-45012-77-025, 10177) 5.

Control of VOC Fug~trve Emlss~ons from sykhebc Organ~c Chemlcal Polymer and Resm Manufactunng Equlpment (EPA-45013-83-006, 3/84) 27'

Tank Truck ~asollne Loadmg Terminals (EPA-45012-77-026, 12/77)6a Apphes to storage tanks In all ~ndustnes, but pnmar~ly In the petroleum refineries, p~pellnes, chem~cal plants, ltqurd term~nals Apphes to leaks equlpment such as pumps, compressors, flanges, valves and, pressure rehef devlces,

Appl~es to non-condensablesfrom vacuum producmgsystems, wastewater separators, and all pressurized process unlts

Apphes to leaks of processflu~ds (gaseous or I~qu~d) from plant equlpment such as pumps. compressors, ~n-hne process valves, pressure rel~ef devces, open-endedvalves, sampltng wnnectlons, flanges, agitators, and wollng towers

throughputs greater than 76,000 l~ters (20,077 gal Storage of ReachveOrganic Compound L~qulds Rule 74 7 - Fug~twe Emlss~ons of Reactwe Organ~c Compounds (ROC) at Petroleum Refinenes and Chem~cal Plants Rule 74 8

### - Refinery Vacuum Produung Systems. Wastewater Separators and Process Turnarounds Rule 74 7- Fugltlve Emmons of Reactwe Organ~c Compounds (ROC) at Petroleum Refinenes and Chemlcal Plants Rule 74 7 - Fug~twe Em~ss~ons of Reactlve Organ~c Compoundsat Petroleum Refinenes and Chem~cal Plants Rule 70 - Storage and Transfer of Gasohne

l30f26 Attachment 2

### Table A-I 

# - Source Categories, CTGlACT List, and Applicable District Rules (cont'd)

Gasoline, andVapor Gasol~ne Tank Trucks and 

### 4thvapor &llectlon systems and the vapor' ' Collection Systems Vapor CollectionSystems collecbon systems at bulk terrnlnals, bulk plants

Boilers

93-034, rev~sed 9/93) 3d the petroleum ~ndustry


# I Stationary Gas 

# I NOx Em~ss~ons from Stat~onary Applles to statlonary gas turblnes used In varlous Turbines Combustion Turb~nes (EPA- 

# I appl~cat~ons and operations


### I Reciprocating 

### I IC Engmes (EPA-453lR-93: 

### I combustion engines 

# I Internal Combustlon 032, 7193, updated 9100) 4O

Enaines 

# I I
I Statlonary Gas I NOx Em~ss~ons from Statlonary I Appl~es to statlonary gas turbmes - .. .

## - ~urbines- CombustionTurb~nesEPA453lR-93-007, 1/93) 2

## 6 and Transfer of effectwe (512412004) Gasol~ne 

# 1
7lll2004 

# 1

Power Generating 

# 1 1 1 (712011999) Equ~pment - Oxldes of N~trogen

Bolters, Steam Generatorsand 

# I I Process Heaters 

### 1 Rule 74 15 1- 1 511 111993 1 611312000 1 66 FR 51576-51578

Bollers, Steam Generators and Process Heaters 

### I Rule 74 15 1

### - 1 511 111993 

### 1 6/13/2000 

### 1 66 FR 51576-51578 Bo~lers, Steam Generators,and 

# I I (1011012000 Process Heaters I I I
Stat~onary Gas Turb~nes 

# I I

Stat~onary Internal Combustlon

l40f 26 Attachment 2

### Table A-1 

# - Source Categories, CTGIACT List, 

### and Applicable District Rules (cont'd)



## I 

## I Cutback Asphalt (EPA-45012- ( roadway pavlng 

## I 1 ( Cutback Asphalt 

## 1


# I from Large Petroleum Dry that consume 123.000 l~ters or more of petroleum Petroleum Solvent 

# I Cleaners. EPA-45013-82-009, 

# 1 solvent per year 

# I Cleanmg 

# I I I Ethylene Oxide

## - Sterilization and Aaratton

a Number corresponds to list of Pre 1990 CTGs found In Question#43 of RACTQs & As - Reasonably Available Control Technology (RACT). QuestionsandAnswers, EPA, May 18,2006 b Number corresponds to list of Post 1990 CTGs found in Quest~on #43 of RACTQs & As 

## - Reasonably Available ControlTechnology (RACT). Quest~ons andAnswers, EPA, May 18,2006 Number corresponds to l~st of VOC ACT Documents found in Question#43 of RACTQs & As 

### - Reasonably Available ControlTechnology (RACT). QuestionsandAnswers, EPA, May 18,2006 Number corresponds to list of NOx ACT Documentsfound in Quest~on #43 of RACTQs & As - Reasonably Available ControlTechnology (RACT): QuestionsandAnswers, EPA, May 18,2006

l50f26 Attachment 2 77-037, 12/77) lza Ethylene Oxlde Stenlizabon (~~~-45013-89-007, 3/89) 3C Apphes to ethylene ox~de used as a stenlantlfumlgant In production of rnedlcal wu~pment supplies. ~n m~scellaneous ter~l~zat~on Rule 62 6- Ethylene Oxide

### - Steril~zat~on and 711611991 NIA 59 FR 39690-39691 (81411994)

### Table A-2 

# - Source Categories and CTGlACT Listfor Which There Are 

### No Applicable District Rules

dutyTrucks, surface from Exlstlng ~tahonary Sources - surface coated n automohve and hght duty truck assembly Coating of Volume II Surface Coatmg of Cans, plants Does not apply to custom~zers, body shops or Corls, Paper, Fabncs,Automob~les, and other repalnters Llght-DutyTrucks (EPA-45012-77-008,


### 1 Business Machine ~~oahn~l~utomob~le Plashc Parts 

### I vehcles and busmess machlnes 

### 1 I

~abrics, ~utornbbiies, from Emst~ng ~tat~on&y Sources - plececan henorbasecoat and over varn~sh, two and and Light DutyTrucks, Volume ll Surface Coahng of Cans, three-plece can Intenor bodyspray, twopece can extenor Suhce Coating of Gods, Paper. Fabncs, Automob~les, end spray or roll coat, three piece can s~de seam spray, and L~ght-Duty Trucks (EPA-45012- and end seahng compound 

## 1 77-008, 5177) 3a 

### I For toll coatlng, appl~es to pnme and topcoator single coat ( No NI A

Surface Coating of- from Exlshng~tabonary Sources, Volume Vll Factory Surface of Flat Wood Panel~ng (EPA-45012-78-032,

Manufactunng (EPA-45013-92-013) ~ncludmg arch~tectural coatings, product coatingfor orlglnal equipment manufacturers,and speaal-purposecoahngs. Also appl~es to ink manufactunng, lncludmg letterpress inks, l~thograph~c and offset inks, gravure nks,and 

# I Surface Coating of from EashngStatlonarySources, 

# I cases. hds, panels and mtenorsupport parts of res~denhal 

# I Volume V Surface Coabng of Large and commemal washers, dryers, ranges, rehgerators. 

# I I

Apphances, EPA-45012-77-034,

- 

# I freezers, water heaters, d~shwasherg trash c6mpactors, alr cond~boners, and slmllar products 

# I

l60f 26 Attachment 2

### Table A-2

# - Source Categories and CTGlACT List for Which There Are No Applicable District Rules

coating for Insulation from ExistingStationary Sources, 

# I Volume IV Surface Coat~ng for Insulation of MagnetW~re(EPAI Petroleum Refineries I Control Techn~aues for VOC I Apphes to petroleum refinenes I No I NIA 1 

### 1 

### I Em~ss~ons from'~tationaw Sources 

### I
" 

### I 

### I I

Chemical 

# I Oxidation Processes In Synthetc Manufacturing Organic Chemical Manufacturing 

# I I (EPA-4531R-92-018, 12/92) 8'



## I Manufacturing 

## I Manufactunng (EPA-4_53/R-94-004. 

## I I I I NIA Synthetic Organic IControlof VOC Emlss~ons from kr
Industry(EPA-45013-84-015, 12/84)28= SOCMl Distillationand Reactor Processes(EPA-45014-91-031, 8/93) .b



### I I Manufactunng(EPA-4531R-94-037, 

### I I I I No

( ~anufacturini Plants ( Ac~d Manufacturin~ Plants (EPA- 

## 1 I 1 I No



### I - 

### I of Agricultural Pestic~des (EPA- 

### I I I Department of Pestmde Regulat~on 

### I NIA



# I Processes in SOCMl Oxidation Pmcesses In SOCMI (EPA- organ~c chemical manufacturing lndustry 

# I 4mn-aenr s 1 wad\ ma

l7of26 Attachment 2

### Table A-2 

# - Source Categories and CTGlACT List for Which There Are No Applicable District Rules (cont'dl

I 1 Batch Processes(EPA-453lR-93- 

### I gum andwood chemicals, cycllc crudes and ~ntermedrates,

### I I

pharmaceukal productscementrng, tread-end cementrng, bead drpprng, and green ubberTlres (EPA45012-78-030,

l8of26 Attachment 2

### Table A-2

# - Source Categories and CTGlACT List for Which There Are No Applicable District Rules

* Not Applicable a Number corresponds to list of Pre 1990 CTGs found In Quest~on #43 of RACTQs & As 

### - Reasonably Available Control Technology (RACT) Questions andAnswers, EPA, May 18,2006 b Number corresponds to list of Post 1990 CTGs found In Quest~on #43 of RACT Qs & As - ReasonablyAva~lable Control Technology (RACT) Questions andAnswers, EPA, May 18,2006 Number corresponds to list of VOC ACT Documents found in Question #43 of RACTQs &As- ReasonablyAvailable ControlTechnology (RACT). Questions andAnswers, EPA, May 18, 2006. Number corresponds to 1st of NOxACT Documents found In Question #43 of RACTQs &As

### - Reasonably Available ControlTechnology (RACT): Questions andAnswers, EPA, May 18,2006.

19of26 Attachment 2

### Table 

### B 

# - Major Sources in 

### Ventura County

00008'

00013* 00015' 00029' 00036 Vintage Petroleum. Inc

00053' 00061 00065' 00012 

### 1 Tenby lnc

1 00041' 1 Aera Energy, LLC I'IJIJI'IJIJIJIJIJImIJIJI MandalayGeneratmg Stabon Procter & Gamble Paper Products Imat~on Corp Paufic Custom Matenals, Inc J

Vintage Petroleum, Inc Southem Califomla Gas Company Ormond Beach Gen. Stabon 00082 00157 00214 00385

00997 01006 01207 J J

I 00990 I Aera Energy, LLC l~lmlJl~l~l~l~~JIJl~lJIJl J -- ConowPh~ll~ps Ventura Stabon Weyerhaeuser Company, Hueneme Mill E F Oxnard, LLC ConowPh~lhps Torrey Stahon

01210 01267 01338 J

J

Naval Base Ventura County Naval BaseVentura County Naval Base Ventura County J J

J

J

Paufic Rewvery Corporabon-Oxnard OLS Energy- Camanllo P W G~ll~brand Co , Inc 01395

- * 100tons per year or greater sources J

J J

J J J

J - - Sm Valley Landfill

01491 01492 01493 01494 07340

20 of 26 Attachment 2 J

J

J

J

J J J

J J Dos Cuadras Offshore Resources, LLC Dos Cuadras Offshore Resources, LLC J

J

J J J

J 01399

Platform Grace Platform Gall Toland Road Landfill J J

J J J J

J J J

J J J J

J

J J J

J VRSD Oxnard Landfill

J J J J

J J

J J J J

J J

J J 

### 1. J J J

J

J J J J J J

J J J

J J

J J

J J J

J J J J

J J J J J J

J

J J J J J J

J J

J J

J J

J

J J J

J J J J J J J 4 J J J/'

P /'

/' /'

/' /' /' /'

P

-
/' /'

/' /'

P /'

P /' P

/' /' /'

/* 

### I P P /'

/' 317 'samosa~ a~oqsgo se~pen3 soa 

### I Z~PCO a3Wuolleld

uollel~ Aauol sdllllc(d~ouo3 311 'WWO 3 3 Il!4Puel PeoN Puelol Ile9 uolleld E6PC0

/'

~8~00 PCZOO OPELO WPCO

- 311 'samosa~ a~oqwo se~pen3 soa llb~uel PJ~~XO ~SHA

P /' -

/' 16~10 66~10

/' 7 pp-p~ '~UI 'wna104ade6elu~

311 'A6Jau3eJ@V .ESOOO



# . CWOO

### Table B

# - Major Sources in Ventura County (cont'd)

00008* 00012 0001 3* 00015* Vlntage Petroleum, Inc Tenby lnc

00029" 00036 00041' Mandalay Generat~ng Station Procter & Gamble Paper Prods

00053" 00061 J J

lmatlon Corporat~on Paufic Custom Materials, Inc Aera Energy, LLC

00065* 

## 1 Onnond Beach Gen Stabon J

Vintage Petroleum, Inc Southern Callfomla Gas Company

00214 00385



### 1 01207" 

### 1 Naval BaseVentura Countv 

### l-l.l.l.l-lJIJIJl.l J

J J

J

00997 01006 J

J J 00082 

### 1 ConocoPh~il~~s Ventura Station

E F Oxnard, LLC ConocoPh~ll~ps Torrey Stabon J J J

J J J

Naval BaseVentura County

012% 01267 J J

J

J J

01338 01395 J

J

141. 141

J

Paafic ~ecovery Corporation-Oxnard OLS Energy- Camanllo

01399 01491 141

J

Naval BaseVentura County

P W G~ll~brand Co , Inc

01493 01494

* 100tons per year or greater sources J J

--

J J

VRSD Oxnard Landfill Dos Cuadras Offshore Resources, LLC

07340 

## 1 Toland Road Landfill

22 of 26 Attachment 2 J

J

J

Platform Grace Platform Gad J J J

J

J

J

SI~I Valley Landfill J J

J J J

J

J

J J J

-

J J

J

J J J J

-

J

J J J

J J J

### Table C

# - District Rules Evaluated for 

### RACT SIP

Electrical Power Generating Equipment Oxrdes of Nltrogen 

# I 59 62 6

63 67 69 - Em~ssions EthyleneOxlde 

### - Ster~l~zatron and Aerat~on Separationand Combust~on of

70 

## I Storage and Transfer of Gasollne 

## I Yes 

## 1 612511974 

## 1 1 1 I11 I2003 

## 1 (512412004)

71 3 

## I Compound ~lqhds Yes 

## 1 612011978 

## 1 611611992 

## 1 (81411994) 

### I Petroleum Sumps, Pits, Ponds, 

### I 1 59 FR 64330

Em~ssrons Vacuum Producing Devlcesa Asphalt Alr Blowlng 

### I Crude Oil Product~on and 71 .I 71 2 Yes Yes



### 1 59 FR 39690 No Yes No

Separation Storage of Reactwe Organlc Compound Liqulds Transfer of Or~anlc Reactrve

71 4 71 5

74 4 

## I Cutback Asphalt Yes 

## 1 611911979 

## 1 71511983 

## 1 (411711987) 

### 1 57 FR 10136 10/6/1969

711 1/91

74.2 74 3 51311972 512311972 512311972

No Yes

and Well Cellars Glycol Dehydrators

- 74 6 

## I Degreaslng Yes 

## 1 512911979 

## 1 1 1 I1

1

I2003 

### ( (1 012512005) 

### 1 70 FR 61561 711511997

711 1191

Architectural Coatmgs Paper, Fabrlc and Fllm Coatlng Operations

74.5 1 74.5 2

74 6.1 

## / Batch Loaded Vapor Degreasers 

## I Yes 

## I Fugrtive Emlssions of ROC at (712011999) 59 FR 38690 (81411994) 47 FR 26389 1 1 121I1 978 71511983 71511983

612011978 612011978

No No



## I I ~eiroleum Ref~neries and 

## I (611811982) 52 FR 12522 (411711987) 52 FR 12522 (411711987) 69 FR 29451

No Yes

Petroleum Solvent Dry Cleanlng Synthetrc Solvent Dry Cleanlng (Per~loroethylene)~ Surface Cleaning and 611611992 912611989

101411988 12/13/1994 (81411994) 58 FR 64157 (1

21611 993) 59 FR 39690

611911979 512911979

Yes Yes

74.7 

## I Chemrcal Plants (VOC) 61811993 1211311 994

Yes 

## - ~~sterns, Wastewater Separators, and Process Turnarounds Stationary InternalCombustron Englnes Components at Crude Oil & Natural Gas Producina & (1 211 411994) 61 FR 7706 (2/2911996) 69 FR 34 1 1

I1

312001 1211 011991

121411990 1

21411990



### I Refinery Vacuum Producrnn

Yes Yes
" 74 10 

## 1 Processing Facllity 

### ( Natural Gas-Flred Resldentlal

23 of 26 Attachment 2 (11212004) 60 FR 46535 (91711995) 52 FR 12522

Yes 74 11 

### 1 Water Heaters 1 2/411990 51911995

No (312411992) 57 FR 10136 (312411992) 70 FR 61 561

### Table C

# - District Rules Evaluated for 

### RACT SIP (cont'd)

74.11.1 601krs Yes 911411 999 911411 999 (1 2/20/2000) Surface Coat~ng of Metal Parts & 70 FR 61 561 74.12 Products Yes 1111911985 1 1 I11I2003 (1 012512005) Aerospace Assembly & Component Manufacturmg 70lFR 61 561 74.13 Operat~ons Yes 411 511986 1 1 I1

1I2003 (1 012512005) Polyester Resin Mater~al 71 FR 5172 74 14 Operat~ons Yes 1 1/24/1987 411212005 (21112006) Bo~lers, Steam Generators 61 FR 4887 74 15 Process Heaters Yes 312811989 11/8/1994 (21911996) Bolters, Steam Generators 66 FR 51576 74 15.1 Process Heaters Yes 511 1I1 993 611312000 (1 011012001) 64 FR 19277 74 16 O~lf~eld Drdling Operat~ons No 1/8/1991 1 I811 991 (412011999) 66 FR 48355 74.1 7 1 Mun~c~pal Sohd Waste Landfills No 311 011998 21911999 (912012001) Motor Vehicle and Mob~le 66 FR 20086 74 18 Equipment Coatrng Operat~ons Yes 112811992 911011 996 (411912001) 70 FR 61 561 74 19 Graphc Arts Yes 811 112002 1111 1I2003 (1012512005) 63 FR 44792 74.19 1 Screen Pr~nt~ng Operat~ons Yes 611 1 I1

996 1 1 I1

1I2003 (8121I1 998) 68 FR 67805 74 20 Adhes~ves and Sealants No 61811993 111 1I2005 (1 2/4/2003) 61 FR 7706 74.21 

## 1 Sem~conductor Manufacturmg No 

## 1 4/6/1993 

## 1 4/6/1993 

## 1 (212911996) 

### I Natural Gas-Fred. Central Fan- 

### I 

### 1 61 FR 18959 74 22 

## 1 Type Furnaces No 

## 1 11/9/1993 

## 1 11/9/1993 

### [ (413011996) 

### 1 

### I 68 FR 33018 74.23 

## 1 Statlonary Gas Turbmes Yes 

## 1 3/14/1995 

## 1 1/8/2002 

## 1 (61312003) 

### 1 70 FR 61561 74.24 Marine Coatmgs Operations Yes 31811994 1 1 I11 I2003 (1 012512005) Pleasure Craft Coatmg and 67 FR 5261 1 74.24 1 Commercial Boatyard Operat~ons Yes 1 1I1 011998 11812002 (811312002) 70 FR 46090 74 25 Restaurant Cookmg Operations No 1011212004 1011212004 (81912005) Crude 011 Storage Tank 61 FR 20145 74 26 Degassmg No 1I1811994 11 I811 994 (51611996) Gasoline & ROC L~qu~d Storage 61 FR 20145 74 27 Tank Degassing Operat~ons No 1 1 1811994 1 1 1811994 (51611996) I 

### I 1 

### 1 1 I 61 FR 7706 74 28 Asphalt Roofmg No 511011994 511011994 (212911996) 67 FR 46596 74 29 

### 1 Soil Decontammat~on Operations 

## 1 No 

## 1 1011011995 

## 1 I1812002 

## 1 (7/1612002) 1 70 FR 61561 

## 1 74 30 

## 1 Wood ProductsCoatmg Yes 

## 1 511 711994 

## 1 1 1 I11 I2003 

## 1 (1 012512005) 

### " No sources In Ventura County Not an ozone precursor

24 of 26 Attachment 2

### Table 

### D 

# - RACT SIP Summary

of N~trogen Em~ss~ons 

## 1 023 Ethylene Ox~de 

### - Ster~l~zation and Aerat~on 

### I EPA Approval 811 711 994; EPA-45013-82- Storage and Transfer of Gasolme . . 009 EPA Approval 5/24/2004, EPA-4501277- 035; EPA-4503-91-022a; Des~gn Criter~a for State IVapor Control systems - Gasoline Service Stations, EPA-45012-77- 026; EPA-45012-78-051, CARB RACTIBARCT Determination last updated 

## 1 311998 Storage of Reactwe Organic Compound L~qu~ds 

### I EPA Approval 12/6/1993, EPA-450-2178-
- 

## 1 047, EPA-453 R-94-00, EPA-453 R-94-001 Transfer of Organ~c Reactive Compound 

### I EPA Approval 8/4/94, EPA-45012-77-026; L~quids 

## I EPA-45012-78-051 Architectural Coatmgs 

### 1 EPA Approval 1/2/2004; CARB - 

## I RACTIBARCT Determinat~on last updated 1011998 Paper, Fabr~c and Film Coating Operat~ons EPA Approval 91711995, EPA-453 R-94- 054 Cutback Asphalt EPA Approval 411 711987 Petroleum Solvent Dry Cleanmg EPA Approval 312411992, EPA-45013-82- 009 Surface Clean~ng and Degreasing EPA Approval 1012512005; EPA-45012-77- 022; CARB RACTIBARCT Defermination last updated 1011998 Batch Loaded Vapor Degreasers EPA Approval 1012512005, EPA 450 3-89- 030; CARB RACTIBARCT Determinat~on last updated 1011998. Fug~twe Em~ss~ons of ROC at Petroleum EPA Approval 712511996, EPA-45012-77- Refineries and Chemical Plants (VOC) 025; EPA-45012-78-036, CARB RACTIBARCT Determinations last updated 1011998 RefineryVacuum Producing Systems EPA Approval 411 711 987; EPA-45012-77- Wastewater Separators and Process 025. Turnarounds Stationary Internal Combustion Engines EPA Approval 1012512002, EPA-453 R-93- - 032. Components at Crude 01 & Natural Gas EPA Approval 811911999, EPA-45012-83- Producmg & Processmg Fac~l~ty 007, CARB RACTIBARCT Determinat~on last updated 1011998 Large Water Heaters and Small Bo~lers EPA Approval 1212012000; EPA 453 R-94- 022 Surface Coatmg of Metal Parts & Products EPA Approval 1012512005, EPA-453lR97- 004, EPA-4501277-032; EPA-45012-78-015; CARB RACTIBARCT Determmat~on last updated 1 011998. Aerospace Assembly & Component EPA Approval 1012512005; EPA-453lR97- Manufacturma O~erations 004: CARB RACTIBARCT Determinat~on 

### -. 

## I lastupdated 1011 998 Polyester Resm O~erations 

### I EPA A~~roval 211 106. EPA-45013-83-006,

25 of 26 Attachment 2

### Table D 

# - RACT 

### SIP Summary (cont'd)

74.15 Boilers, Steam Generators Process Heaters

74 15 1 Bo~lers, Steam Generators Process Heaters

74 18 MotorVehcle and Mob~le Equ~pment Coatmg Operat~ons 74 19 Graphic Arts

I 

# 1 74 19.1 Screen PrmtingOperat~ons

I 74.23 Stationary Gas Turbmes 74 24 Marme Coatrngs Operations

74 24.1 Pleasure Craft Coat~ng and Commerc~al Boatyard Operat~ons 74 26 Crude 011 Storage Tank Degassing 74 30 Wood Products Coatmg 022, EPA-453 R-93-034, CARB RACTIBARCT Determ~nation last updated 1011998 EPA Approval 1011012001, EPA-453 R-94- 022, EPA-453 R-93-034; CARB RACTIBARCT Determmat~on last updated 1011998 EPA Approval 411912001, EPA-5403-88- 009; CTG EPA-453 R-94-054, CARB RACTIBARCT Determination 511995 EPA Approval 1012512005, EPA-45012-78- 033; EPA-453 R-94-054, CARB RACTIBARCT Determmat~on last updated 1011998 EPA Approval 8121198; EPA-45012-78-033: EPA-453 R-94-054 EPA Approval 6/3/2003; EPA-453 R-93- 007; EPA-453 R-93-007. EPA Approval 1012512005; EPA-453lR-94- 032; 61FR44050; CARB RACTIBARCT Determ~natlon last updated 10198 EPA Approval 811312002, CARB RACTIBARCT Determmatlonlast updated 1011998 EPA Approval 51611996. EPA Approval 1012512005; EPA-453lR-96- 007, CARB RACTIBARCT Determmat~on last u~dated 5/1998 

### * CARB RACTIBARCT Determ~nations are posted at htt~'llwww.arb.canovlss~slss~s.htm#RACTlBARCT EPA Approvals cert~fy that rules meet RACT All cert~fications contmue to be valid

26 of 26 Attachment 2Attachment 

### 3
PUBLIC COMMENTSAND DISTRICT RESPONSES TO COMMENTSVentura County 669 County Square Drwe tel 805/645-1400 Richard H. Baldwin Air Pollution Ventura, Cal~forn~a 93003 fox 805/645-1444 Air Pollution Control Officer Control District

June 16,2006 Andrew Steckel, Chief Rulemaking Office United States Environmental ProtectionAgency Region 

### IX 75 Hawthorne Street San Francisco, CA 

### 94 105
Dear Mr. Steckel, Thank you for your letter dated June 5,2006providing comments on the District's 8-hour Ozone Reasonably Avadable Control Technology - StateImplementation Plan (RACT SIP)Analysis. We have reviewed your comments and offer the followingresponses: 1. Comment Partzcularly where the last RACT determznatzon for speclJicsource categorzes occurred many years ago, the staffreport should reflectsome analyszs that RACT has not subsequently changed. At a mznzmum, we believe a short comparison of VCAPCD controls versus rules zn two or three other similar azr distrzcts is appropnate for each rule lzsted zn Enclosure (I)[Table 

### I - Rules needing further clarz$catzon that they still represent RACTfneededfor RACU. TheDzstrict should also certzfj,zt u not aware of any szgnzjkant changes in technology that affect the origznalRACT determznatzon. Response We have examined the list ofDistrict rules on Table 1, and have conducted analyses as recommended. Please see Attachment A for the analyses. It should be noted that we no longer have sources subjectto the several of the listed rules. This isnoted where appropriate on Attachment 

### A. 2. Comment In cases where theDistrict has relzed on the CalforniaAzr Pollution Control Oficers Associatzon (CAPCOA) September 2003 PotentialAll Feasible Measures (AFM)Report to help demonstrateRACK some explanatory text zs needed to justzfj, the assumption that theAFM fu@lled RACT m 2003 and include some sort ofcertz$catzon/demonstratzon that no addztional controls have become more reasonably available since then. Response We did not rely onthe CAPCOA September 2003 Potential All FeasibleMeasures Report to help demonstrateRACT We had planned to do so, but upon further evaluation,decided it would be best to base our evaluation on other cnteria. We mentioned 

### in the District's penodic "all feasiblemeasures" analyses in the RACT SIP Attachment 3A Steckel June 16 2006 Page 2 because it is one of severalmechmsms that help to keep District rules currentwith similar rules in other California air districts.
3. Comment VCAPCD's staff report, page 5, states that each adopted rule is evaluated against applicable CTGs and ACTS,as well as against current California rules and regulations. Rule provisions are also compared against the California "all feasible measures" requirements when adopted or modified. A brief discussion shouldbe added to this section to mherdescribe the analysis that is performed. It may be helpful to attach to the staffreport an example of a pnor rule analysis. Response As noted in the preceding response to Comment No. 

### 3, we did not rely on California's "all feasiblemeasures" requirement for our RACT SIP rule analyses.
4. Comment VCAPCD's staff report, Table A-2, lists CTG categones for which there are no corresponding District rules. Theprocedure VCAPCD used to verify that there are no sources within Districtboundaries for a given CTG source should be described in the negative declaration (e.g., searchofthe permits database, emission inventory, SIC Code, yellow pages etc.) Response Theprocedure the Districtused to verify that there are not sources with District boundaries for a given CTG source has been added to the RACT SIP as suggested. See CTG Sources on page 6 ofthe 2006 RACT SIP. 5. Comment VCAPCD's staffreport,page 3, indicated some sourcesmight be subject to CTGs, but there are no correspondingDistnct rules. VCAPCD explained that such sources are controlled to Best Available Control Technology (BACT) and are less than 25 tpy. Some CTGs apply tosources below the major source threshold. Enclosure (2)LTable2- CTG Source Categorres with noApplicable District Rule (YCAPCD TableA-2)J lzsts CTG categories for which there may be VCAPCDsources wrth no correspondingDistrict rule. To implement RACT as required for these sources, the District should eithersubmit 

### a RACTprohibitory rule or source-specijicSIP reviszons based on the permits. Response District staff conducted a more thorough evaluationofthe CTG categorieslisted in Table 2 and has determined that the there are no sourceswithn Districtboundaries subject to those CTGs. The 2006 RACT SIPhas been revised accordingly.

Attachment 3A. Steckel June 16 2006 Page 3 

### 6. Comment Page 

### 8 listsRule 74.18, Motor Vehicle Coating Operations, under the Graphic Arts CTG. Please verzfy this is correctly placed. 

### Response You are correct. Rule 74.18, Motor Vehicle Coating Operations, has been removed fiom Graphic Arts in Table A-1 onpage 8. 7. Comment Rule EPA 453R-94-022, Natural Gas-Fired Residential Water Heaters, is listed by YCAPCD under several tables in the staflreport. Residential Water Heaters is not a CTG category and can be removed. Other rules, such as Rule 62 

### 6 for Ethylene Oxide, and some NOx rules (Rules 59, 74.15),are covered under anAlternative Control Technology (ACT)and need only be analyzed for RACT

### zf VCAPCD has a major sources covered by the ACT. 

### Response District staff has reexamined the abovementioned District rules, plus several others, and agree that the rules are either not coveredby CTGs, or areNOx rules coveredby ACTS for which there are no major sourcesin Ventura County. Therefore, those rules have been removed fiom Table D -

### RACT SIP Summary.
We appreciate the time and effort you and your staff spent reviewingthis importantpublic policy document. TheDistrict's responsesto your commentswill be included 

### in the 2006 

### RACT 

### SIP submittal. The Ventura County Air Pollution Control Board will hold a public hearing on the 2006 RACT 

### SIPRevisions at 1 1:00 a.m. on June 27,2006, in the Ventura CountyBoard of Supervisors Hearing Room. If you have any questions, please call Chuck Thomas ofmy staffat (805) 645-1427. Sincerely,

/MICHAEL VILLEGAS Air Pollution Control Officer Attachment A: Clarification ofRules for the 2006 

### RACT SIP

Attachment 

### 3

### Attachment A Clarification of Rulesfor the 

### 2006 RACT SIP 1) Rule 59, 

### Electrical Power Generatinq Equipment

# - Oxides of Nitroaen Emissions Table 1 Electrical Power Generatmg Equipment Rules Comparison

VCAPCD Rule 59 

### - Electrical Power Generating Equipment -NOx Emissions SCAQMD Rule 1135, Emissions of NOx fi-omElectric Power Generating Systems S JVAPCD Rule 4306, Boilers, Steam Generators and Process Heaters

-Phase 3

ACT -EPA-453IR94-023 Utilitv Boilers 0.1 lb NOx per MW-HR

0.15 lb NOx per MW-HR system-wide including all boilers (utility and auxiliary)

"Enhanced option" effective 12/1/08=0.007 lb NOx per MM BTU (approx. 0.07 lb NOx per MW-HR, assuming a heat rate of 10,000 BTU per KW-HR). "Standard option" effective 6/1/07 =0.011 lb NOx per 

### MM BTU (approx. 0.11 lb NOx per MW-HR, assuming a heat rate of 10,000BTU per KW-HR). 0.05 to 0.1 lb per 

### MM BTU Wall-fired natural gas boiler with SCR AuxiliaryBoilers 0.04 lb NOx per MM BTU

0.15 lb NOx per MW-HR systemwide including all boilers (utility and auxiliary) Same limits as utility boilers, assuming auxiliaryboilers are rated higher than 20 MM BTU per HR as is the case for Ventura County power plants.

Total auxiliary boiler fbel input for Ventura Countypower plants is less than 0.2% oftotal fbel input. Therefore, a simulated "system wide" emission limit for Ventura County is insignificantly higher than 0.1 lb NOx per MW-HR, and more stringent than South Coast AQMD's 0.15 lb NOx per MW-HR system-wide limit (see Table 1 above). The South Coast rule also contains absolute emission caps expressed in terms ofpounds ofNOx per day, which are not in the Venturarule. Compliance isprobably achievedby curtailing power generation rather than using "reasonably available controltechnology." Therefore, absolute NOx emission caps are not "RACT." Because the San Joaquin Valley APCD "enhanced option" is optional and has a future effective date, it 1s does represent current RACT and therefore not yet appropriate for comparison until sources choosethat option.

1 Attachment 3Attachment 

### A Clarification of Rules for the 2006 RACT SIP (continued) Rule 59 represents RACT for Ventura Countybecause its emission limits are more stringent than the ACT and other California air district rules currently in effect. 2) Rule 62.6, Ethvlene Oxide 

## - Sterilization and Aeration This rule is covered under an Alternative Control Technology document (ACT) and need onlybe analyzed for RACT if there are major sourcesin the District. There are no major ethylene oxide sources in the District. A comparison to other ethylene oxide-applicable requirements follows. Rule 62.6 appliesto both commercial and non-commercial ethylene oxide stenlization operations. Rule 62.6 contains control requirements for commercial operationsthat are as stringentor more stringent than the requirements contained in EPA's National Emissions Standardsfor Hazardous Air Pollutants for Ethylene Oxide Commercial Sterilizationand Fumigation Operations (59 FR 62585). Rule 62.6 also contains control requirements for non-commercial operations (hospitals and veterinary clinics)use more than 4 pounds of ethylene oxide per year. Further, Rule 62.6 is equivalent to the California Air Resources Board's Air Toxic ControlMeasure for Ethylene Oxide Sterilization Operations. Therefore, Rule 62.6 meets or exceedsRACT requirements. Furthermore, there are no commercial sterilization or fumigation operations in Ventura County. 

### 3) Rule 

### 67. Vacuum Producing Devices The purpose of this rule is to limit VOC emissions from refinery vacuum producing devices and systems. Rule 67 limits VOC emissions to no more than three (3) pounds of ROC in any one hour fiom any vacuum producing devices or systems includinghot wells and accumulators, unless said discharge has been reduced by at least 90percent. Ths requirement is essentially the same as South Coast AQMD Rule 465, Refinery Vacuum Producing Devices or Systems, and San Joaquin Valley Air Pollution Control District Rule 4453, Refinery Vacuum Producing Devices or Systems. Therefore, Rule 67 meets or exceedsRACT Requirements. Furthermore, a searchofthe current permitted sources in Ventura County shows that there are no petroleum refineries operatingin the county. Any new petroleum refineries would be subject to Rule 26, New SourceReview, which would require both Best Available Control Technology and Emission Offsets. Therefore, this certifiesthat Ventura County has no petroleum refineries and a RACT analysis is not required. 4) Rule 71 .I, Crude Oil Production and Separation Rule 7 1.1 limits the emissionsofreactive organic compounds from the storage,production, and processing of crude oil and natural gas prior to custody transfer. Basically, this rule requires vapor recovery systems at crude oil production facilities and also requires that emissionsfrom produced natural gas be controlled. The currentvapor recoveryrequirements have been in effect for a number of years, at least since October 4, 1988. In October of 1990, the Environmental Protection Agency (EPA) Region 

### IX issued a SIP disapproval based on 2 Attachment 3

### Attachment A Clarification of Rulesfor the 

### 2006 RACT SIP (continued) rule deficiencies includingAir Pollution Control Officer discretion over approval ofrule exemptions and other enforceabilityissues. None of the rule requirementswere disapproved because ofReasonably Available Control Technology (RACT) requirements, and there is no federal Control Techniques Guideline (CTG) governing this source category. The last revision of this rule on June 16, 1992, corrected the EPA-identified rule deficiencies,and the rule was approved into the State ImplementationPlan on August 4, 1994 (59 FR 36690, 8/4/1994). This SIP approval indicated that EPA considered that the 1992adoption of Rule 71.1 as RACT at that time. Staff has recentlyreviewed the requirements, and our conclusion is that this rule still exceedsRACT requirements. Rule 71.1 requires vapor recoveryemission controls on crude oil storage tanks, produced water storagetanks and wash tanks. Vapor recovery systems are assumed to control 90 percent ofthe ROC emissions fi-omthese tanks. Oilfield operators may qualify for an exemption from vapor recoveryrequirements based on three established criteria outlined 

### in the rule. The three exemption levels are: (1) if the ROC content ofthe liquid is less than 5 milligrams per liter; (2) if the Reid vapor pressure is less than 0.5 psia; and, (3) if a Best Available Control Technology (BACT) cost analysis indicates that a vapor recovery installation on a tank exceeds $9per pound ofROC emissionreduced, based on a policy adopted by the Ventura CountyAir Pollution Control Board on December 20, 1988. District staffdid a search of all the oilfield permits to determine the numbers of oilfield tanks exempt fiom vapor recovery, 

### and the 

### criterion used to qualify for the vapor recovery exemption. There are 59 exempt oilfield tanks in the county. Ten ofthese tanks qualifyfor 

### an exemption because of low vapor pressure less than 0.5 psia, and eleven qualifybecause the ROC content of the produced water is less than 5 milligrams per liter. The remainder or 

### 38 exempt tanks qualify after a BACT cost analysis was performed. All of these demonstrated that the vapor recovery, although feasible, exceed the BACT cost-effectiveness of $9 per pound ofROC reduced. The requirements of Rule 71.1 fulfillRACT requirements because the ROC emissions are insignificant as shown by the low vapor pressure (< 0.5 psia) or low concentration (less than 5mg/l)or the required control equipment is too costly as determinedby the BACT cost analyses, which exceed $9per pound ofROC reduced. This BACT cost threshold is typicallyused to evaluatenew or modified sources subjectto Rule 26, New Source Review. Rule 7 1.1 exempts fi-omvapor recoveryrequirements only 59 of the more than 1,000 tanks permitted by the District, or less than six percent of the total. Moreover, the ROC emissions fi-omthese exempt tanks represent less than 0.5 percent ofthe total tank emissions. 

### 5) Rule 71.2. 

### Storaae of Reactive Orsanic Com~ound Liauid Rule 7 1.2limits the emissions ofROC fiom the storage ofROC liquids including crude oil after custody transfer. This rule contains ROC control requirements for large above-ground crude oil shipping tanks. This rule was last amended on September 26, 1989. The 1989 revision was adopted for the following reasons:

3 Attachment 3

### Attachment 

### A Clarification of Rulesfor the 

### 2006 RACT 

### SIP (continued) 1. Make the rule conformto EPA's Control Technology Guidelines (CTG).

2. Correct deficienciesbased on EPA's "Issues Relatingto VOC Regulations Cutpoints, Deficiencies, and Deviations" dated May 25, 1988. 3. Address concerns expressedby the Air Resources Board in July, 1983. 4. To increase the rule stringencyand extend applicabilityto tanks whose contentshave a Reid vapor pressure greater than 0.5 psia. New requirements in the 1989amendments even exceed the CTG requirements published by EPA in October of 1993. Examples include a requirement for "zero gap" secondaryseals, and a restriction on the use of shoe-mounted secondary seals. Moreover, EPA approved this version ofthe rule into the SIP on December 6, 1993 (58 FR 64157-64158), which was after the 1993 CTG was published. This SIP approval indicated that EPA considered that the 1989 adoption of Rule 71.2 as RACT at that time. Staff has recently reviewed the requirements, and our conclusionis that this rule still exceeds RACT requirements. District staff comparedthe requirements of VCAPCD Rule 71.2 with South Coast Air QualityManagement District (AQMD) Rule 1178, Further Reduction ofVOC Emissions from Storage Tanks at Petroleum Facilities,which was adopted on December 2 1,2001,to determine if RACT requirementshave changed since the CTG was published in 1993. The only significant requirement in South Coast AQMD Rule 11 78 not contained in Rule 71.2 is a new requirement to install a domed roof on all external floating roof storagetanks. A searchofpermitted sources Indicates there are eight floating roof tanks, five ofwhich have external floating roofs and three have mternal floatingroofs. District staffhas contacted Conservatek,a supplier of aluminum domed roof from Conroe, Texas to obtain cost informationfor a retrofit of an existingtank. The Conoco tank on Permit No. 387 was evaluated since it is the smallesttank with the largest ROC emissions, thus providing the most cost-effectiveexample. The installed price was quoted at $236,000 for the roof, and is shown on the following page. Staff contactedEd Muehlbacher, Program Supervisor for South Coast AQMD, to inquire about the implementationofRule 1178. Mr. Muehbacher indicated that a fire-suppression system costing about $100,000 shouldbe added to the total cost ofthe installation. One advantage of this system is that it can be installed without taking the tank out of service. A cost-effectiveness analysisfor retrofitting an existingtank with a dome roof is summarized in the Table 2 below:

4 Attachment 3

### Attachment 

### A Clarification of Rulesfor the 2006 RACT SIP (continued)

Table 2 Cost-Effectivenessfor Retrofitting External Floating Roof Tank with a Dome Capital Costs
Fire Suppression ~~eration~aintenance $5,000 Annualized Costs Dome $236,000

I Total $336,000( Total $59,698 Annual Emissions Reduced =4950 lbslvear Assume n = 10 yrs at 10% Capital Costs $54,684

Cost-Effectiveness=Annualized Cost I Annual EmissionsReduced $12 per pound ofROC Reduced The $12 per pound ofROC reduced exceeds the BACT cost-effectiveness of $9per pound of ROC reduced. Since BACT requirements, which are required for new sources, are always more stringent than RACT, hs new requirement for domes would be considered a requirement above and beyond RACT requirement. Thus, Rule 7 1.2 still exceeds RACT requirements for this source category. Moreover, South Coast AQMD Rule 1178contains an exemption from doming requirements for tanks containing crude oil (SectionJ.7), presumably based on a similar costeffectiveness calculation doneby South Coast district staff. 

### 6) Rule 71 

### 3, Transfer of Orqanic Reactive Compound Liquids The provisions of this rule applyto equipment used to transfer reactive organic compound (ROC) liquids with a Modified Reid vapor pressure 

### WVP)greaterthan or equal to 0.5 psia. The provisions of the rule do not apply to the transfer of gasolineor the transfer ofROC liquids via pipeline. The requirements of this rule are essentially the same as those of South Coast Rule 462, Organic Liquid Loading, and San Joaquin Rule 4624, Organic Liquid Loading. Therefore,this rule still meets RACT for applicable sources in Ventura County. 

### 7) Rule 74.3, 

### Paper, Fabric and Film Coatins Operations Rule 74.3 limits the emissionsofreactive organic compounds from the coating ofpaper, fabric or film substrates. 

### A search ofthe current permitted sources in Ventura County shows that only one source, Irnation, is subjectto this rule On September 7, 1995, the Environmental Protection Agency (EPA) adopted a Final Rule whlch incorporated the latest revision to Rule 74.3 (December 10, 1991) into the 

### SIP (60 FR 46535, 9/7/1995). This codirrns that Rule 74.3 met requirements from the federal Control Techniques Guideline (CTG) governing this source category, which is the "Control ofVolatile Organic EmissionsFrom Stationary Sources - Volume 11: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks" (EPA 

### - 45012-77-008)published in May 1977.

5 Attachment 3Attachment A Clarification of Rules for the 

### 2006 

### RACT SIP (continued) Moreover, the only sourceregulated by Rule 74 3, Irnation, is a Title V federally-regulated sourcethat underwent site-specificrulemaking, which led to the adoption of VCAPCD Rule 37, Project XL. Rule 37 was incorporated into the SIP by an EPA Final Rule on December 13, 1999 (64 FR 69404, 12/13/1999). This EPA rule review and adoption insures that applicable requirements from the CTG New Source Performance Standards (NSPS) have been met. The
I applicable NSPS, StandardsofPerformance for Magnetic Tape Coating Facilities,was adopted ! 

### i on October 3, 1988 (53 FR 38892, 10/3/1988) Since Rule 74.3 only applies to one source, Imation, that meets and exceeds the requirements of this rule, there is no need to compare the requirements of Rule 74.3 with other Distnct rule requirements. Any future sourcethat will be subject to this rule will have to meet Best Available Control Technology (BACT)requirements required under Rule 26, New SourceReview. 

### 8) Rule 74.4. Cutback Asphalt The limits ofthis rule are the same as South Coast AQMD Rule 1108,Cutback Asphalt and San Joaquin Rule 4641, Cutback, Slow Cure, and Emulsified Asphalt, Paving, and Maintenance Operations. This rule therefore still meets RACT. 

### 9) Rule 74.5.1, Petroleum Solvent Drv Cleaninq The CTG for petroleum solvent

### dry cleaners establishesemission limits for cleaners that consume more than 32,500 gallons ofpetroleum solvent per year. There are 23 petroleum solvent 

### dry cleaners in Ventura County The largest facility is permitted to consume approximately 680 gallons ofpetroleum solvent per year. There are no major petroleum solvent dry cleaning sources in the District. Therefore, no RACT analysisisrequired for this category. Rule 74.5.1 is compared to other petroleum solvent

### dry cleaning rules Table 3 below. Table 

### 3 Solvent Dry Cleaning Rules Comparison VCAPCD Rule 74.5.1, Petroleum SolventDry Cleaners 90%back-end control, or, for facilitiesthat operate a still 

### - overall emissions may not exceed 5% of dry weight of articles cleaned and for facilitiesthat do not operate a still overall emissions may not exceed 8% of dry weight of articles cleaned. Transfermachines are ~rohibited. Limit filtration wastes to 1.O% of

### dryweight of articles cleaned. Drain cadgesfor 24 hours, or 12hrs if subsequently dned in a container vented to a 90% efficient control device.

Drain cartridges for 24 hours.

6 Attachment 3Attachment A Clarification of Rules for the 2006 RACT SIP

SJVAPCD Rule 4672, Petroleum Solvent Dry Cleaning Operations

CTG -EPA-45013- 82-009 and EPA Model VOC Rules for RACT June 1992 (continued) Table 

### 3 (continued) Limit VOC emissions fiom solvent recovery dryers to 3.0% of dry weight of articles cleaned.

Limit VOC emissions to 3.5% of dry weight of articles cleaned. Limit filtration wastes to 1.O% of 

### dry weight of articles cleaned.

Limit filtration wastes to 1.O% of dry weight of articles cleaned. Drain cartridges for 24 hrs., or 12hrs. if subsequently dried in a container vented to a 90% efficient control device. Drain cartridges for 8 hours.

Rule 74.5.2. Svnthetic Solvent Dry Cleaninq All existing synthetic solvent dry cleaners in Ventura County use exempt solvents. Any new application for a synthetic solvent dry cleaner wishing to use a VOC solventwould be subjectto the BACT requirements of Rule 26, New SourceReview. Therefore, Rule 74.5.2 is not related to attainmentofthe 8-hour ozone standard because it does not regulate ozoneprecursors. A RACT analysisis necessary. Rule 74.7, Fugitive Emissions of Reactive Organic Compounds (ROC) at Petroleum Refineries Rule 74.7 limits the fugitive emissions (both gaseous and liquid leaks) ofreactive organic compounds (ROC) fiom componentsat petroleum refineries and chemical plants. Components includepumps, compressors,pressure relief devices, open-ended lines, agitators,valves, fittings, flanges, connections, diaphragms,hatches, and meters. Rule 74.7 controls fugitiveROC emissions by requiring an operator to establish a Leak Detection and Repair (LDAR) program. A search of the current permitted sources in Ventura County shows that only one source, Cook Composites & Polymers is subject to Rule 74.7. Facility-wide permitted ROC emissions from Cook Composites are limited to 12.96tons per year. One other facilityin the county, Rhodia, which produces silicone,is not subject to the rule because its processes are under vacuum, which means no leaks should occur. Also, there are no petroleum refineries operatingin Ventura County. The latest revision to Rule 74.7 was adopted on October 10, 1995,and incorporated requirements outlined in the RACT Guidance for an Enhanced Inspection and MaintenanceProgram for Controlling Leaks from Refineries and Chemical Plants, published by the Air Resources Board in December of 1993. On July 25, 1996, the EPA adopted a Final Rule which incorporated the latest revision to Rule 74.7 (October 10, 1995)into the SIP (61 FR 38571,712511996). This

Attachment 3Attachment 

### A Clarification of Rules for the 

### 2006 RACT 

### SIP (continued) confirmsthat Rule 74.7 met requirements from the federal Control Techniques Guideline (CTG) governing this source category, which is the "Control of Leaks from Petroleum Refinery Equipment (EPA-45012-78-036)published in June 1978, and met requirements from the state RACT Guidance document. Staff has recentlyreviewed the requirements, and our conclusion is that this rule still exceedsRACT requirements. The most recent Environmental Protection Agency (EPA) Alternative Control Technology (ACT) document for this sourcecategory is called "Petroleum Refinery Tier 2 BACT Analysis Report" and is dated January 16,2001. This ACT report references the National Emissions Standards for Hazardous Pollutants (NESHAP) adopted for Hazardous Organic Compounds, and is known as the HON. Although some of the leak thresholds defined by Rule 74.7 may be greater for some componentscompared to the Phase I1 and Phase 

### III federalHazardous Organic NESHAP (40 CFR 

### Part 63, Subpart H), Rule 74.7 is actually a more stringentregulation because it can be enforcedby inspectorswho have the authorityunder the rule to issue Notices of Violationswhen leaks are discovered by the use oftheir portable leak detectors. Under the federalHON, no such authority exists for inspectors to cite violators for leaking components found at the facility. The federal HON is strictlyenforcedby a review of operatorrecords. This is a critical difference which makes Rule 74.7 a more effective regulationbecause it provides an incentive for operators to carefully screen for and effectively repair leaks to avoid field enforcement actions. Existing leaks thresholds in Rule 74.7 are 1,000 ppm, as methane, for gaseous leaks and three dropsper minute for liquid leaks. Although the 500ppm gaseous leak threshold in the HON is a more stringent threshold, the lack of an adequate enforcement mechanism for inspectorsin the field makes the HON a less effective regulation in reducing hgitive ROC emissions. Rule 74.7 1s one of only two rules in the country that allow inspectors to issue Notices ofViolations for leaking components in the field. The other rule allowing this enforcement authonty is South Coast 

### AQMD Rule 1173. Since Rule 74.7 incorporates both the most recent federal CTG and state RACT guidance, and has the added feature of field-enforceable provisions, staff still considersthat this rule has exceeded currentRACT requirements. 74.8, Refinery Vacuum Producinq System, Wastewater Separators, and Process Turnarounds Rule 74.8 limits the emissionsofreactive organic compounds from three sources at petroleum refinenes. These three refinery sources include vacuumproducing systems,wastewater separators, and refinery process vessel depressurization during a process turnaround. A search of the current permitted sources in Ventura County shows that there are no petroleum refineries operatingin the county. Any new petroleum refineries would be subjectto Rule 26, New Source Review, which would require both Best AvailableControl Technologyand Emission Offsets. Therefore, this certifiesthat Ventura Countyhas no petroleum refinenes for this CTG Category, and a RACT analysis is not required.

8 Attachment 3

### Attachment A Clarification of Rules for the 2006 RACT SIP (continued) 13) Rule 74.1

### 5. Boilers. Steam Generators. and Process Heaters Rule 74.15 regulates liquid, solid and gas-fueled boilers with a rated heat input capacity of 5 million Btu per hour and larger. Boilersburning more than 9 billion Btu per year must comply with a 40 ppm NOx limit. Boilersburning less than 9 billion Btu per year must be periodically tuned. There is no CTG for these units. There are no major sources comprisedofuts subject to Rule 74.15 in the District. Therefore, a RACT analysis isnot necessary. 

### 14) Rule 74.26. Crude Oil Storaqe Tank Degassing Operations 

### & Rule 74.27. Gasoline and ROC Liquid Storage Tank Deqassinq Operations District Rules 74.26 and 74.27 restnct emissions ofreactive organic compounds (ROC)by prohibiting the venting ofROC vapors to the atmosphere from tanks used to store gasoline and other ROC-containing materials. When tanks are undergoing maintenance or being decommissioned, the rule requiresROC vapors to be treated rather than released to the air. The Districtreassessed Rule 74.27 in 2003 because Bay Area AQMD (BAAQMD) Rule 8-40 had the appearanceof a more stringent cleanliness standard for tanks. BAAQMD requires tanks to be degassed to 5,000ppm organiccompounds as compared to the 10,000ppm standard in VCAPCD Rule 74.27. The followingis the District's analysis of its tank degassing requirements as compared to the requirements in effect in BAAQMD Rule 8-40 and South Coast AQMD Rule 1149. District Rules 74.26 and 74.27 were compared to the most stnngent of California's air districttank degassing rules. The District staff's preliminaryreassessment identified the BAAQMD and South Coast AQMD rules as the most stringent in the state, and possiblymore stringentthan District rule requirements. Tank Cleanliness District Rules 74.26 and 74.27 require tanks to be degassed such that "the tank vapor concentration remazns at or below 10,OOOppm for at least one hour as demonstrated by measuring the vapor concentratron at least four tzmes at 15-mrnutezntervals. The monitorzng rnstrument used to measure the vapor concentrationshall meet the speclJicatzonsofEPA Method 21. The probe inlet ofthe monztorzng znstrument shall be located one foot above the bottom of the tank or one foot above the surface ofany sludge matenal on the bottom ofthe tank. For uprzght, cylzndrical aboveground tanks, theprobe znlet shall be 

### (I) located at least 2 feet away from the innersu@ace ofthe tank wall and (2) zfsamples are wzthdrawn from 

### a manhole, znserted in an opening ofno more than one inch diameter on a flexible or inflexiblematerzal that is impermeableto reactive organzc compound (ROC) vapors, secured over the manhole."

9 Attachment 3

### Attachment A Clarification of Rulesfor the 

### 2006 RACT SIP (continued) BAAQMD Rule 8-40 requires tanks to be degassed to 5,000pprn organic compounds as determined by EPA Method 25A. BAAQMD Rule 8-40 leaves the details of testing (shown above in italics) open to interpretation. Issues related to subsequent offgassing from interior tank walls and bottom sludge during the hour after degassing is complete, and air infiltrationduring testing, are not addressed by BAAQMD Rule 8-40. Because of the differencesin test methods and the lack of testing details in the BAAQMD rule, the two standards (5,000pprn vs. 10,000 ppm) as measured by two different test methods and sampling procedures cannot be compared. Notwithstanding the above inconsistencies, ifthe two standards (5,000 pprn vs. 10,000 ppm) are assumed to be comparable, District staff believes the small incremental increase in emission reductions is not likely to be achieved cost effectively. For example, if it is assumed that tank gasses are initially at saturation (25%), degassing a tank volume to 5,000pprn as compared to 10,000pprn represents additionalemission control of less than 2%, and less than 0.2 pounds per 1000 gallons of vapor controlled (for gasoline vapor). The additional time (and cost)needed to evacuate the tank sufficiently to lower the concentrationby an additional 50percent (fiom 10,000pprn in District Rules 74.26 and 74.27 as compared to 5,000pprn in BAAQMD Rule 8- 40) is significant, considering the large amount of dilution air infiltrationthat must occur to accomplish this 50percent reduction in concentration. South Coast AQMD Rule 1149requires 2.3 tank volumes of gasses to be withdrawn from the tank and treated regardless ofthe final concentration left in the tank. Based on data in the 11/8/94Distnct staffreport for adoption ofRules 74.26 and 74.27, between 7 and 13tank volumesmust be drawn from a tank being treated to bring the vapor concentrationdown to 10,000ppm. Therefore, South Coast Rule 1149is less stringent than Distnct Rules 74.26 and 74.27 in this respect. Based on the above discussion, District staff believes Rules 74.26 and 74.27 correctly specify feasible tank cleanliness, and does not propose to modify the District's tank cleanliness standard at this time. Furthermore, District staff believes any potential additional emissionreductions that might be achieved using a 5,000 pprn standard would be insignificant. Avvlicabilitv -Gasoline Tanks District Rule 74.27 applies to gasoline tanks larger than 5,000 gallons (both above- and underground). South Coast AQMD Rule 1149 appliesto underground gasoline tanks larger than 500 gallons 

### and above ground gasoline tanks larger than 19,815gallons. District permit files indicate there 

### are 26 underground tanks not regulated by Rule 74.27 that would be considered feasiblefor degassing regulation by the South Coast AQMD (i.e., tanks between 500 and 5000 gallons capacity). The combined capacityofthese 26 underground gasolinetanks is 72,000 gallons.

10 Attachment 3

### Attachment A Clarification of Rules for the 2006 RACT SIP 

### (continued) District permit files indicatethere are 12 above ground tanks regulated by Rule 74.27that would not be regulated by the South Coast AQMD rule (i.e., tanks between 5,000 and 19,815 gallons capacity). The combined capacityofthese 12 above-ground gasoline tanks is 117,000 gallons. Based on the above inventory ofunder- and above-ground gasoline tanks, and assumingthat under- and above-ground tanks are routinely cleaned on equivalent time schedules, the District rule turns out to be the more effective rule for the gasoline storagetank inventoryin Ventura County because its applicabilitythresholds capturemore tank capacitythan the South Coast AQMD rule if appliedto the Ventura County jurisdiction. Additionally, the infeasibility, based on cost-effectiveness, ofrequiring gasoline tanks smaller than 5,000 gallons to be degassed was set forth as follows in the 11/8/94Distnct staffreport for adoption of Rules 74 26 and 74.27: Tank degassing costs are $400 

### + $0.04per gallon ROC cost-effectivenessthreshold is $9.00 per pound ofROC emission reduced Gasoline vapors weigh 0.014pounds per gallon Control device efficiencyis 95% Therefore: $9.00/pound = $400

### + ($O.O4/nallon)(Volume) Volume = 5018 gallons (0.014

### pounds/gallon)(Volume)(0.95) According to one contractor, his current (2004)minimum charge is 3 to 4 hours at $175 per hour. This quote reinforces the rational for the 5,000 gallon threshold. Based on the above discussion, Rule 74.27 correctly specifies the gasolinetank size threshold for feasible air pollution control. Therefore District staffconcludes that Rule 74.27 meets RACT. Applicability -Crude Oil Storage Tanks Distnct Rule 74.26 applies to the followingvapor recovery equipped crude oil or produced water storage tanks: Tanks having a capacity of 2000 barrels (84,000 gallons), which store organiccompound liquids with a Reid vapor pressure of 3.4psi or more. Tanks greaterthan 2000 barrels capacity regardless of Reid vapor pressure (RVP). Floatingroof tank capacity is based on the vapor space that exists in the fully lowered roof position. Floatingroof tanks are regulated if such capacityis 2,000 barrels or more, regardless ofReid vapor pressure.

11 Attachment 3

### Attachment A Clarification of Rulesfor the 2006 RACT SIP (continued) South Coast AQMD Rule 1149 applies to: Above-ground tanks larger than l9,815 gallons (472 barrels) that store organic liquid with a Reid vapor pressure more than 3.9 psi. Above-ground tanks larger than 39,630 gallons (944 barrels) that store organic liquid with a Reid vapor pressuremore than 2.6 psi. If applied in Ventura County, the South Coast 

### AQMD Rule 1149 applicabilitythresholds would regulate the following additionaltanks: Tanks >472 bbl but 

### 5 944bbl having a RVP 

### 2 3.9 psi, and Tanks >944 bbl but 

### 5 2000 bbl having a RVP 

### 12.6 psi excludingtanks that are exactly 2000 bbl having a RVP 

### 2 3.4 psi Permittingrecords indicate there are 189 tanks in Ventura County meeting the above criteria. The volume-weighted averageRVP of the fluid in these tanks is 3.1 psi, and the total volume of these tanks is 192,830bbls or 8,098,860 gallons. Assuming an ROC vapor density of 0.004 lblgallon, control efficiency at 95%, and a tank cleaning frequency on average once every 10 years, use ofthe South Coat AQMD applicabilitythresholds would result in a potential for additionalemission reductionsof 1.6 tons per year. Staff obtained the followingcost estimatesfrom two tank degassing contractors $1,500 for a 500 bbl tank $2,500 for a 1000bbl tank $2,000 for a 500 bbl tank AssumingROC vapor density of 0.004 lblgallon and control efficiencyis 95%, the costeffectiveness for the above examples of 500bbl and 1,000 bbl tanks ranges from $1 6 to $25 per pound ofROC reduced. Using the same assumptions, a 2,000 bbl tank would be cost-effective to degas if the cost is less than $2,873 (The Ventura CountyAPCD Board has approved a costeffectiveness threshold is $9per pound ofROC reduced). Based on the above discussions, the Districtbelieves Rule 74.26 and Rule 74.27 still meet RACT for applicable sources in Ventura County.

12 Attachment 3