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 Control Board 

800 South Victoria Avenue 

Ventura, CA 93009 

SUBJECT: PUBLIC HEARING TO APPROVE THE 2006 REASONABLY 

A VAILABLE CONTROL TECHNOLOGY STATE IMPLEMENTATION 

PLAN RE VISION (2006 RACT SIP REVISION) 

RECOMMENDED ACTION: 

1. Approve District stafrs determination that the draft 2006 Reasonably Available 

Control Technology State Implementatzon Plan Revzszon is not a project subject to 

the California Environmental Quality Act (CEQA), pursuant to CEQA Guidelines 

Sectlon 15378(a). 

2. Approve, adopt, and authorize the Chair to sign a resolution (Attachment 1) 

adopting the draft 2006 Reasonably Available Control Technology State 

Implementation Plan Revision (Attachment 2) as the final 2006 Reasonably 

Available Control Technology State Implementation Plan Revuzon. 

3. Direct the clerk of the board to forward two certified minute orders and an 

affidavit of publication of the public hearing notlce for the proposed action to the 

Air Pollution Control District. 

4. Direct staff to forward the signed resolution and the final 2006 Reasonably 

Avazlable Control Technology State Implementatzon Plan Revzszon to the 

California Air Resources Board for transmittal to the U.S. Environmental 

Protection Agency as a proposed revision to the California State Implementation 

Plan for ozone 

FISCAL IMPACT: 

Mandatory: Yes 

Fiscal impacts: None 
2006 RACT SIP 

June 27,2006 

Page 2 

STATEMENT OF MATTER FOR BOARD CONSIDERATION: 

General Background 

The federal Clean Air Act Amendments (CAAA) of 1990 give 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 in order to protect public 

health and safety. 

CAAA Sections 182(b)(2) and 182(f) require ozone nonattainment areas to implement 

Reasonably Available Control Technology (RACT) for sources that are subject to EPA 

Control Techniques Guideline (CTG) documents and for "major sources" of ozone 

precursor emissions, or volatile organic compounds (VOCs) and oxides of nitrogen 

(NOx). 42 U.S.C. 751 la, subdivisions (b)(2) and (f). 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). CTGs are EPA documents that define 

RACT for existing sources of volatile organic compounds, which are precursors to 

ozone. Emission sources covered by CTGs are known as CTG sources. 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 Best Available Control Technology (BACT) or "maximum 

achievable control technology" (MACT) levels expected of new 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/existing RACT 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 demonstration plan, 

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 of the Draft 2006 RACT SIP Revision 

District staff started its 2006 RACT SIP Revision evaluation by reviewing all available 

CTGs and Alternative Control Technique (ACT) guidelines and comparing them to 

applicable Distnct rules and sources. For each source category, Distnct staff Identified 

applicable sources and corresponding District rules. 

Following identification of District rules to be evaluated for the 2006 RACT SIP 

Revision, District staff made determinations as to whether the rules meet RACT. The 

determinations were based on two criteria. 

(1) Local air pollution control rule approval by the U.S. Environmental Protection 

Agency; and, 

(2) RACTBARCT determinations issued by the California Air Resources Board. 

BARCT (Best Available Retrofit Control Technology) 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. 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 for ths analysis because they are more current 

and stringent than RACT. Moreover, the District must implement RACTBARCT 

determinations as a requirement of the 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 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 stnngent control requirements of the California Clean 

Air Act. 

District staff also found that all CTG sources and major, non-CTG sources under its 

jurisdiction are controlled to RACT or better standards. There are several CTG source 

categories (listed in Table A-2 of the draft 2006 RACT SIP) for which there are no 

sources within District boundaries. Moreover, the District does not anticipate these 

sources in the fbture. Therefore, District staff determined that negative declarations 

documenting that there are no sources in the county subject to those CTGs are 

appropriate. Moreover, any new sources would be subject to best available control 

technology (BACT) requirements, pursuant to the District's New Source Review (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 evaluation of current Distnct air pollution rules 

and will not result in new or revised District regulations or any physical change in the 

environment. Therefore, adoption of the proposed 2006 RACT SIP Revision is not a 

"Project" as described in Section 15378(a) of the 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 of the 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. If you have any questions, please contact Chuck Thomas at 645-1427. 

Air Pollution Control Officer 

Attachment 1 Resoluhon Approvmg and Adoptmg the 2006 Reasonably Avazlable Control Technology 

State Implementafton Plan Revzs~on 

Attachment 2 Draft 2006 Reasonably Avazlable Control Technology State Zmplementatzon Plan 

Revzszon 

Attachment 3 Public Comments and Distnct Responses to Comments 
Attachment 1 

RESOLUTION APPROVING AND ADOPTING THE 2006 REASONABLY 

AVAILABLE CONTROL TECHNOLOGY STATE IMPLEMENTATION PLAN 

RE MSION 
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 control plans, 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 expeditiously as 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) (relating to Marginal Areas), and to also submit revisions to the 

applicable SIP described under Section 182(b) (relating to Moderate Areas) for the purpose of 

showing progress towards the attainment of the ozone NAAQS; 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 Reasonably Available Control Technology (RACT) corrections; and, 

WHEREAS, Section 182(b)(2) of the federal Clean Air Act requires states with ozone 

nonattainment areas designated as "moderate" or greater to submit a revision to the State 

Implementation Plan for implementation of RACT under Section 172(c)(l) of the federal Clean 

Air Act; and, 

WHEREAS, the United States Environmental Protection Agency (EPA) promulgated, 

through Federal Register, Volume 70, page 71612 et seq., November 29,2005, the requirement 

that the State of California must 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 staff evaluated 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 controlled to RACT or better standards; and, 

1 

Attachment 1 
WHEREAS, District staff found that RACT analyses for the CTG sources listed in Table 

A-2 of the District's staff report 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 District VOC 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 for purposes of meeting both the federal and state ambient air quality ozone 

standards as expeditiously as practicable; and, 

WHEREAS, on May 1 1,2006, the Ventura County Air Pollution Control Distnct 

("District") published a notice of the public hearing on the draft 2006 Reasonably Avadable 

Control Technology State Implementation Plan Revision (2006 RACT SIP) in a newspaper of 

general circulation within 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 testimony presented at the 

public hearing, written comments, and District responses 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 pursuant to CEQA Guidelines 

Section 1506O(c)(3). 

NOW, THEREFORE BE IT RESOLVED, the Board adopts the draft 2006 RACT SIP 

as the final 2006 RACT SIP; and, 

BE IT FURTHER 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 ozone NAAQS in accordance with the federal 

Clean Air Act; and, 

BE IT FURTHER RESOLVED, the Board directs staff to forward this Resolution and 

the final 2006 RACT SIP to the California Air Resources Board for transmittal to the U.S. 

Environmental Protection Agency by September 15,2006 as a revision to the California SIP for 

ozone; and, 

FINALLY, BE IT RESOLVED, that in the event the California Air Resources Board is 

unable to submit the final 2006 RACT SIP to the Environmental Protection Agency by 

September 15,2006, the Board authorizes staff to submit this Resolution, the final 2006 RACT 

SIP directly to the U.S. Environmental Protection Agency. 

2 

Attachment 1 
APPROVED AND ADOPTED this June 27,2006. 

VENTURA COUNTY 

AIR POLLUTION CONTROL DISTRICT 

Chair, Air Pollution Control Board 

ATTEST: 

Clerk of District Board 

BY 

Deputy Clerk 

3 

Attachment 1 
Attachment 2 

DRAFT 2006 REASONABLYAVAILABLE CONTROL TECHNOLOGY STATE 

IMPLEMENTATION PLAN REVISION 
VENTURA 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 complying with 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 successive AQMP 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 2 
2006 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 

are known 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 demonstrations can 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 subject to 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 

submitted to EPA by September 15,2006. 

Attachment 2 
I 

2006 RACT SIP 

June 27,2006 

Page 3 of 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 

fulfilling RACT. 

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. 

DETERMINATION OF 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 2 
2006 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 100 tons 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 facility name. 

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 2 
2006 RACT SIP 

June 27,2006 

Page 5 of 26 

The District routinely implements BARCT 

through its rule development, enforcement, and 

permit review programs. District staff performs 

assessments of BARCT when proposing new 

rules or rule revisions and the CARB reviews 

District rules and proposed rule revisions to 

ensure that 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 

objectives to 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 District rule requirements. 

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 District rules District 

staff evaluated for the RACT SIP. Given for 

each rule is the rule name, whether there is a 

Attachment 2 
2006 RACT SIP 

June 27,2006 

Page 6 of 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 

finding that 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 still meet 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 staff of 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 

determinations for 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-ior Non-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 2 
2006 RACT SIP 

June 27,2006 

Page 7 of 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 available CTGs 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 100 tons 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 subject to 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 or better 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 2 
2006 RACT SIP 

June 27,2006 

Page 8 of 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 

QUALIN ACT (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 Duty Trucks, 

Surface Coating of 

Graph~c Arts 

Coating Operatrons at 

Aerospace Manufactunng and 

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 Coating of 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~ 

Stabonary Sources, 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 

Supersedes the applicable parts of the 

M~scellaneous Metal Part and Products CTG 

Does not apply to manufactunng or rework 

operat~ons involv~ng space vehdes, rework 

operations performed on antique aerospace 

veh~cles or components, or research and 

development, quality control, laboratory testlng, 

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 plastic film, and 

includes decoratwe coatings on metal fo~l such as 

gift wap and packagng 

b" 1 """* 

Applies to graphic arts operations that use the 

flexograph~c and rotogravure pnntrng processes 

as applied to 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 

Rule 74.18 - Motor Veh~cle and 

Mob~le Equipment L Coasting 

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 fabnc and any decora6ve or 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, pressure sensltwe tapes regardless of 

substrate (e g ) paper fabnc or plasbc film), and 

related web coatmg processes on plash film 

such as typewriter nbbons, photographrc film, or 

magnehc tape. Also lncludes decorative coatmgs 

Control of Volatde Organlc I Apphes to surface coabng of metal furniture by 

Em~ss~ons from ~xisth~ metal furn~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, metal furn~ture, magnet we, and large 

appl~ances )

Sh~~bulldlna and S~ID Re~alr I Aml~es to coatinas and solvents used for bu~ld~na 

oi malntalnlng metal manne or fresh-water metai 

hulled vessel used for rn~l~tary or commerc~al 

operations, lncludlng self-propelled vessels and 

those towed by other craft (barges) Th~s 

definlhon ~ncludes, but IS not llmrted to, 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 

Roof Tanks, 

- I Emlssrons from 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 caDaclties areater 

&in 150,000 lit& contalnlng petrheum lr&lds 

wth a true vapor pressure greater than 10 5 KPa 

Exempts fixed 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 natural gasolrne It 

is not applrcable to compressor stations, 

dehydratron unrts, sweetening unlts, field 

treatment, underground storage fac~l~t~es, liquefied 

natural gas units and field gas gathenng systems 

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 

Components at 

C~de 011 and 

Natural Gas 

Product~on and 

Processmg 

Fac~l~ties 

NIA 

912611 989 

912611 989 

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 Refinew Vacuum 

Produung systems, 

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-condensables from vacuum 

producmg systems, wastewater separators, and 

all pressurized process unlts 

Apphes to leaks of process flu~ds (gaseous or 

I~qu~d) from plant equlpment such as pumps. 

compressors, ~n-hne process valves, pressure 

rel~ef devces, open-ended valves, sampltng 

wnnectlons, flanges, agitators, and wollng 

towers 

throughputs greater than 76,000 l~ters (20,077 

gal 

Storage of 

Reachve Organic 

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 

Compounds at 

Petroleum 

Refinenes and 

Chem~cal Plants 

Rule 70 - Storage 

and Transfer of 

Gasohne 

l30f 26 

Attachment 2 
Table A-I - Source Categories, CTGlACT List, and Applicable District Rules (cont'd) 

Gasoline, and Vapor Gasol~ne Tank Trucks and 4th vapor &llectlon systems and the vapor' ' 

Collection Systems Vapor Collection Systems 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- Com bustion Turb~nes EPA453lR-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 

Generators and I I 

Process Heaters 1 

Rule 74 15 1 - 1 511 111993 1 611 312000 1 66 FR 51 576-51578 

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 (1011 012000 

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 RACT Qs & As - Reasonably Available Control Technology (RACT). 

Questions and Answers, EPA, May 18,2006 

b Number corresponds to list of Post 1990 CTGs found in Quest~on #43 of RACT Qs & As - Reasonably Available Control Technology (RACT). 

Quest~ons and Answers, EPA, May 18,2006 

Number corresponds to l~st of VOC ACT Documents found in Question #43 of RACT Qs & As - Reasonably Available Control Technology (RACT). 

Questions and Answers, EPA, May 18,2006 

Number corresponds to list of NOx ACT Documents found in Quest~on #43 of RACT Qs & As - Reasonably Available Control Technology (RACT): 

Questions and Answers, EPA, May 18,2006 

l50f 26 

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~scellaneouster~l~zat~on 

Rule 62 6 - Ethylene Oxide - 

Steril~zat~on and 

711 611 991 NIA 59 FR 39690-39691 

(81411 994) 
Table A-2 - Source Categories and CTGlACT List for Which There Are No Applicable District Rules 

duty Trucks, 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-Duty Trucks (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 - plece can henor basecoat and over varn~sh, two and 

and Light Duty Trucks, Volume ll Surface Coahng of Cans, three-plece can Intenor body spray, 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 topcoat or 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 coating for orlglnal 

equipment manufacturers, and speaal-purpose coahngs. 

Also appl~es to ink manufactunng, lncludmg letterpress 

inks, l~thograph~c and offset inks, gravure nks, and 

I Surface Coating of from Eashng Statlonary Sources, I cases. hds, panels and mtenor support 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 Existing Stationary Sources, I Volume IV Surface Coat~ng for 

Insulation of Magnet W~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 

Synthetic Organic NIA IControl of VOC Emlss~ons from kr 

Industry (EPA-45013-84-015, 12/84) 28= 

SOCMl Distillation and 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 

l7of 26 

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 and wood chemicals, cycllc crudes and ~ntermedrates, I I 

pharmaceukal productscementrng, tread-end cementrng, bead drpprng, and green 

ubber Tlres (EPA45012-78-030, 

l8of 26 

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 RACT Qs & As - Reasonably Available Control Technology (RACT) 

Questions and Answers, EPA, May 18,2006 

b Number corresponds to list of Post 1990 CTGs found In Quest~on #43 of RACT Qs & As - Reasonably Ava~lable Control Technology (RACT) 

Questions and Answers, EPA, May 18,2006 

Number corresponds to list of VOC ACT Documents found in Question #43 of RACT Qs &As - Reasonably Available Control Technology (RACT). 

Questions and Answers, EPA, May 18, 2006. 

Number corresponds to 1st of NOx ACT Documents found In Question #43 of RACT Qs &As - Reasonably Available Control Technology (RACT): 

Questions and Answers, EPA, May 18,2006. 

19of 26 

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 

Mandalay Generatmg 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~

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 Base Ventura County 

Naval Base Ventura County 

J 

J 

J 

J 

Paufic Rewvery Corporabon-Oxnard 

OLS Energy - Camanllo 

P W G~ll~brand Co , Inc 

01395 

- 

* 100 tons 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 

/' 

/' 

/' 

P /* I P 

/' 

/' 

317 'samosa~ a~oqsgo se~pen3 soa I Z~PCO 

a3W uolleld 

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 'wna104ad e6elu~ 

311 'A6Jau3 eJ@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 Base Ventura 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 Base Ventura 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 Base Ventura County 

P W G~ll~brand Co , Inc 

01493 

01494 

* 100 tons 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 

Ethylene Oxlde - Ster~l~zatron and 

Aerat~on 

Separation and Combust~on of 

70 I Storage and Transfer of Gasollne I Yes 1 612511 974 1 1 1 I1 1 I2003 1 (512412004) 

71 3 I Compound ~lqhds Yes 1 612011 978 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 611911 979 1 71511983 1 (411 711987) 

1 57 FR 10136 

10/6/1969 

711 1/91 

74.2 

74 3 

51311 972 

512311 972 

512311 972 

No 

Yes 

and Well Cellars 

Glycol Dehydrators 

- 

74 6 I Degreaslng Yes 1 512911 979 1 1 1 I1 1 I2003 ( (1 012512005) 

1 70 FR 61 561 

711 511997 

711 1 191 

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 

(712011 999) 

59 FR 38690 

(81411 994) 

47 FR 26389 

1 1 121 I1 978 

71511 983 

71511 983 

612011 978 

612011 978 

No 

No 

I I ~eiroleum Ref~neries and I 

(611 811 982) 

52 FR 12522 

(411 711 987) 

52 FR 12522 

(411 711 987) 

69 FR 29451 

No 

Yes 

Petroleum Solvent Dry Cleanlng 

Synthetrc Solvent Dry Cleanlng 

(Per~loroethylene)~ 

Surface Cleaning and 

611 611 992 

912611 989 

101411988 

12/13/1994 

(81411 994) 

58 FR 641 57 

(1 21611 993) 

59 FR 39690 

611 911 979 

512911 979 

Yes 

Yes 

74.7 I Chemrcal Plants (VOC) 

61811 993 

1211 311 994 

Yes 

- 

~~sterns, Wastewater 

Separators, and Process 

Turnarounds 

Stationary Internal Combustron 

Englnes 

Components at Crude Oil & 

Natural Gas Producina & 

(1 211 411 994) 

61 FR 7706 

(2/2911996) 

69 FR 34 

1 1 I1 312001 

1211 011 991 

121411 990 

1 21411 990 

I Refinery Vacuum Producrnn 

Yes 

Yes 

" 

74 10 1 Processing Facllity 

( Natural Gas-Flred Resldentlal 

23 of 26 

Attachment 2 

(1 1212004) 

60 FR 46535 

(91711 995) 

52 FR 12522 

Yes 

74 11 1 Water Heaters 

1 2/411 990 

51911 995 

No 

(312411 992) 

57 FR 10136 

(312411 992) 

70 FR 61 561 
Table C - District Rules Evaluated for RACT SIP (cont'd) 

74.11.1 601krs Yes 911 411 999 911 411 999 (1 2/20/2000) 

Surface Coat~ng of Metal Parts & 70 FR 61 561 

74.12 Products Yes 1 111 911985 1 1 I1 1 I2003 (1 012512005) 

Aerospace Assembly & 

Component Manufacturmg 70lFR 61 561 

74.1 3 Operat~ons Yes 411 511 986 1 1 I1 1 I2003 (1 012512005) 

Polyester Resin Mater~al 71 FR 51 72 

74 14 Operat~ons Yes 1 1/24/1987 411 212005 (211 12006) 

Bo~lers, Steam Generators 61 FR 4887 

74 15 Process Heaters Yes 312811 989 1 1/8/1994 (21911 996) 

Bolters, Steam Generators 66 FR 51576 

74 15.1 Process Heaters Yes 511 1 I1 993 611 312000 (1 011 012001 ) 

64 FR 19277 

74 16 O~lf~eld Drdling Operat~ons No 1/8/1991 1 I811 991 (412011 999) 

66 FR 48355 

74.1 7 1 Mun~c~pal Sohd Waste Landfills No 311 011 998 21911 999 (912012001) 

Motor Vehicle and Mob~le 66 FR 20086 

74 18 Equipment Coatrng Operat~ons Yes 112811992 911 011 996 (411 912001 ) 

70 FR 61 561 

74 19 Graphc Arts Yes 811 112002 1 111 1 I2003 (1 012512005) 

63 FR 44792 

74.1 9 1 Screen Pr~nt~ng Operat~ons Yes 611 1 I1 996 1 1 I1 1 I2003 (8121 I1 998) 

68 FR 67805 

74 20 Adhes~ves and Sealants No 61811 993 111 1 I2005 (1 2/4/2003) 

61 FR 7706 

74.21 1 Sem~conductor Manufacturmg No 1 4/6/1993 1 4/6/1993 1 (212911 996) 

I Natural Gas-Fred. Central Fan- I 1 61 FR 18959 

74 22 1 Type Furnaces No 1 1 1/9/1993 1 11/9/1993 [ (413011 996) 

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 31811 994 1 1 I1 1 I2003 (1 012512005) 

Pleasure Craft Coatmg and 67 FR 5261 1 

74.24 1 Commercial Boatyard Operat~ons Yes 1 1 I1 011 998 11812002 (811 312002) 

70 FR 46090 

74 25 Restaurant Cookmg Operations No 1011 212004 1011 212004 (81912005) 

Crude 011 Storage Tank 61 FR 20145 

74 26 Degassmg No 1 I1811994 1 1 I811 994 (51611 996) 

Gasoline & ROC L~qu~d Storage 61 FR 20145 

74 27 Tank Degassing Operat~ons No 1 1 1811 994 1 1 1811 994 (51611 996) 

I I 1 1 1 I 61 FR 7706 

74 28 Asphalt Roofmg No 511 011 994 511 011 994 (212911 996) 

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 Products Coatmg Yes 1 511 711 994 1 1 1 I1 1 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-450 3-91-022a; Des~gn Criter~a 

for State I Vapor 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 

1011 998 

Paper, Fabr~c and Film Coating Operat~ons EPA Approval 91711 995, EPA-453 R-94- 

054 

Cutback Asphalt EPA Approval 411 711 987 

Petroleum Solvent Dry Cleanmg EPA Approval 312411 992, EPA-45013-82- 

009 

Surface Clean~ng and Degreasing EPA Approval 1012512005; EPA-45012-77- 

022; CARB RACTIBARCT Defermination 

last updated 1011 998 

Batch Loaded Vapor Degreasers EPA Approval 1012512005, EPA 450 3-89- 

030; CARB RACTIBARCT Determinat~on 

last updated 1011 998. 

Fug~twe Em~ss~ons of ROC at Petroleum EPA Approval 712511 996, EPA-45012-77- 

Refineries and Chemical Plants (VOC) 025; EPA-45012-78-036, CARB 

RACTIBARCT Determinations last updated 

1011 998 

Refinery Vacuum 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 811 911 999, 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 1 011 998. 

Aerospace Assembly & Component EPA Approval 1012512005; EPA-453lR97- 

Manufacturma -. O~erations 004: CARB RACTIBARCT Determinat~on 

I last updated 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 Motor Vehcle and Mob~le Equ~pment Coatmg 

Operat~ons 

74 19 Graphic Arts 

I 1 74 19.1 Screen Prmting Operat~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 

1011 998 

EPA Approval 1011 012001 , EPA-453 R-94- 

022, EPA-453 R-93-034; CARB 

RACTIBARCT Determmat~on last updated 

1011 998 

EPA Approval 411 912001, EPA-540 3-88- 

009; CTG EPA-453 R-94-054, CARB 

RACTIBARCT Determination 511 995 

EPA Approval 1012512005, EPA-45012-78- 

033; EPA-453 R-94-054, CARB 

RACTIBARCT Determmat~on last updated 

1011 998 

EPA Approval 8121 198; 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; 61 FR44050; CARB RACTIBARCT 

Determ~natlon last updated 10198 

EPA Approval 811 312002, CARB 

RACTIBARCT Determmatlon last updated 

1011 998 

EPA Approval 51611 996. 

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.ca novlss~slss~s.htm#RACTlBARCT 

EPA Approvals cert~fy that rules meet RACT All cert~fications contmue to be valid 

26 of 26 

Attachment 2 
Attachment 3 

PUBLIC COMMENTS AND DISTRICT RESPONSES TO COMMENTS 
Ventura 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 Protection Agency 

Region IX 

75 Hawthorne Street 

San Francisco, CA 94 105 

Dear Mr. Steckel, 

Thank you for your letter dated June 5,2006 providing comments on the District's 8-hour Ozone 

Reasonably Avadable Control Technology - State Implementation Plan (RACT SIP) Analysis. 

We have reviewed your comments and offer the following responses: 

1. Comment 

Partzcularly where the last RACT determznatzon for speclJic source categorzes occurred 

many years ago, the staffreport should reflect some 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 RACT fneeded for RACU. The Dzstrict should also certzfj, zt u not aware of 

any szgnzjkant changes in technology that affect the origznal RACT determznatzon. 

Response 

We have examined the list of District 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 subject to the several of the listed rules. This is noted where 

appropriate on Attachment A. 

2. Comment 

In cases where the District has relzed on the Calfornia Azr Pollution Control Oficers 

Associatzon (CAPCOA) September 2003 Potential All Feasible Measures (AFM) Report 

to help demonstrate RACK some explanatory text zs needed to justzfj, the assumption that 

the AFM fu@lled RACT m 2003 and include some sort of certz$catzon/demonstratzon that 

no addztional controls have become more reasonably available since then. 

Response 

We did not rely on the CAPCOA September 2003 Potential All Feasible Measures 

Report to help demonstrate RACT 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 feasible measures" analyses in the RACT SIP 

Attachment 3 
A Steckel 

June 16 2006 

Page 2 

because it is one of several mechmsms that help to keep District rules current with 

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 should be added to this 

section to mher describe the analysis that is performed. It may be helpful to attach to 

the staff report 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 feasible measures" 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. The procedure VCAPCD used to verify that there are no 

sources within District boundaries for a given CTG source should be described in the 

negative declaration (e.g., search of the permits database, emission inventory, SIC Code, 

yellow pages etc.) 

Response 

The procedure the District used 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 of the 2006 RACT SIP. 

5. Comment 

VCAPCD's staff report, page 3, indicated some sources might be subject to CTGs, but 

there are no corresponding Distnct rules. VCAPCD explained that such sources are 

controlled to Best Available Control Technology (BACT) and are less than 25 tpy. 

Some CTGs apply to sources below the major source threshold. Enclosure (2)LTable 2- 

CTG Source Categorres with no Applicable District Rule (YCAPCD Table A-2)J lzsts 

CTG categories for which there may be VCAPCD sources wrth no corresponding District 

rule. To implement RACT as required for these sources, the District should either submit 

a RACTprohibitory rule or source-specijic SIP reviszons based on the permits. 

Response 

District staff conducted a more thorough evaluation of the CTG categories listed in Table 

2 and has determined that the there are no sources withn District boundaries subject to 

those CTGs. The 2006 RACT SIP has been revised accordingly. 

Attachment 3 
A. Steckel 

June 16 2006 

Page 3 

6. Comment 

Page 8 lists Rule 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 on page 8. 

7. Comment 

Rule EPA 453 R-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 an Alternative 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 covered by CTGs, or are NOx rules covered by ACTS 

for which there are no major sources in 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 reviewing this important public policy 

document. The District's responses to your comments will be included in the 2006 RACT SIP 

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

2006 RACT SIP Revisions at 1 1 :00 a.m. on June 27,2006, in the Ventura County Board of 

Supervisors Hearing Room. If you have any questions, please call Chuck Thomas of my staff at 

(805) 645-1427. 

Sincerely, 

/MICHAEL VILLEGAS 

Air Pollution Control Officer 

Attachment A: Clarification of Rules for the 2006 RACT SIP 

Attachment 3 
Attachment A 

Clarification of Rules for 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 

1 135, Emissions of 

NOx fi-om Electric 

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 = 0.01 1 lb 

NOx per MM BTU 

(approx. 0.11 lb NOx per MW-HR, assuming 

a heat rate of 10,000 BTU per KW-HR). 

0.05 to 0.1 lb per MM BTU 

Wall-fired natural gas boiler with SCR 

Auxiliary Boilers 

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 

auxiliary boilers 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 County power plants is less than 0.2% of total 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 of pounds of NOx per day, which are not in the Ventura rule. 

Compliance is probably achieved by curtailing power generation rather than using "reasonably 

available control technology." 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 choose that option. 

1 

Attachment 3 
Attachment A 

Clarification of Rules for the 2006 RACT SIP 

(continued) 

Rule 59 represents RACT for Ventura County because 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 

only be analyzed for RACT if there are major sources in the District. There are no major 

ethylene oxide sources in the District. A comparison to other ethylene oxide-applicable 

requirements follows. 

Rule 62.6 applies to both commercial and non-commercial ethylene oxide stenlization 

operations. Rule 62.6 contains control requirements for commercial operations that are as 

stringent or more stringent than the requirements contained in EPA's National Emissions 

Standards for Hazardous Air Pollutants for Ethylene Oxide Commercial Sterilization and 

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 Control Measure for Ethylene Oxide Sterilization Operations. Therefore, 

Rule 62.6 meets or exceeds RACT 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 including hot wells and 

accumulators, unless said discharge has been reduced by at least 90 percent. 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 

exceeds RACT Requirements. Furthermore, a search of the current permitted sources in 

Ventura County shows that there are no petroleum refineries operating in the county. Any 

new petroleum refineries would be subject to Rule 26, New Source Review, which would 

require both Best Available Control Technology and Emission Offsets. Therefore, this 

certifies that 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 emissions of reactive 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 

emissions from produced natural gas be controlled. The current vapor recovery requirements 

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 Rules for the 2006 RACT SIP 

(continued) 

rule deficiencies including Air Pollution Control Officer discretion over approval of rule 

exemptions and other enforceability issues. None of the rule requirements were disapproved 

because of Reasonably 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 Implementation Plan on August 4, 1994 (59 FR 36690, 

8/4/1994). This SIP approval indicated that EPA considered that the 1992 adoption of Rule 

71.1 as RACT at that time. Staff has recently reviewed the requirements, and our conclusion 

is that this rule still exceeds RACT requirements. 

Rule 71.1 requires vapor recovery emission controls on crude oil storage tanks, produced 

water storage tanks and wash tanks. Vapor recovery systems are assumed to control 90 

percent of the ROC emissions fi-om these tanks. Oilfield operators may qualify for an 

exemption from vapor recovery requirements based on three established criteria outlined in 

the rule. The three exemption levels are: (1) if the ROC content of the 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 $9 per pound of ROC emission reduced, based on a policy 

adopted by the Ventura County Air Pollution Control Board on December 20, 1988. 

District staff did 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 of these tanks qualify for 

an exemption because of low vapor pressure less than 0.5 psia, and eleven qualify because 

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 of ROC reduced. 

The requirements of Rule 71.1 fulfill RACT 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 determined by the BACT cost 

analyses, which exceed $9 per pound of ROC reduced. This BACT cost threshold is 

typically used to evaluate new or modified sources subject to Rule 26, New Source Review. 

Rule 7 1.1 exempts fi-om vapor recovery requirements 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-om these exempt tanks represent less than 0.5 percent of the total tank emissions. 

5) Rule 71.2. Storaae of Reactive Orsanic Com~ound Liauid 

Rule 7 1.2 limits the emissions of ROC fiom the storage of ROC 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 Rules for the 2006 RACT SIP 

(continued) 

1. Make the rule conform to EPA's Control Technology Guidelines (CTG). 

2. Correct deficiencies based on EPA's "Issues Relating to VOC Regulations Cutpoints, 

Deficiencies, and Deviations" dated May 25, 1988. 

3. Address concerns expressed by the Air Resources Board in July, 1983. 

4. To increase the rule stringency and extend applicability to tanks whose contents have a 

Reid vapor pressure greater than 0.5 psia. 

New requirements in the 1989 amendments even exceed the CTG requirements published by 

EPA in October of 1993. Examples include a requirement for "zero gap" secondary seals, 

and a restriction on the use of shoe-mounted secondary seals. Moreover, EPA approved this 

version of the 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 conclusion is that this rule still exceeds RACT requirements. 

District staff compared the requirements of VCAPCD Rule 71.2 with South Coast Air 

Quality Management District (AQMD) Rule 1178, Further Reduction of VOC Emissions 

from Storage Tanks at Petroleum Facilities, which was adopted on December 2 1,2001, to 

determine if RACT requirements have 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 storage tanks. A 

search of permitted sources Indicates there are eight floating roof tanks, five of which have 

external floating roofs and three have mternal floating roofs. 

District staff has contacted Conservatek, a supplier of aluminum domed roof from Conroe, 

Texas to obtain cost information for a retrofit of an existing tank. The Conoco tank on 

Permit No. 387 was evaluated since it is the smallest tank with the largest ROC emissions, 

thus providing the most cost-effective example. The installed price was quoted at $236,000 

for the roof, and is shown on the following page. Staff contacted Ed Muehlbacher, Program 

Supervisor for South Coast AQMD, to inquire about the implementation of Rule 1178. Mr. 

Muehbacher indicated that a fire-suppression system costing about $100,000 should be added 

to the total cost of the installation. One advantage of this system is that it can be installed 

without taking the tank out of service. 

A cost-effectiveness analysis for retrofitting an existing tank with a dome roof is summarized 

in the Table 2 below: 

4 

Attachment 3 
Attachment A 

Clarification of Rules for the 2006 RACT SIP 

(continued) 

Table 2 

Cost-Effectiveness for 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 Emissions Reduced 

$12 per pound of ROC Reduced 

The $12 per pound of ROC reduced exceeds the BACT cost-effectiveness of $9 per 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 1178 contains an exemption from doming 

requirements for tanks containing crude oil (Section J.7), presumably based on a similar costeffectiveness calculation done by South Coast district staff. 

6) Rule 71 3, Transfer of Orqanic Reactive Compound Liquids 

The provisions of this rule apply to equipment used to transfer reactive organic compound 

(ROC) liquids with a Modified Reid vapor pressure WVP) greater than or equal to 0.5 psia. 

The provisions of the rule do not apply to the transfer of gasoline or the transfer of ROC 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 emissions of reactive organic compounds from the coating of paper, fabric 

or film substrates. A search of the current permitted sources in Ventura County shows that only 

one source, Irnation, is subject to 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 of Volatile Organic Emissions From 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 3 
Attachment A 

Clarification of Rules for the 2006 RACT SIP 

(continued) 

Moreover, the only source regulated by Rule 74 3, Irnation, is a Title V federally-regulated 

source that underwent site-specific rulemaking, 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, Standards of Performance 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 source that will be subject to this rule will have to meet Best Available 

Control Technology (BACT) requirements required under Rule 26, New Source Review. 

8) Rule 74.4. Cutback Asphalt 

The limits of this 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 establishes emission limits for cleaners that 

consume more than 32,500 gallons of petroleum solvent per year. There are 23 petroleum 

solvent dry cleaners in Ventura County The largest facility is permitted to consume 

approximately 680 gallons of petroleum solvent per year. There are no major petroleum solvent 

dry cleaning sources in the District. Therefore, no RACT analysis is required 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 

Solvent Dry 

Cleaners 

90% back-end control, or, for 

facilities that operate a still - 

overall emissions may not 

exceed 5% of dry weight of 

articles cleaned and for 

facilities that do not operate a 

still overall emissions may not 

exceed 8% of dry weight of 

articles cleaned. 

Transfer machines are 

~rohibited. 

Limit filtration 

wastes to 1 .O% 

of dry weight of 

articles cleaned. 

Drain cadges for 

24 hours, or 12 hrs 

if subsequently 

dned in a container 

vented to a 90% 

efficient control 

device. 

Drain cartridges for 

24 hours. 

6 

Attachment 3 
Attachment 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 12 hrs. 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 solvent would be subject to 

the BACT requirements of Rule 26, New Source Review. Therefore, Rule 74.5.2 is not related 

to attainment of the 8-hour ozone standard because it does not regulate ozone precursors. A 

RACT analysis is 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) of reactive organic 

compounds (ROC) fiom components at petroleum refineries and chemical plants. Components 

include pumps, compressors, pressure relief devices, open-ended lines, agitators, valves, fittings, 

flanges, connections, diaphragms, hatches, and meters. Rule 74.7 controls fugitive ROC 

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 12.96 tons per year. One other facility in 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 operating in 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 Maintenance Program 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 3 
Attachment A 

Clarification of Rules for the 2006 RACT SIP 

(continued) 

confirms that 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 recently reviewed the requirements, and our conclusion is 

that this rule still exceeds RACT requirements. 

The most recent Environmental Protection Agency (EPA) Alternative Control Technology 

(ACT) document for this source category 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 components compared to the Phase I1 and Phase III federal Hazardous Organic 

NESHAP (40 CFR Part 63, Subpart H), Rule 74.7 is actually a more stringent regulation because 

it can be enforced by inspectors who have the authority under the rule to issue Notices of 

Violations when leaks are discovered by the use of their portable leak detectors. Under the 

federal HON, no such authority exists for inspectors to cite violators for leaking components 

found at the facility. The federal HON is strictly enforced by a review of operator records. This 

is a critical difference which makes Rule 74.7 a more effective regulation because 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 

drops per minute for liquid leaks. Although the 500 ppm gaseous leak threshold in the HON is a 

more stringent threshold, the lack of an adequate enforcement mechanism for inspectors in 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 of Violations 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 

considers that this rule has exceeded current RACT requirements. 

74.8, Refinery Vacuum Producinq System, Wastewater Separators, and Process 

Turnarounds 

Rule 74.8 limits the emissions of reactive organic compounds from three sources at petroleum 

refinenes. These three refinery sources include vacuum producing 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 

operating in the county. Any new petroleum refineries would be subject to Rule 26, New Source 

Review, which would require both Best Available Control Technology and Emission Offsets. 

Therefore, this certifies that Ventura County has 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. Boilers burning more than 9 billion Btu per year must comply 

with a 40 ppm NOx limit. Boilers burning less than 9 billion Btu per year must be periodically 

tuned. 

There is no CTG for these units. There are no major sources comprised of uts subject to Rule 

74.15 in the District. Therefore, a RACT analysis is not 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 of reactive organic compounds (ROC) by 

prohibiting the venting of ROC 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 requires ROC vapors to be treated rather than released to the air. 

The District reassessed Rule 74.27 in 2003 because Bay Area AQMD (BAAQMD) Rule 8-40 

had the appearance of a more stringent cleanliness standard for tanks. BAAQMD requires tanks 

to be degassed to 5,000 ppm organic compounds as compared to the 10,000 ppm standard in 

VCAPCD Rule 74.27. The following is 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 

district tank degassing rules. 

The District staff's preliminary reassessment identified the BAAQMD and South Coast AQMD 

rules as the most stringent in the state, and possibly more stringent than 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-mrnute zntervals. The monitorzng 

rnstrument used to measure the vapor concentration shall meet the speclJicatzons of EPA Method 

21. The probe inlet of the monztorzng znstrument shall be located one foot above the bottom of 

the tank or one foot above the surface of any sludge matenal on the bottom of the tank. For 

uprzght, cylzndrical aboveground tanks, the probe znlet shall be (I) located at least 2 feet away 

from the inner su@ace of the tank wall and (2) zfsamples are wzthdrawn from a manhole, 

znserted in an opening of no more than one inch diameter on a flexible or inflexible materzal that 

is impermeable to reactive organzc compound (ROC) vapors, secured over the manhole." 

9 

Attachment 3 
Attachment A 

Clarification of Rules for the 2006 RACT SIP 

(continued) 

BAAQMD Rule 8-40 requires tanks to be degassed to 5,000 pprn 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 infiltration during 

testing, are not addressed by BAAQMD Rule 8-40. Because of the differences in test methods 

and the lack of testing details in the BAAQMD rule, the two standards (5,000 pprn vs. 10,000 

ppm) as measured by two different test methods and sampling procedures cannot be compared. 

Notwithstanding the above inconsistencies, if the 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 5,000 pprn as compared to 

10,000 pprn represents additional emission 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 concentration by an additional 50 percent (fiom 

10,000 pprn in District Rules 74.26 and 74.27 as compared to 5,000 pprn in BAAQMD Rule 8- 

40) is significant, considering the large amount of dilution air infiltration that must occur to 

accomplish this 50 percent reduction in concentration. 

South Coast AQMD Rule 1149 requires 2.3 tank volumes of gasses to be withdrawn from the 

tank and treated regardless of the final concentration left in the tank. Based on data in the 

11/8/94 Distnct staff report for adoption of Rules 74.26 and 74.27, between 7 and 13 tank 

volumes must be drawn from a tank being treated to bring the vapor concentration down to 

10,000 ppm. Therefore, South Coast Rule 1149 is 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 emission reductions 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 applies to underground gasoline tanks larger than 500 

gallons and above ground gasoline tanks larger than 19,815 gallons. 

District permit files indicate there are 26 underground tanks not regulated by Rule 74.27 

that would be considered feasible for degassing regulation by the South Coast AQMD 

(i.e., tanks between 500 and 5000 gallons capacity). The combined capacity of these 26 

underground gasoline tanks is 72,000 gallons. 

10 

Attachment 3 
Attachment A 

Clarification of Rules for the 2006 RACT SIP 

(continued) 

District permit files indicate there are 12 above ground tanks regulated by Rule 74.27 that 

would not be regulated by the South Coast AQMD rule (i.e., tanks between 5,000 and 

19,8 15 gallons capacity). The combined capacity of these 12 above-ground gasoline 

tanks is 1 17,000 gallons. 

Based on the above inventory of under- and above-ground gasoline tanks, and assuming that 

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 storage tank inventory in Ventura 

County because its applicability thresholds capture more tank capacity than the South Coast 

AQMD rule if applied to the Ventura County jurisdiction. Additionally, the infeasibility, based 

on cost-effectiveness, of requiring gasoline tanks smaller than 5,000 gallons to be degassed was 

set forth as follows in the 11/8/94 Distnct staff report for adoption of Rules 74 26 and 74.27: 

Tank degassing costs are $400 + $0.04 per gallon 

ROC cost-effectiveness threshold is $9.00 per pound of ROC emission reduced 

Gasoline vapors weigh 0.014 pounds per gallon 

Control device efficiency is 95% 

Therefore: $9.00/pound = $400 + ($O.O4/nallon)(Volume) Volume = 501 8 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 gasoline tank size threshold for 

feasible air pollution control. Therefore District staff concludes that Rule 74.27 meets RACT. 

Applicability - Crude Oil Storage Tanks 

Distnct Rule 74.26 applies to the following vapor recovery equipped crude oil or produced water 

storage tanks: 

Tanks having a capacity of 2000 barrels (84,000 gallons), which store organic compound 

liquids with a Reid vapor pressure of 3.4 psi or more. 

Tanks greater than 2000 barrels capacity regardless of Reid vapor pressure (RVP). 

Floating roof tank capacity is based on the vapor space that exists in the fully lowered 

roof position. Floating roof tanks are regulated if such capacity is 2,000 barrels or more, 

regardless of Reid vapor pressure. 

11 

Attachment 3 
Attachment A 

Clarification of Rules for the 2006 RACT SIP 

(continued) 

South Coast AQMD Rule 1149 applies to: 

Above-ground tanks larger than l9,8 15 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 pressure more than 2.6 psi. 

If applied in Ventura County, the South Coast AQMD Rule 1149 applicability thresholds would 

regulate the following additional tanks: 

Tanks >472 bbl but 5 944 bbl having a RVP 2 3.9 psi, and 

Tanks >944 bbl but 5 2000 bbl having a RVP 1 2.6 psi excluding tanks that are exactly 

2000 bbl having a RVP 2 3.4 psi 

Permitting records indicate there are 189 tanks in Ventura County meeting the above criteria. 

The volume-weighted average RVP of the fluid in these tanks is 3.1 psi, and the total volume of 

these tanks is 192,830 bbls 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 of the South Coat AQMD applicability thresholds would result in a potential for 

additional emission reductions of 1.6 tons per year. 

Staff obtained the following cost estimates from two tank degassing contractors 

$1,500 for a 500 bbl tank 

$2,500 for a 1000 bbl tank 

$2,000 for a 500 bbl tank 

Assuming ROC vapor density of 0.004 lblgallon and control efficiency is 95%, the costeffectiveness for the above examples of 500 bbl and 1,000 bbl tanks ranges from $1 6 to $25 per 

pound of ROC 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 County APCD Board has approved a costeffectiveness threshold is $9 per pound of ROC reduced). 

Based on the above discussions, the District believes Rule 74.26 and Rule 74.27 still meet RACT 

for applicable sources in Ventura County. 

12 

Attachment 3