# 8-Hour Reasonably Available Control Technology – State Implementation Plan Analysis

(RACT SIP Analysis)

July 2015

Antelope Valley Air Quality Management District

43301 Division Street, Suite 206 Lancaster, California 93535-4649

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# AVAQMD RACT SIP Analysis

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# Table of Contents Abbreviations and Acronyms ........................

................................................... ....................... ii Executive Summary .................................

................................................... .................................. 1 CHAPTER 1 - Introduction and Background ...........

................................................... ............. 3

Introduction ......................................

................................................... ........................................ 5 Purpose ...........................................

................................................... ......................................5 Background ........................................

................................................... ...................................... 5 Regulatory History ................................

................................................... ................................5 Federal Legal Requirements ........................

................................................... .........................5 Pollutant Description and Health Effects ..........

................................................... ...................5 Setting ...........................................

................................................... ........................................6

CHAPTER 2 – RACT SIP Evaluation ...................

................................................... .................. 7

Process ...........................................

................................................... .......................................9 CTG Sources .......................................

................................................... ..................................9 Major Non-CTG Sources .............................

................................................... .........................9
CHAPTER 3 – AVAQMD RACT Actions ...................

................................................... ......... 11 Federal Negative Declarations .....................

................................................... ......................13 Required RACT Actions .............................

................................................... .........................14 Proposed Rule Adoption Schedule ...................

................................................... ...................15 Appendices ........................................

................................................... .......................................... 1 Appendix A - RACT Evaluation Table ................

................................................... ............... A-1

# ii AVAQMD RACT SIP Analysis July 2015 

# Abbreviations and Acronyms
ACT.................... Alternative Control Technol ogy AQMA ............... Air Quality Management Area AVAQMD.......... Antelope Valley Air Quality Manage ment District BACT ................. Best Available Control Techn ology CARB ................. California Air Resources Boa rd CTG.................... Control Techniques Guidelin e CFR .................... Code of Federal Regulation s FCAA ................. Federal Clean Air Act FND.................... Federal Negative Declaratio n NAAQS .............. National Ambient Air Quality S tandard NO X 

# .................... Oxides of Nitrogen O 3 

# ....................... Ozone POTW ................ Publicly Owned Treatment Work s RACT ................. Reasonably Available Control Technology SCAQMD .......... South Coast Air Quality Managemen t District SIP ...................... State Implementation Pla n USEPA ............... United States Environmental P rotection Agency VOC ................... Volatile Organic Compounds

# AVAQMD RACT SIP Analysis

July 2015 1 

# Executive Summary The Federal Clean Air Act (FCAA) requires newly des ignated ozone non-attainment areas to implement Reasonably Available Control Technology ( RACT) on certain sources, including all major sources of ozone precursors. For the purpose s of the FCAA, the District has been designated non-attainment for ozone and classified as Severe-15 for the 1997 and 2008 ozone standard (May 8, 2012, 77 FR 26950 and June 6, 2013 78 FR 34178). The Antelope Valley Air Quality Management District (AVAQMD) has evaluated its adopted rules and all of its major sources of ozone precursors to ensure that current rules satisfy RACT. The evaluation process produced several rules that must be updated to curr ent federal RACT standards.

This document presents the evaluation method, the e valuation results, and the AVAQMD’s commitment to adopt the required RACT rule updates.

The original 2006 RACT SIP Analysis (for the 1997 8-hour ozone standard), together with the supplemental March 13, 2014 RACT SIP Analysis and this document, represent a current and complete RACT SIP Analysis document to satisfy the District’s RACT obligation for the 1997 and 2008 8-hour ozone standards.

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# AVAQMD RACT SIP Analysis

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# CHAPTER 1 – Introduction and Background

Purpose Regulatory History Federal Legal Requirements Pollutant Descriptions Setting

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# AVAQMD RACT SIP Analysis

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# INTRODUCTION

Purpose The FCAA requires that ozone non-attainment areas i mplement RACT for sources that are subject to Control Techniques Guidelines (CTGs) and for major sources of ozone precursors. This document: (1) reviews all available instances of RACT for applicability to the AVAQMD; (2) reviews all AVAQMD major sources for RACT appli cability; and (3) identifies any actions the AVAQMD must take to address applicable RACT req uirements. This document satisfies 42 U.S.C. §§7511a (FCAA §182) regarding RACT requireme nts for the 8-hour ozone National Ambient Air Quality Standard (NAAQS).



# BACKGROUND

Regulatory History The United States Environmental Protection Agency ( USEPA) designated the desert portion of Los Angeles County as non-attainment of the 8-hour ozone NAAQS as part of the Southeast Desert Modified Air Quality Management Area (AQMA) on April 15, 2004 (40 CFR 81). This large “maintenance area” was classified moderate ba sed on a 128 ppb ozone design value calculated from 2000 through 2002 8-hour ozone valu es within the Los Angeles County portion of the area.

The desert portion of Los Angeles County was establ ished as its own air district as of July 1, 1997, the Antelope Valley Air Pollution Control Dis trict (AVAPCD), pursuant to former H&SC §40106 (Statutes 1996 ch 542, Repealed Statutes 200 1 ch. 163). This air district was replaced by the AVAQMD on January 1, 2002, pursuant to H&SC §41 300 et seq (Statutes 2001 ch. 163). As a successor district to SCAQMD, the AVAQMD assumes the authorities and duties of the SCAQMD for the Antelope Valley (H&SC §41302).

Ozone plans have been adopted by the AVAQMD to addr ess Federal ozone planning requirements, including RACT applicability. This d ocument updates the Federal RACT portion of all previously submitted plans.



# Federal Legal Requirements Sections 182(b)(2) and 182(f) of the FCAA require t hat ozone non-attainment areas implement RACT for sources that are subject to CTGs and for m ajor sources of ozone precursors (42 U.S.C. §7511a). Ozone non-attainment areas classified mod erate and higher must submit a RACT SIP (State Implementation Plan) analysis by July 20, 20 14 (40 CFR 51.912).



# Pollutant Description and Health Effects Ozone (O 3 

# ) - A colorless gas that is a highly reactive form of oxygen. It has a strong odor when highly concentrated. Ozone can occur naturally but can also be formed from other compounds through photochemistry, a complex system of reactio ns with hydrocarbons and oxides of

# 6 AVAQMD RACT SIP Analysis July 2015 nitrogen in the presence of sunlight (ultraviolet). The Mojave Desert Air Basin experiences ozone concentrations in excess of the State and Fed eral ambient air quality standards.

Ozone can cause respiratory irritation and discomfo rt, making breathing more difficult during exercise. Ozone can reduce the respiratory system’ s ability to remove inhaled particles, increase pulse rate, decrease blood pressure and reduce the body’s ability to fight infection. After six hours of exposure a healthy person can have signifi cant reduction of lung function. It is an irritant of the skin, eyes, upper respiratory syste m, and mucous membranes, although symptoms disappear after exposure. It may also be a carcino gen.



# Setting The Antelope Valley is the desert portion of Los An geles County. The Antelope Valley covers 1300 square miles and included 219,628 persons as o f the 1990 census (approximately 400,000 in 2002), centered within the cities of Lancaster a nd Palmdale. The region is characterized by a wide, arid valley with little precipitation.

The primary roadways in the Antelope Valley are Sta te Route 14 and State Route 18. Both of these arterials carry a substantial amount of daily commute traffic from the region into the Greater Los Angeles Basin.

The Antelope Valley is primarily a bedroom communit y, but does have significant aerospace development and manufacturing. Air Force Plant 42 and a portion of Edwards Air Force Base are located within the District (Boeing, Lockheed M artin and Northrop Grumman all lease facilities on the base from the Air Force).

# AVAQMD RACT SIP Analysis

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# CHAPTER 2 – RACT SIP Evaluation

Process CTG Sources Major Non-CTG Sources Future Years

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# AVAQMD RACT SIP Analysis

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# Process The AVAQMD reviewed a USEPA-provided list of source categories and applicable CTGs that collectively define RACT. The AVAQMD reviewed this list for local applicability, and the results are presented in Appendix A.



# CTG Sources Those categories of sources covered by a published CTG are referred to as CTG sources. For each CTG source category, the AVAQMD has identified whether or not a current source is sited within its jurisdiction, or whether it is likely a source may be sited within its jurisdiction. In most cases, where the AVAQMD has no source that mee ts the category, the AVAQMD will file a Federal Negative Declaration (FND) for that categ ory. For some categories the AVAQMD has an adopted rule that applies to the category that h as been deemed to meet the applicable RACT for that category. In several cases, the AVAQMD ha s a rule which has been evaluated and needs to be updated for RACT, and the AVAQMD is committin g to amending the rule to current RACT for those source categories accordingly. Chap ter 3 details AVAQMD actions identified by this evaluation process.



# Major Non-CTG Sources RACT is also required for all major sources of ozon e precursors within the AVAQMD. For severe non-attainment areas a major source is defin ed as any stationary source or group of sources that emits, or has the potential to emit, a t least 25 tons per year of VOCs or NO X 

# (FCAA 182(d) and (f)). Table 1 below presents a list of all facilities that have submitted applications for Title V Federal Operating Permits within the AVAQMD , whether the facility is a major source of ozone precursors, and the current RACT applicabl e to those sources. This list includes all major sources in the AVAQMD. Chapter 3 details AVA QMD actions identified by this evaluation process.

# 10 AVAQMD RACT SIP Analysis July 2015 Table 1 - Major Source Table Source FOP Description Applicable RACT Northrop-Grumman * 

# 102301816 Aerospace research, development and manufacturing 1. Aerospace (CTG and MACT) (EPA453/R-97-004, December 1997). 2. Aerospace MACT (59 FR 29216, June 1994).

Lockheed Martin Skunk Works * 

# 9701754 Aerospace research, development and manufacturing 1. Aerospace (CTG and MACT) (EPA453/R-97-004, December 1997). 2. Aerospace MACT (59 FR 29216, June 1994).
Antelope Valley Public Landfill + 

# 121002106 Municipal solid waste disposal No applicable CTG.

Not a major source of ozone precursors Lancaster Landfill & Recycling Center +# 

# 122802129 Municipal solid waste disposal No applicable CTG.

Not a major source of ozone precursors Wm. Bolthouse Farms 180403054 Agriculture No applicable CTG. 1. ACT Document – NO X 

# Emissions from Stationary Internal Combustion Engines (EPA-453/R-93-032, 07/93).

* 

## Potential to emit exceeds major source threshold.

+ 

## Required to obtain a Title V permit under 40 CFR Pa rt 60 subpart WWW §60.752(b).

# 

## The 2012 CARB inventory for NO x 

## for this facility includes emissions from mobile sources.

# AVAQMD RACT SIP Analysis

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# CHAPTER 3 – AVAQMD RACT Actions

Federal Negative Declarations Required RACT Rule Actions

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# AVAQMD RACT SIP Analysis

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# Federal Negative Declarations Current AVAQMD review has identified many source ca tegories that do not have corresponding sources (major or minor) within the jurisdiction of the AVAQMD. The District reviewed its permit files and the emission inventory for its Fed eral Clean Air Plan, and conducted SIC Code searches, the internet, yellow pages, and District inspectors and engineer’s knowledge, and has determined that there are no stationary sources or emitting facilities that meet the applicability threshold for the following CTG categories. The Di strict also does not anticipate sources that will exceed the CTG applicability threshold in the near future. For these source categories the AVAQMD is filing FNDs. In some cases the FND is an update of an earlier FND. 1 

# FND actions are summarized in Table 2 below.

1 

## The District may have an existing SIP rule for a p articular source category subject to these FNDs. F iling a FND does not mean that the District will not subsequent ly amend its rule and update the SIP at a future ti me.

# 14 AVAQMD RACT SIP Analysis July 2015 Table 2 - Federal Negative Declarations

Source Category Control Techniques Guideline Coverin g Action

Fiberglass Boat Manufacturing Materials 1. Control Techniques Guidelines for Fiberglass Boa t Manufacturing Materials (EPA-453/R-08-004, 09/2008). Metal Furniture Coating 1. Control Techniques Guidel ines for Metal Furniture Coatings (EPA-453/R-07-005 , 09/2007).

Refinery Vacuum Producing Systems, Wastewater Separators, and Process
Unit Turnarounds 1. Control of Refinery Vacuum Producing Systems, Wa stewater Separators, and Process Unit Turnarounds (EPA-450/2-77-025).

Coils 1. Control of Volatile Organic Emissions from Exist ing Stationary Sources - Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles , and Light-Duty Trucks (EPA-450/2-77-008, 05/1977).

Insulation of Magnet Wire 1. Control of Volatile Organic Emissions from Exist ing Stationary Sources - Volume IV: Surface Coating of Insulation of Magnet Wire (EPA-450/2-77- 033, 12/1977).

1. Control of Volatile Organic Emissions from Exist ing Stationary Sources - Volume V: Surface Coating of Insulation of Large Appliances (EPA-450/ 2-77-034, 12/1977).

2. Control Techniques Guidelines for Large Applianc e Coatings (EPA-453/R-07-004, 09/2007).

Bulk Gasoline Plants 1. Control of Volatile Organic Emissions from Bulk Gasoline Plants (EPA-450/2-77-0 35, 12/1977).

Petroleum Refinery Equipment 1. Control of Volatile Organic Compound Leaks from Petroleum Refinery Equipment (EPA-450/2- 78-036, 06/1978).

Synthesized Pharmaceutical Products 1. Control of Volatile Organic Emissions from Manuf acture of Synthesized Pharmaceutical Products (EPA-450/2-78-029, 12/1978).

Pneumatic Rubber Tires 1. Control of Volatile Organic Emissions from Manufacture of Pneumatic Rubber Tires (EPA450/2-78-030, 12/1978). Manufacture of High-Density Polyethylene, Polypropylene, and Polystyrene Resins 1. Control of Volatile Organic Compound Emissions f rom Manufacture of High-Density Polyethylene, Polypropylene, and Polystyrene Resins (EPA-450/3-83-008, 11/1983).

Natural Gas/Gasoline Processing Plants 1. Control of Volatile Organic Compound Leaks from Natural Gas/Gasoline Processing Plants (EPA-450/3-83-007, 12/1983).

Synthetic Organic Chemical Polymer and Resin Manufacturing Equipment 1. Control of Volatile Organic Compound Leaks from Synthetic Organic Chemical Polymer and Resin Manufacturing Equipment (EPA-450/3-83-006, 03 /1984).

1. Control of Volatile Organic Compound Emissions f rom Air Oxidation Processes in Synthetic Organic Chemical Manufacturing Industry (EPA-450/3- 84-015, 12/1984).

2. Control of Volatile Organic Compound Emissions f rom Reactor Processes and Distillation Operations in Synthetic Organic Chemical Manufactur ing Industry (EPA-450/4-91-031, 08/1993).

Wood Furniture Manufacturing Coating Operations 1. Control of Volatile Organic Compound Emissions f rom Wood Furniture Manufacturing Operations (EPA-453/R-96-007, 04/1996).

Shipbuilding and Ship Repair Surface Coating Operations 1. Control Techniques Guidelines for Shipbuilding a nd Ship Repair Operations (Surface Coating) (61 FR 44050 8/27/96, 04/1994).

Flat Wood Paneling 1. Control Techniques Guidelines for Flat Wood Paneling Coatings (EPA-453/R-06-004, 09/2006).

Large Petroleum Dry Cleaners 1. Control of Volatile Organic Compound Emissions from Large Petroleum Dry Cleaners (EPA450/3-82-009, 09/1982).

Fixed-Rood Tanks 1. Control of Volatile Organic Emissions from Stora ge of Petroleum Liquids in Fixed-Roof Tanks (EPA-450/2-77-036, 12/1977).

Floating-Roof Tanks 1. Control of Volatile Organic Emissions From Petro leum Liquid Storage in External Floating Roof Tanks (EPA-450/2-78-047, 12/1978).

Federal Negative Declarations

Large Appliance Coatings

Synthetic Organic Chemical Manufacturing Industry

# AVAQMD RACT SIP Analysis

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# Required RACT Actions – 2006 RACT SIP Analysis The AVAQMD identified three required RACT rule acti ons in the 2006 RACT SIP Analysis

. These actions are detailed below.

Aerospace Coating The AVAQMD has aerospace coating operations within its jurisdiction and a current rule that applies to this source category, Rule 1124 – Aerospace Assembly and Component Manufacturing Operations . Rule 1124 was most recently amended on 08/20/201 3. No further action is required at this time if USEPA determines that this amendmen t fulfils current RACT.

Stationary Internal Combustion Engines The AVAQMD has stationary internal combustion engin es at major sources within its jurisdiction, and had two rules that applied to thi s source category, Rule 1110 - Emissions from Stationary Internal Combustion Engines (Demonstrati on) and Rule 1110.2 - Emissions from Stationary, Non-road & Portable Internal Combustion Engines

.

• Rule 1110 was rescinded by the AVAQMD on 01/15/2013 . Rule 1110 was adopted by South Coast Air Quality Management District (SCAQMD ) on 11/06/1981 to set up a demonstration program to collect emissions data for SCAQMD Rule 1110.1 - Emissions from Stationary Internal Combustion Engines . The SCAQMD demonstration program was completed on or about November 1991. This was prior to the formation of the Antelope Valley Air Pollution Control District on 0 7/01/1997. Rule 1110 was subsequently rescinded by the SCAQMD on 11/14/1997. Due to the provisions of the implementing statute and the subsequent statutory c reation of the Antelope Valley Air Quality Management District the rule remained in th e AVAQMD rule book though it was inapplicable due to the termination of the program and the fact that none of the program engines were located within what is now the jurisdi ction of the AVAQMD. USEPA is to update the rescission action in the SIP.

• The AVAQMD will either update Rule 1110.2, or adopt a separate agricultural internal combustion engine rule to address items including, but not limited to, those identified in 69 FR 21483, 04/21/2004.



# Additional Required RACT Actions USEPA requested further clarification for several r ules to determine if they still represent RACT, or should be submitted for SIP approval if needed f or RACT. 2 

# The AVAQMD provided this analysis to USEPA on 03/13/2014 in the 2014 Supplement to the 2006 AVAQMD RACT SIP Analysis

. 3 

# The original 2006 RACT SIP Analysis (for the 1997 8-hour ozone standard), together with the supplemental March 13, 2014 RACT SIP Analy sis and this document, represents a current and complete RACT SIP Analysis document to satisfy the District’s RACT obligation for the 1997 and 2008 8-hour ozone standards. Those it ems identified in the 2014 Supplement, and additional rule analysis which address newer CTGs, are as follows. A current and complete

2 

## USEPA letter September 11, 2006, Re: 8-hour Ozone Reasonably Available Control Technology – State Implementation Plan (RACT SIP) Analysis, dated Augu st 2006, Table 1 and Table 2.
3 

## 8-hour Ozone Reasonably Available Control Technolo gy RACT State Implementation Plan (SIP) Analysis – Supplemental Analysis, March 13, 2014.

# 16 AVAQMD RACT SIP Analysis July 2015 analysis for each rule will be completed at the tim e of the specific rule amendment. Those reasons identified below as a basis for updating th e rule to federal RACT are not necessarily inclusive of all rule changes that will be made at the time of amendment.

Rule 462 – Organic Liquid Loading Rule 462 to be amended to address deficiencies in t he Limited Approval/Limited Disapproval in the NPRM issued 62 FR 26560, 05/14/1997.

Rule 1107 – Coating of Metal Parts and Products Rule 1107 is consistent with CTG control recommenda tions, but several VOC limits in SCAQMD Rule 1107 are lower and have been identified as RACT.

Rule 1110.2 – Emissions from Gaseous and Liquid Fueled Internal C ombustion Engines Rule 1110.2 must be updated to remove the agricultu ral exemption and address other USEPA comments identified in the LA/LD (69 FR 21482, 04/2 1/2004).

Rule 1145 – Plastic, Rubber and Glass Coatings Rule 1145 to be amended to incorporate additional R ACT provisions identified in SCAQMD Rule 1145.

Rule 1146 - Emissions Of Oxides Of Nitrogen From Industrial, In stitutional And Commercial Boilers, Steam Generators, And Process Heaters Will survey affected units for applicability and de termine if it is feasible to update limits as RACT.

Rule 1151 – Motor Vehicle and Mobile Equipment Coating Operatio ns Rule must be amended to incorporate provisions of C ontrol Techniques Guidelines for Automobile and Light-Duty Truck Assembly Coating as applicable to “Heavier” vehicles, which includes all vehicles that meet the definition of t he term “other motor vehicles”, as defined at 40 CFR §63.3176. BYD Coach and Bus is not a major sou rce but is permitted above the CTG for Automobile and Light Duty Truck Assembly Coatings ( EPA-453/R-08-006, September 2008) threshold.

Rule 1171 – Solvent Cleaning Operations Rule must be amended to include work practices, adj ust categories for consistency with source specific rules, include alternative composite vapor pressure limit.



# Proposed Rule Adoption Schedule The AVAQMD will amend all identified rules by the e nd of calendar year 2016.

# AVAQMD RACT SIP Analysis

July 2015 A-1 

# Appendices

APPENDIX A – RACT EVALUATION TABLE

1. Rule 462 – Organic Liquid Loading 2. Rule 463 – Storage of Organic Liquids 3. Rule 1102 – Petroleum Solvent Dry Cleaners 4. Rule 1104 – Wood Flat Stock Coating Operations 5. 1106.1 – Pleasure Craft Coating Operations 6. Rule 1107 – Coating of Metal Parts and Products 7. Rule 1110.2 – Emissions from Gaseous and Liquid Fueled Internal C ombustion Engines 8. Rule 1141.1 – Coatings and Ink Manufacturing 9. Rule 1145 – Plastic, Rubber and Glass Coatings 10. Rule 1146 – Emissions Of Oxides Of Nitrogen From Industrial, In stitutional And Commercial Boilers, Steam Generators, And Process H eaters 11. Rule 1146.1 – Emissions of Oxides of Nitrogen from Small Industri al, Institutional, and Commercial Boilers, Steam Generators, and Process H eaters 12. Rule 1151 – Motor Vehicle and Mobile Equipment Coating Operatio ns 13. Rule 1171 – Solvent Cleaning Operations 14. Rule 1176 – VOC Emissions From Wastewater Systems

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# AVAQMD RACT SIP Analysis

July 2015 A-3 1. Rule 462 – Organic Liquid LoadingAV Rule 462 -Organic Liquid LoadingSCAQMD Rule 462 -Organic Liquid LoadingRACT DeficienciesRACT Version06/09/1995 (62 FR 60784, 11/13/1997)205/14/1999, 64 FR 39037, 7/21/1999ApplicabilityFacilities that load organic liquids with a vaporpressure of 1.5 psia or greater under actual loadingconditions into any tank truck, trailer or railroadcar asdefined as Class A, B or C facilities.Facilities that load organic liquids with a vapor pressure of 1.5psia or greater under actual loading conditions into any tanktruck, trailer or railroad car as defined as ClassA, B or Cfacilities.DefinitionsFacility Vapor Leak: Escape of organic vapors fromasource other than a tank truck, trailer or railroadcar inexcess of 3,000 ppm as methane above backgroundwhen measured at a distance of 2 cm from the sourceaccording to EPA Method 21. A facility vapor leaksource does not include liquid spillage or condensateresulting from "liquid leaks."Facility Vapor Leak: Escape of organic vapors froma sourceother than a tank truck, trailer or railroad car inexcess of3,000 ppm as methane above background when measuredaccording to EPA Method 21. A facility vapor leaksource doesnot include liquid spillage or condensate resultingfrom"liquid leaks."New and revised definitions added for rule clarityperSCAQMD TSD.TSD for SCAQMD Rule 462identified that the revision ofthe definition of "facilityvapor leak" to remove the 2cm measurement distancewas a deficiency in the rule.Suggested Control OptionsProvision added as a compliance mechanism for Districtapproval of vapor recovery and/or disposal systemsthat donot require CARB Certification per SCAQMD TSD.Update for RACT.Evaluation of RACT and recommendationUpdate Rule 462 to address deficiencies in the Limited Approval/Limited Disapproval in the NPRM issued05/14/1997.AVAQMD Rule 462 - Organic Liquid Loading11Table 1, item 6 of the EPA comment letter asks foridentification of which District rule was reviewedon the RACT Evaluation Table. Upon review, it wasdetermined that Rule 462 required furtherevaluation from the "Tank" section of the Rule Evaluation Table.2The AVAQMD does not believe that the SIP version ofRule 462 is as listed on the EPA Region 9 website.EPA lists the SIP version as amended on 06/09/1995 (11/13/1997 62 FR 60784). This FR noticespecifically excludes the AVAQMD from the SCAQMD approval. The 5/14/1997 NPRM does not exclude the AVAQMD. The AVAQMD separated from the SCAQMD on 07/01/1997, between the NPRM and theFinal rule. Since the 05/14/1997 NPRM does not exclude the AVAQMD, the 06/09/1995 version of Rule 462is still technically "SIP pending." The last SIPapproved version of Rule 462 would be the 10/14/1979SCAQMD amendment (no action shown for the 04/04/86version, and no final on the 12/07/1990 version).Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals, EPA-450/2-77-026Control of Volatile Organic Compound Leaks from Gasoline Tank Trucks and Vapor Collection Systems, EPA450/2-78-051Control of Volatile Organic Emissions from Bulk Gasoline Plants, EPA-450/2-77-035Applicable CTG(s)

# A-4 AVAQMD RACT SIP Analysis July 2015 2. Rule 463 – Storage of Organic Liquids

AVAQMD Rule 463 - Organic Liquid Storage SCAQMD Rule 463 - Organic Liquid Storage RACT Deficiencies Amended 03/11/1994 (SIP Approved 10/23/1996 61 FR 54941) Amended 11/04/2011 (SIP approved 03/28/2013 78 FR 18854)

Applicability Above-ground stationary tanks with a capacity of 75,000 liters or greater used forstorage of organic liquid, and any aboveground tank with a capcity between 950 liters and 75,000 liters used for the storage of gasoline. Above-ground stationary tanks with a capacity of 75,000 liters or greater used forstorage of organic liquid, and any aboveground tank with a capcity between 950 liters and 75,000 liters used for the storage of gasoline. Same

Definitions Definitions added for: Actual Storage Conditions, Ambient Temperature, Certified Person, Drain-Dry Breakout Tank, Heavy Crude Oil, and Working Day. Definition for Vapor Tight has been modified to 500 ppm, expressed as methane, above background. Update definitions if rule is updated.

Update definition of "Vapor Tight" to specify 500 ppm, expressed as methane, above background, from 1,000 ppm expressed as methane, above background.

Tank Roof Requirements Equivalency for vapor control device to be reviewed by District, ARB and USEPA and approved in writing by Executive Officer, ARB
and USEPA.

For vapor recovery systems, efficiency shall be 95%, or vent tank emissions to a fuel gas system. Add equivalency review criteria.

Allow tank to vent emissions to a fuel gas system.

Other Performance Requirements No crude oil containing in excess of 70 ppm by weight of HS shall be stored in floating
roof tank. Provision added that organic liquids listed in addendum shall be deemed in compliance with appropriate vapor pressure limits for the tank in which it is stored provided the actual storage temp does not exceed the corresponding max temp listed.

AV crude oil provision has been removed. Add additional SCAQMD provision.

Evaluate if crude oil with 70 ppm HS provision
should be removed.

Self-Inspection of Floating Roof
Tanks Out of date compliance dates for inspection and maintenance plan req. Remove compliance dates that have expired from AV rule for inspection and maintenance plan req.

Reporting and Recordkeeping Requirements Emissions reporting updates allowable methods for providing emissions information
to include USEPAs most recent version of "Tanks 4.0 Program." Update emissions reporting programs to include USEPA "Tanks 4.0 Program."

Exemptions Added exemption provision for drain-dry breakout tanks subject to Rule 1149. Evaluate if this provision should be added.

Test Methods Vapor tight condition appears to need to be updated. Updated/added test methods: TVP less than 5 mmHg, TVP of crude oils and distillates, API gravity. Updated test methods as applicable.

Addendum Several pages of Attachment C have been removed in the most recent SCAQMD
amendment. Remove information from Appendix C if no longer applicable or necessary.

1 Table 1, item 6 of the EPA comment letter asked fo r identification of which District rule was reviewe d on the RACT Evaluation Table. Upon review, it wa s determined that Rule 463 required further evaluation from the "Tank " section of the Rule Evaluation Table as it had no t been properly identified. Review of the AVAQMD R ACT SIP Analysis and the Federal Negative Declaration for Three Sou rce Categories includes Storage of Petroleum Liquid s in Fixed-Roof Tanks and Petroleum Liquid Storage in External Floating Roof Tanks (CTGs referenced: Control of Vo latile Organic Emissions from Storage of Petroleum Liquids in Fixed-Roof Tanks (EPA-450/2-77-036, 12/7 7) and Control of Voaltile Organic Emissions from Petroleum Liquid St orage in External Floating Rood Tanks (EPA-450/2-78 -047, 12/78)). AVAQMD Rule 463 - Organic Liquid Storage 1

Evaluation for RACT and recommendation

Rule 463 was inherited from the South Coast Air Qua lity Management District (SCAQMD) when the Antelope Valley Air Pollution Control District (AVAPCD) was created on July 1, 1997. This rule was in the SCAQMD SIP, and is in the AVAQMD SIP.

USEPA has a CTG for external floating roof tanks (E PA-450/2-78-047, 12/78) and fixed-roof tanks (EPA-4 50/2-77-036, 12/77).

AVAQMD has several tanks that meet the capacity req uirement in the fixed-roof tank CTG, but all are us ed to store fuel which is lower than the true vapor pressure requirement (JP5, JP8, Jet A, Jet A-1, Diesel and 1 010 oil). The AVAQMD has the potential to acquire sources that may be subject to the CTG applicabilit y threshold. Therefore the AVAQMD will not file a FND at this ti me but will update the rule to current Federal RACT when a source is acquired.

Applicable CTG(s) Emissions from Petroleum Liquid Storage in External Floating Roof Tanks, EPA-450/2-78-047, 12/78 Control of Volatile Organic Emissions from Storage of Petroleum Liquids in Fixed-Roof Tanks, EPA 450/2 -77-036, 12/77

# AVAQMD RACT SIP Analysis

July 2015 A-5 3. Rule 1102 – Petroleum Solvent Dry Cleaners

SCAQMD Rule 1102 (Amended 11/17/2000, SIP approved, 67 FR 46876 07/17/2002) AVAQMD Rule 1102 (Amended 12/07/1990, SIP approved, 57 FR 10136 03/24/1992) AV Rule 1102 RACT Deficiencies

Applicability Dry cleaning facility using solvent other than
PERC Petroleum Solvent Dry Cleaners Applicability does not include all solvents
besides PERC.

Definitions Terms added/removed from previous version to cover additional requirements Not as comprehensive, does not cover SCAQMD expanded applicability. Would need to be updated to cover more comprehensive applicability.

Operating Requirements Cartridge filters containing paper or carbon shall be fully drained in a sealed filter housing for 24 hours before removal.

Additional specifications for closed-loop
machines.

Transfer machines no longer allowed.

Leak check and repair requirements specified. Cartridge filters containing paper or carbon shall be fully drained in a sealed filter housing for 12 hours before removal. Increased drainage time for cartridge filters
from 12 to 24 hours.

Additional specifications for closed-loop machines not specified.

Transfer machines no longer allowed.

Leak check and repair requirements not specified as to frequency, specificity of SCAQMD Rule 1102.

Recordkeeping Pre-wash weight of materials/load Purchase and delivery receipts for solvent. Log of solvent added by operator. Inventory of solvent.
Amount of solvent used. Dates of leak inspections. Detection and repair log for leaks. Facility mileage for solvent used. All records maintained pursuant to Rule 109. Pre-washed weight of articles. Solvents purchased and solvent inventory. Maintain records pursuant to Rule 109. Less comprehensive recordkeeping than SC
1102.

Test Methods EPA Test Method 25 or SCAQMD Test Method 25.1 (March 1989). EPA Test Method 25 or SCAQMD Test Method 25.1 (March 1989). Same test methods specified.

Compliance Schedule Not allowed after 01/01/2001 - dip tanks, drying cabinets, closed-loop machine opened before completion of drying cycle. Not allowed after 01/01/2005 - Transfer
machines. By 01/01/1993 all petroleum solvent drycleaning facilities were to meet rule provisions. SCAQMD Rule no longer allows the operation of transfer machines, and they are still allowed in AVAQMD rule.

Notes AV SIP rule was the SC version prior to their
most recent amendment. Rule 1102 - Petroleum Solvent Dry Cleaners

Evaluation of RACT and recommendation

The AVAQMD does not have any sources that meet the CTG applicability threshold (The largest source in the AVAQMD is permitted for purchase of 82 gallons annually). The AVAQMD will not file a FND at this time but will update the rule to current Federal RA CT when a source is acquired. CTG Threshold

Consume ≥123,000 liters (32,483 gallons) of petrol eum solvent annually. Applicable CTG

Control of Volatile Organic Compound Emissions from Large Petroleum Dry Cleaners, EPA-450/3-82-009. 09 /1992.

# A-6 AVAQMD RACT SIP Analysis July 2015 4. Rule 1104 – Wood Flat Stock Coating Operations

SCAQMD Rule 1104 (Amended 08/13/1999, SIP approved, 65 FR 15240 03/22/2000) AVAQMD Rule 1104 (Amended 03/01/1991, SIP approved, 59 FR 32354 06/23/1994) AV Rule 1102 RACT Deficiencies

Applicability Applies to all persons applying coatings, inks, and adhesives to flat wood stock for the purpose of manufacturing a finished wood panel for attachment to the inside walls of buildings, including but not limited to, homes and office buildings, mobile homes, trailers, prefab buildings and similar structures, boats and ships; or a finished exterior wood siding intended for use in
construction. Applies to all persons applying coatings, inks, and adhesives to flat wood stock for the purpose of manufacturing a finished wood panel for attachment to the inside walls of buildings, including but not limited to, homes and office buildings, mobile homes, trailers, prefab buildings and similar structures, boats and ships; or a finished exterior wood siding intended for use in
construction. Same applicability.

Requirements Wood flat stock coatings, inks, and adhesives for interior wood panels and exterior wood siding - <250 g/l of coating, ink or adhesive, less water and exempt compound.

Added reference to Rule 1171 - Solvent Cleaning Operations *Wood flat stock coatings and adhesives for wood panels - <250 g/l of coating or adhesive, less water and exempt compound. *Wood flat stock inks - <300 g/l of VOC per liter of ink, less water and exempt compound. *Wood flat stock coatings for exterior wood siding - <350 g/l of VOC per liter of coating, less water and exempt compound. Wood flat sock inks for wood panels and wood flat stock coatings for exterior wood siding exceed the limits in SC
RACT version.

No Rule 1171 reference.

Recordkeeping Pursuant to Rule 109 (Amended 05/02/2003, Approved 69 FR 3018 01/22/2004) Pursuant to Rule 109 (Amended 4/20/2010, Approved 77 FR 12495 03/01/2012) Same recordkeeping requirements.

Test Methods, AECP, Exemption Same test methods, AECP, Exemptions
cited.

Notes AV SIP rule was the SC version prior to
their most current amendment.

15 lb/day (6.8 kg/day) Rule 1104 - Wood Flat Stock Coating Operations

Evaluation of RACT and recommendation

The AVAQMD does not have any sources that meet the CTG applicability threshold. The AVAQMD will not f ile a FND at this time but will update the rule to current Federal RACT when a source is acquired. Applicable CTG

Control of Volatile Organic Compounds Emissions fro m Existing Stationary Sources Volume VII: Factory S urface Coating of Flatwood Panelling ( EPA-450/2-78 -032, June 1978)

CTG Threshold

# AVAQMD RACT SIP Analysis

July 2015 A-7 5. 1106.1 – Pleasure Craft Coating OperationsApplicabilityVOC Content LimitApplication MethodsAdd-On ControlsSolvent Cleaning/Work PracticesExemptionsRule 1106.1Applicable to all coatingoperations of pleasure craft, ,or their parts andcomponents, for the purposeof refinishing,repairing, modification, ormanufacturing such craft. Alsoapplies to establishmentsengaged in activitiesdescribed under StandardIndustrial Classification (SIC)codes 3732 - Boat Building andRepairing and 4493 - Marinas.TopcoatsExtreme High Gloss 490High Gloss 420Pretreatment Wash Primers 780Finish Primer/Surfacer 420High Build Primer Surfacer 340Teak Primer 775 (non-CTG)Antifoulant CoatingsAluminum Substrate 560Other Substrates 150 (lower)Clear Wood FinishesSealers 550 (non-CTG)Varnishes 490 (non-CTG)Others 420Hand ApplicationHVLP or equivalentAdd-on Controls not specified.References Rule 1171 -Solvent CleaningOperations.Rule 1171 requirements adequately coverCTG recommended solvent cleaning workpractices.Aerosol coating products.EPA CTG:Control TechniquesGuidelines for MiscellaneousMetal and Plastic Parts (EPA453/R-08-003, September2008)Applicable to coatings that areapplied to the surfaces of avaried range of metal andplastic parts and products,including the metal andplastic componenets ofpleasure craft (recreationalboats).TopcoatsExtreme High Gloss 490 (4.1)High Gloss 420 (3.5)Pretreatment Wash Primers 780 (6.5)Finish Primer/Surfacer 420 (3.5)High Build Primer Surfacer 340 (2.8)Antifoulant CoatingsAluminum Substrate 560 (4.7)Other Substrates 340 (2.8)Others420 (3.5)Recommended control options specify useof one or more of the following coatingapplication methods in conjunction with theuse of low-VOC content coatings:electrostatic application, HVLP spray, flowcoat, roller coat, dip coat (includingelectrodeposition), airless spray, air-assisted airless spray, or other coatingapplication methods capable of achieving atransfer efficiency equivalent to or betterthan that achieved by HVLP spraying.Overall VOC control efficiency of 90% forfacilities that choose to use add-on controlsinstead of low VOC content coatings andspecified application methods.Cover mixing and storage vessels for VOC-containing cleaning materials, and cleanngwaste materials except when adding,removing or mixing contents.Used closed containers or pipes to store orconvey VOC-containing cleaning andcleaning waste materials.Minimize spills of VOC-containing cleaningand cleaning waste materials.Minimize VOC emissions during cleaningoperations.Recommends exemptionsrequired in SCAQMD Rule1106.1.SCAQMD Rule 1106.1(amended 02/12/1999,approved/RACT 64 FR 47393,08/31/1999)Same applicability asAVAQMD, except forreferences Rule 1106 - MarineCoating Operations, whichwas rescinded by AVAQMD.All coating limits are the same as AVAQMDRule 1106.1 except Antifoulant Coatings -Other Substrates than Aluminum, which hasincreasedfrom 150 to 330 g/L.Per SCAQMD January 1999 Staff Report, useof water-based antifoulants resulted inapplication problems, includingdelamination/blistering above the waterline, burn-back around metal fittings, andshorter service life. These problemsresulted in the unexpected growth ofmarine organisms in problem areas,requiring re-application and considerableexpense to boatyards.Removed Hand application, HVLP orequivalent. Application method not furtherspecified.Per SCAQMD January 1999 Staff Report, useof HVLP spray equipment led toperformance problems such as sags, orangepeel and other appearance imperfectionsdue primarily to the coating formulation.The use of HVLP spray equipment withcompliant coatings, which are higher insolids than their conventional counterparts,are routinely used illegally (i.e., greaterthan 10 psi) in order to avoid appearanceproblems such as sags and orange peel. Inan attempt to improve the flow propertiesof coatings sprayed with HVLP sprayequipment, additional thinner was added,causing an increase in emissions. Sincepleasure craft coating operations areconducted outdoors, weather conditionssuch as wind, humidity, and heatexacerbate an already difficult situation.Add-on Controls not specified.References Rule 1171 -Solvent CleaningOperations.Aerosol coating products.Evaluation for RACT:Rule 1106.1 - Pleasure Craft Coating Operations (Amended 6/13/1997)Conclusion/Recommendation:Rule does not require an update for federal RACT. If updated, the rule could be amended for several administrative items such as removing the reference to Rule 1160, which has been rescinded, and several test methods which have updatedreference numbers. None of these items affect federal RACT requirements.Rule 1106.1 meets or exceeds VOC and control requirements in CTG and most recent amendment of SCAQMD Rule 1106.1

# A-8 AVAQMD RACT SIP Analysis July 2015 6. Rule 1107 – Coating of Metal Parts and Products

Applicability VOC Control Device Efficiency Coating Application Methods

Rule 1107

Applies to all metal coatings operations except those performed on aerospace assembly, magnet wire, marine craft, motor vehicle, metal container, and coil coating operations. VOC limits consistant with those in CTG, except as noted:

- High Performance Architectural Coating limit is lower in AVAQMD rule. -AV rule does not include Drum Coating categories or limits*.

*The District does not currently have a drum coating facility, or expect any in the future. Not having drum coating categories at this time does not constitute a RACT deficiency at this time. Collect 90% with destruction efficiency of
at least 95% Electrostatic
HVLP Flow Coat
Roll Coater Dip Coat Hand Application Methods Equivalent to HVLP

Control Techniques Guidelines for
Miscellaneous Metal and Plastic Parts Coatings (EPA-453/R-08-003, September 2008)

These miscellaneous metal products include, but are not limited to, metal components of the following types of products as well as the products themselves: fabricated metal products, small and large farm machinery, commercial and industrial machinery and equipment, automotive or transportation equipment, interior or exterior automotive parts, construction equipment, motor vehicle accessories, bicycles and sporting goods, toys, recreational vehicles, pleasure craft (recreational boats), extruded aluminum structural components, railroad cars, heavier vehicles, lawn and garden equipment, business machines, laboratory and medical equipment, electronic equipment, steel drums, metal pipes, and numerous other industrial and household products. Coating Categories and limits (g/L) not
included:

Drum Coating, New, Exterior (Air-dried, 340/Baked, 340) Drum Coating, New, Interior (Air-dried, 420/Baked, 420) Drum Coating, Reconditioned, Exterior (Air-dried, 420/Baked, 420) Drum Coating, Reconditioned, Interior (Air-dried, 500/Baked, 500) 90% overall control efficiency. Electrostatic
HVLP Flow Coat
Roller Coat Dip Coat (electrodeposition) Airless Spray Air-assisted airless spray Equivalent to HVLP

SCAQMD Rule 1107 General has been separated out to OneComponent and Multi-component Categories. One-Component air-dried
limit lower than CTG and AV version.

Extreme High-Gloss, Air-dried lowered
to 340.

Prefabricated Architectural separated to One-Component and Multi-Component. One-Component and Multi-Component
air-dried limits lower than CTG and AV
version.

SCAQMD added separate Rule 1125 to cover steel pail and drum coatings. Collect 90% with destruction efficiency of
at least 95% Electrostatic
Flow coat
Roll coat Dip coat
HVLP Hand application methods Printing techniques (inkjet) Equivalent to HVLP Rule 1107 - Coating of Metal Parts and Products

Evaluation for RACT:

Conclusion/Recommendation: Rule 1107 is consistent with the CTG, but several V OC limits in SCAQMD Rule 1107 are slightly lower.

Amend Rule 1107 to meet federal RACT requirements.

# AVAQMD RACT SIP Analysis

July 2015 A-9 7. Rule 1110.2 – Emissions from Gaseous and Liquid Fueled Internal C ombustion Engines

AVAQMD Rule 1110.2 - Emissions From Stationary, Non -road & Portable Internal Combustion Engines 1

1 

## Rule 1110.2 was originally adopted by SCAQMD on 08/ 03/1990 and amended 09/07/1990, 08/12/1994 and 12/09/1994. EPA did not approve any of these rule versions into the SIP. The AVAQMD subsequently amen ded Rule 1110.2 on 05/15/2001 and 01/21/2003. On 04/21 /2004, EPA proposed a limited approval/limited disa pproval (69 FR 21482, 04/21/2004) of the revision. The LA/ LD was based on the agricultural ICE exemption. T he LA/LD also included a request for justification of the seasona l exemption for ICE used for snow manufacturing and ski lift operation, request for correction of several citati ons, and increasing record retention from 2 years t o 5 years. Specifically, EPA determined that the Ag exemption, and possibly the snow/ski exemption, disqualified Rule 1110.2 from meeting RACT.

Evaluation for RACT and recommendation Rule 1110.2 is not RACT. Rule 1110.2 must be updat ed to remove the Ag exemption and address other EPA comments identified in the LA/LD (69 FR 21482, 04/2 1/2004).

# A-10 AVAQMD RACT SIP Analysis July 2015 8. Rule 1141.1 – Coatings and Ink Manufacturing

AVAQMD Rule 1141.1 - Coatings and Ink

Manufacturing SCAQMD Rule 1141.1 - Coatings and Ink Manufacturing RACT Deficiencies

Amended 03/06/1992 (SIP version amended 03/14/1984, approved 01/24/1985, 50 FR 3338) Amended 11/17/2000 (02/12/2002, 67 FR 6410)

Applicability Coatings manufacturer - establishment that

mixes, blends, and/or compounds paints, varnishes, lacquers, enamels, shellacs, or sealers, and is classified as 2851 in the SIC
Manual.

Ink manufacturer - establishment that mixes, blends, and/or compounds printing inks and
is classified as 2893 in the SIC Manual. Coatings manufacturer - establishment that mixes, blends, and/or compounds paints, varnishes, lacquers, enamels, shellacs, or sealers, and is classified as 2851 in the SIC
Manual.

Ink manufacturer - establishment that mixes, blends, and/or compounds printing inks and
is classified as 2893 in the SIC Manual. Same applicability.

Definitions Still have definition for ROG. Definition added for exempt compound, updated for VOC and waterbased coating. Update definitions

Requirements Reference ROG rather than VOC. Same requirements, but reference VOC
rather than ROG. Update reference from ROG to VOC.

Recordkeeping None Maintain daily or monthly records, including type and amount of each coating/ink manufactured, type and amount of each VOC containing material in each coating or ink, the type and VOC content of each solvent used for clean-up used.

Maintain records for 2 years. Add recordkeeping requirements.

Exemptions Added exemption from rule provisions except recordkeeping if manufacture less than 11,000 gallons of coatings and/or inks per calendar month. Will evaluate adding additional exemption. All other exemptions the same.

Compliance Lists dates for compliance with rule

requirements. Have been removed from SCAQMD rule amendment. May be removed from AVAQMD rule if no longer necessary.

Fees Permit application linked to filing of

compliance plan. May be required to submit engineering evaluation fee as well. This provision has been removed from SCAQMD rule. May be removed from AVAQMD rule if no longer necessary.

AVAQMD has no major sources subject to the provisio ns of Rule 1141.1. This rule is not required to me et RACT and does not require updating at this time. If the AVAQMD acquires a major source, the rule wil l be re-evaluated for RACT at that time. Rule 1141.1 - Coatings and Ink Manufacturing

Applicable CTGs

Control of Volatile Organic Emissions from Existing Stationary Sources, Volume I: Control Methods for Surface Coating Operations (EPA-450/2-76-028, 11/76, NTIS PB-260-386). Although often listed wit h the CTGs for historical reasons, this document do es not define RACT for any source. It is a compilat ion Control of VOC Emissions from Ink and Paint Manufac turing Processes (EPA-450/3-92-013, 4/92)

Evaluation for RACT and recommendation

# AVAQMD RACT SIP Analysis

July 2015 A-11 9. Rule 1145 – Plastic, Rubber and Glass Coatings

AV Rule 1145 - Plastic, Rubber, and Glass Coatings 1 SC Rule 1145 - Plastic, Rubber, Leather, and Glass Coatings RACT Deficiencies

SIP Version Amended 01/10/92 (12/20/1993, 58 FR 6628 6) Amended 12/04/2009 (07/14/2010, 75 FR 40726)

Applicability Reduce VOC emissions from the application

of coatings to any plastic, rubber or glass product. Reduce VOC emissions from the application of coatings to any plastic, rubber, leather or glass products. Evaluate if need to expand applicability to include leather coatings.

Definitions Several definitions have been added/removed/updated: carpet backing, coating,extreme performance coating, HVLP, leather antique coating, leather color coating, leather sealer coating, leather stain coating, leather top coating, refrigerated glass door coating, vacuum metalizing/physical vapor deposition. Update definitions as needed and add definitions for leather coatings if leather is added to applicability.

VOC Limits Several higher VOC limits: General Coatings

(one- and two-component), multi-colored coatings, mirror backing (roll coated), optical coatings. Added categories: extreme performance, leather, refrigerated glass doors. Update VOC limits if cost-effective, and add new categories if needed.

Requirements Remove 1151 references if now contained in

1151.

Update transfer efficiency requirement. Added qualification for classification as extreme performance. Add extreme performance coating qualification, update transfer efficiency requirement, remove 1151 reference if applicable. Compliance Test
Methods Update test methods to include additional

references. Added determination of efficiency of emission control system. Update test methods.

Prohibition of Sale Additional language. Update prohibition of sale requirements if applicable.

Exemptions Update exemption for clear and translucent

coatings. Added exemption applicable to polyurethane shoe sole coating. Update exemptions.

1 The version of Rule 1145 in the AVAQMD Rule book i s as amended by SCAQMD 02/14/1997. The AVAQMD sepa rated from the SCAQMD on 07/01/1997, prior to the submission of this rule to USEPA on 08/01/1997. The SCAQMD approval of the 02/14/1997 version (05 /04/1999, 64 FR 23774) specifically excluded the AVAQMD from the aproval action. The RACT analysis w ill compare the rulebook version to the SCAQMD SIP version. Applicable CTGs
CTG for Miscellaneous Metal and Plastic Parts Coati ngs (EPA-453/R-08-003, September 2008) Rule 1145 - Plastic, Rubber and Glass Coatings

Evaluation of RACT and recommendation Update Rule 1145 to address deficiencies noted in R ACT rule analysis with SCAQMD Rule 1145.

# A-12 AVAQMD RACT SIP Analysis July 2015 10. Rule 1146 - Emissions Of Oxides Of Nitrogen From Industrial, In stitutional And Commercial Boilers, Steam Generators, And Process H eatersAVAQMD Rule 1146 - Emissions of Oxides of Nitrogenfrom Industrial, Institutional, and Commercial Boilers,Steam Generators, and Process Heaters, Adopted5/13/1994 (SIP approved 09/06/1995, 60 FR 46220)SCAQMD Rule 1146 - Emissions of Oxides of NitrogenfromIndustrial, Institutional, and Commercial Boilers,SteamGenerators, and Process Heaters, Amended 11/17/2000(SIP approved 04/08/2002, 67 FR 16640)SJVUAPCD Rule 4306 - Boilers, Steam Generators, andProcess Heaters - Phase 3, Amended 10/16/2008 (SIPApproved 01/13/2010, 75 FR 1715)RACT DeficiencyApplicabilityBoilers, steam generators, and process heaters of equalto or greater than 5 million Btu per hour rated heat inputcapacity used in all industrial, institutional operationswith the exception of boilers used by electric utilities togenerate electricity, boilers and process heaters with arated input capacity greater than 40 MMBtu per hourused in petroleum refineries, and sulfur plant reactionboilers.Boilers, steam generators, and process heaters of equal toor greater than 5 million Btu per hour rated heat inputcapacity used in all industrial, institutional operations withthe exception of boilers used by electric utilitiestogenerate electricity, boilers and process heaters with arated input capacity greater than 40 MMBtu per hourusedin petroleum refineries, and sulfur plant reactionboilers.Any gaseous fuel or liquid fuel fired boiler, steamgenerator, or process heater with a total rated heatinput greater than 5 million Btu per hour.≥ 5 million Btu/hr and> 90,000 Therms fuel use40 ppm NOx (gaseous, liquid or solid fuel)400 CO40 ppm NOx (gaseous fuels)40 ppm Nox (combination gaseous/non-gaseous - ≥5 and<40)400 ppm CO≥ 40 million Btu/hr and> 25% annual capacity factor30 ppm NOx400 CO30 ppm Nox400 ppm CO≥ 40 million Btu/hr and> 25% annual capacity less than factor and >90,000Therms40 ppm NOx400 CO40 ppm NOx (≥ 40 million Btu/hr and rated heat input ≤25% burning gaseous and non-gaseous)400 ppm COAny unit with rated heat input capacity ≥ 5 millionBtu/hr, annual heat unput ≤ 90,000 Therms shall:-maintain stack gas [O2] at ≤ 3% on a dry basis forany consecutive 15-min averaging period; or-be tuned at least 2x/year according to proceduresin attachment or manufacturer's specifications fortune-up. ≥ 40 million Btu/hr and and annual heat input >200x 109shall have a continuous in-stack nitrogenoxides monitor or equivalent verification systemin compliance with 40 CFR 60 Appendix B Spec. 2. CEMS for any unit subject to emission limits orapproved alternative monitoring system≥ 10 million Btu/hr and burning gaseous fuels30 ppm Nox400 ppm CO≥ 10 million Btu/hr and burning combination ofgaseous and non-gaseous fuels30 ppm Nox400 ppm CO≥ 5 million Btu/hr and <10 Btu/hr30 ppm Nox400 ppm CO≤ 20 MMBtu/hrStd/Gaseous - 15 ppmvEnhanced/Gaseous - 9 ppmvLiquid - 40 ppmvCO - 400 ppm> 20 MMBtu/hrStd/Gaseous - 9 ppmvEnhanced/Gaseous - 6 ppmvLiquid - 40 ppmvCO - 400 ppmLoad-following UnitsStd/Gaseous - 15 ppmvEnhanced/Gaseous - 9 ppmvLiquid - 40 ppmvCO - 400 ppmUnits limited by PTO to annual heat input of 9billion Btu/year to 30 billion Btu/yearGaseous - 30 ppmvLiquid - 40 ppmvCO - 400 ppmvUnit in which the rated heat input of each burner is≤5 MMBtu/hr but total of all burners in unit is > 5MMBtu/hr, and the products of combustion do notcome in contact with the products of combustionof any other burnerGaseous - 30 ppmvLiquid - 40 ppmvCO - 400 ppmvEvaluation for RACT and recommendationWill survey affected units for applicability and determine if it is feasible to update limits as RACT.Emission LimitsAVAQMD Rule 1146 - Emissions of Oxides of Nitrogenfrom Industrial, Institutional, and Commercial Boilers, Steam Generators, and Process HeatersWill survey affected units forapplicability and determine ifit is feasible to update limitsas RACT.

# AVAQMD RACT SIP Analysis

July 2015 A-13 11. Rule 1146.1 – Emissions of Oxides of Nitrogen from Small Industri al, Institutional, and Commercial Boilers, Steam Generators, and Process H eaters

AVAQMD Rule 1146.1, Amended 05/13/1995 SJVUAPCD Rule 4307 - Boilers, Steam Generators, and Process Heaters - 2.0 MMBtu/hr to 5.0 MMBtu/hr, Amended 10/16/2008 RACT deficiencies

SIP Version SIP approved 09/06/1995, 60 FR 46220 SIP approved 01/13/2010, 75 FR 1715

Applicability Boilers, steam generators, and process heaters that are greater than 2 million Btu per hour and less than 5 million Btu per hour rated heat input capacity used in any industrial, institutional, or commercial operation. Gaseous fuel or liquid fuel fired boiler, steam generator, or process heater with a total rated hea t input of 2.0 million Btu per hour up to and including 5.0 MMBtu/hr. AVAQMD rule does not have different limits for liquid and gaseous fueled boilers, steam generators, or process heaters in applicability. Both liquid and gaseous have same limit in AVAQMD rule, where liquid fired units in SJUAPCD rule has higher NOx limit for liquid fueled units.

Definitions Many definitions have been added or modified. May need to be updated for clarification or new requirements.

Exemptions NOx and CO limits do not apply if:

Non-resettable, totalizing fuel meter demonstrating that unit operates less than 18,000 therms per calendar year.

Records list cumulative fuel annual usage for preceding calendar year.

Must maintain stack-gas oxygen concentrations, be tuned twice per year, submit compliance plan. 1. Solid fuel fired units. 2. Dryers and glass melting furnaces. 3. Kilns, humidifiers, and smelters where the products of combustion come in direct contact
with the material to be heated. 4. Unfired or fired waste heat recovery boilers tha t are used to recover or augment heat from the exhaust combustion of gas turbines or ICE.
5. NOx and CO limits shall not be enforced when burning other than PUC fuel during an approved
curtailment. Add exemptions if applicable.

Requirements Standards for NOx and CO. Standards for NOx, CO, PM and SOx, as well as newand replacement atmospheric and nonatmospheric units. The AVAQMD is not nonattainment for PM 10 and SOx, and does not need to incorporate these limits in the rule. The requirements for new and replacement units would be evaluated for BACT at major facilities. Therefore, the RACT limits for NOx and CO in AVAQMD Rule 1146.1 are the same
as those in SJVUAPCD 4307. Equipment Tuning Procedure Appendix A, Rule 1146.1 Rule 4304 Contains same info. No update necessary.

Start-up, shutdown 6-hr time limit for start-up, shu t down. Places 1-hr or 2-hr requirements on start-up and
shutdown Expand start-up, shutdown requirements.

Monitoring Provisions Tune-up provision, operational non-resettable, totalizing mass or volumetric flow meters on each
line. Monitor manufacturer recommended operational
characteristics once a month. Operational non-resettable, totalizing mass or volumetric flow meters on each line, or a master

meter. Add monthly monitoring of manufacturer recommended operational characteristics.

Test Methods May need to update several test methods
referenced. Recordkeeping 2 years 5 years Update record retention to 5 years. Additional Requirements To be analyzed as necessary for applicability.

AVAQMD Rule 1146.1 - Emissions of Oxides of Nitroge n from Small Industrial, Institutional, and Commerc ial Boilers, Steam Generators, and Process Heaters 1

1 The SCAQMD rule amendment in the SIP is identical to the AVAQMD rulebook version. SCAQMD most recentl y amended Rule 1146.1 - Emissions of Oxides of Nitr ogen from Small Industrial, Institutional, and Commercial Boilers, Steam Generators, and Process Heaters on 11/01/2013 . This version has not been updated as a SIP appro ved RACT rule on the Region 9 SIP site, nor does it appear that CARB has yet subm itted this amendment to USEPA. The prior 09/05/200 8 SC amendment received proposed Limited Disapprova l/Limited Approval from
USEPA. Evaluation of RACT and recommendation
NOx and CO limits are consistent with current RACT limits in SJVUAPCD Rule 4307 as well as SCAQMD Rule 1146.1. These rules, as well as the TSD for the S CAQMD 09/05/2008 amendment will be used for updating requirements during next rule update.

Applicable CTG(s) ACT Document - NOx Emissions from Industrial/Commer cial/Institutional (ICI) Boilers, USEPA 453/R-94-02 2, March 1994. ACT Document - NOx Emissions from Utility Boilers, USEPA 452/R-93-008, March 1994.

# A-14 AVAQMD RACT SIP Analysis July 2015 12. Rule 1151 – Motor Vehicle and Mobile Equipment Coating Operatio ns

Rule 1151 - Motor Vehicle and Mobile Equipment Coating Operatio ns Applicable CTGs

Control Techniques Guidelines for Automobile and Li ght Duty Truck Assembly Coatings, EPA 453/R-08-006, 09/2008.

Protocol for Determinng the Daily Volatile Organic Compound Emission Rate of Automobile and Light-Duty Truck Primer-Surfacer and Topcoat Operations, EPA 453/R-08-022, 09/2008. CTG Applicability

This CTG applies to the application of coatings in automobile and light-duty truck assembly coatings, which includes heavier vehicles (buses) as defined at 40 CFR
63.3176. Evaluation for RACT

Rule must be amended to incorporate provisions of C ontrol Techniques Guidelines for Automobile and Light-Duty Truck Asse mbly Coating as applicable to “Heavier” vehicles, which includes all vehicles tha t meet the definition of the term “other motor vehicles”, as defined at 40 CFR § 63.3176. BYD Coach and Bus is not a major source but is permitted above the CTG f or Automobile and Light Duty Truck Assembly Coatings .

# AVAQMD RACT SIP Analysis

July 2015 A-15 13. Rule 1171 – Solvent Cleaning Operations

Rule 1171

Amended 11/17/98 SIP Approved 05/24/01, 66 FR 28666 CTG

Control Techniques Guidelines for Industrial Cleaning Solvents, EPA-453/R-06-001, 09/2006 RACT Evaluation

Applicability VOC Containing materials in

solvent cleaning operations during the production, repair, maintenance or servicing of parts, products, tools, machinery, equipment, or general work areas, and storage and disposal of VOC containing materials. Use organic solvent for cleaning operations such as mixing vessels (tanks), spray booths, and parts cleaners where a facility emits at lt least 15 lb/day of VOC before
consideration of controls in an
ozone nonattainment area.

CTG recommends particular cleaning activities are only subject to one set of requirements

Work Practices Not specified. 1. Cover open containers and used applicators.
2. Minimize air circulation around cleaning operations. 3. Properly dispose of used solvent and shop towels. 4. Implement equipment practices that minimize
emissions. Add work practices.

VOC limits 50 grams VOC per liter for each of the 9 unit operations (spray gun cleaning, spray booth cleaning, large manufactured components cleaning, parts cleaning, equipment cleaning, line cleaning, floor cleaning, tank cleaning, small manufactured components cleaning) Need to update rule to reference source specific rules, and VOC
limits

Overall Control Efficiency Collect 90%, 95% destruction 85% Meets

Alternative Composite Vapor
Pressure Limit Several below, several above

recommended limit 8 mmHg at 20°C, as a replacement or alternative limit to 50 g/l VOC. Update Rule 1171 - Solvent Cleaning Operations

Evaluation of RACT and recommendation Update Rule 1171 to include work practices, adjust categories for consistency with source specific rul es, include alternative composite vapor pressure limit.

# A-16 AVAQMD RACT SIP Analysis July 2015 14. Rule 1176 – VOC Emissions From Wastewater Systems