SACRAMENTO METROPOLITAN 

AIR QUALITY MANAGEMENT DISTRICT

STAFF REPORT 

Analysis of Reasonably Available Control Technology for the 8-Hour Ozone State 

Implementation Plan (RACT SIP) 

September 26, 2006 

Prepared by: Kevin J. Williams, Ph.D. 

Program Coordinator

Reviewed by: Aleta Kennard 

Program Supervisor

Approved by: Brigette Tollstrup 

Division Manager
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 1 

BACKGROUND

The U.S. Environmental Protection Agency (EPA) published the final Phase 2 Rule to implement 

the 8-hour ozone air quality standard on November 29, 2005 (70 FR 71611). Among the 

requirements of the Phase 2 Rule, a new section was added to the Code of Federal Regulations 

(40 CFR 51.912) that requires the District to submit a revision to the State Implementation Plan 

(SIP) that meets the Reasonably Available Control Technology (RACT) requirements for VOC and 

NOx in accordance with Sections 182(b)(2) and 182(f) of the federal Clean Air Act. This 

requirement is known as the RACT SIP. 

EPA defines RACT (44 FR 53762) as “the lowest emission limitation that a particular source is 

capable of meeting by the application of control technology that is reasonably available considering 

technological and economic feasibility.” Sections 182(b)(2) and 182(f) of the Clean Air Act require 

the District to implement RACT for: 

• Each category of VOC sources that is covered by a Control Technique Guideline (CTG) 

document issued by EPA; and 

• All major stationary sources of VOC and/or NOx. 

EPA’s designations and classifications for the 8-hour ozone standard were published on April 30, 

2004 (69 FR 23857) and became effective on June 15, 2004. The Sacramento Metropolitan Area 

was classified as a serious nonattainment area, with a deadline of 2013 to attain the standard. The 

major source emissions threshold for areas classified as serious is 50 tons per year of either VOC 

or NOx. 

EPA Region 9 provided guidance for the RACT SIP submittal in a letter from Andrew Steckel dated 

March 9, 2006. The following elements were included in the recommended strategy: 

• Describe efforts to identify all source categories within the District requiring RACT, including 

CTG sources (i.e., covered by an EPA Control Technique 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 state/local 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 Technique guidance (ACTs) , 

Maximum Achievable Control Technology (MACT) standards, New Source Performance 

Standards (NSPS), California Suggested Control Measures (SCM) and RACT/Best 

Available Retrofit Control Technology (BARCT) determinations, regulations adopted in other 

Districts, and guidance and rules developed by other state and local agencies. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 2 

The purpose of this staff report is to provide sufficient analysis of the CTG categories and major 

sources within the District to determine whether the District meets the requirements of RACT. 

RACT ANALYSIS 

The process Staff used to demonstrate compliance with federal RACT requirements consists of the 

following steps: 

• For CTG source categories for which the District has no applicable rule, verify that the 

District has no sources in these categories. 

• For CTG source categories for which the District has an applicable rule, perform a detailed 

comparison of the rule requirements with applicable CTG and other RACT guidance 

documents. Appendix A contains the analyses for CTG source categories. 

• For non-CTG source categories that are found at one or more major sources within the 

District, perform a detailed comparison of the rule requirements applicable to those source 

categories with relevant RACT guidance documents. Appendix B contains the analyses for 

these non-CTG source categories. 

• For major sources, determine the types of emission units at the facility and determine which 

District rules apply to these sources. The RACT requirement is satisfied for a major source 

when all units that emit VOC or NOx are subject to rules that have been determined to 

satisfy RACT (as demonstrated in Appendix A or B). Appendix C contains the analyses for 

major sources. 

EPA Region 9 provided a list of CTG categories and documents in a letter from Andrew Steckel 

dated April 4, 2006. Staff reviewed the list, and determined which District rules are applicable to the 

CTG categories. For categories where the District has no applicable rule, Staff reviewed the 

database of permitted sources and the yellow pages to determine whether there are any sources in 

these categories. Staff determined that there are no CTG categories for which the District has 

sources but no applicable rule. Table 1 lists the CTG categories, the applicable District rules, and 

the SIP status of the rules. 

Table 1 – CTG Source Categories 

CTG Category CTG Date 

SMAQMD 

Rule No. 

(Most Recent 

Amendment) 

SIP Status 

Aerospace 

Manufacturing 

Dec. 1997 456 (7/23/98) Adopted 9/5/96; Approved 11/9/98 

Automobile Coating May 1977 No Sources 

Cutback Asphalt 1977 453 (8/31/82) Adopted 8/31/82; Approved 1/24/85 

Dry Cleaning 

(Petroleum Solvent) 

Sep. 1982 No Sources 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 3 

CTG Category CTG Date 

SMAQMD 

Rule No. 

(Most Recent 

Amendment) 

SIP Status 

Gasoline Service 

Stations 

Nov. 1975 448 (2/2/95) 

449 (9/26/02) 

Adopted 2/2/95; Approved 1/23/96 

Adopted 9/26/02; Approved 3/24/03 

Gasoline Tank Trucks 

and Bulk Plants 

Oct. 1977, 

Dec. 1977 and 

Dec. 1978 

447 (4/2/98) 

448 (2/2/95) 

Adopted 4/2/98; Approved 11/26/99 

Adopted 2/2/95; Approved 1/23/96 

Graphic Arts 

(Rotogravure) 

Dec. 1978 No Sources 

Graphic Arts 

(Flexographic) 

Dec. 1978 450 (3/23/00) Adopted 12/5/96; Approved 11/13/98 

Large Appliance 

Coating 

1977 No Sources 

Magnetic Wire Coating Dec. 1977 No Sources 

Metal Can Coating May 1977 452 (9/5/96) Adopted 9/5/96; Approved 11/9/98 

Metal Coil Coating May 1977 No Sources 

Metal Furniture 

Coating 

Dec. 1977 451 (10/2/97) Adopted 11/29/83; Approved 1/24/85 

Adopted 9/5/96; No EPA Action 

Metal Parts and 

Products Coating 

June 1978 451 (10/2/97) Adopted 11/29/83; Approved 1/24/85 

Adopted 9/5/96; No EPA Action 

Natural Gas/Gasoline 

Processing 

Dec. 1983 No Sources 

Paper and Fabric 

Coating 

May 1977 No Sources 

Petroleum Liquid 

Storage Tanks 

Dec. 1977 and 

Dec. 1978 

446 (11/16/93) Adopted 11/16/93; Approved 9/16/94 

Pharmaceutical 

Products 

Manufacturing 

Dec. 1978 455 (9/5/96) Adopted 11/29/83; Approved 1/24/85 

Adopted 9/5/96; No EPA Action 

Resin Manufacturing – 

High Density 

Polyethylene, 

Polypropylene, and 

Polystyrene 

Nov. 1983 and 

Mar. 1984 

No Sources 

Refineries Oct. 1977 and 

June 1978 

No Sources 

Rubber Tire 

Manufacturing 

Dec. 1978 No Sources 

Ship Coating Aug. 1996 No Sources 

Solvent Cleaning 

(Degreasers) 

Nov. 1977 454 (5/23/02) Adopted 4/3/97; Approved 4/2/99 

Synthetic Organic 

Chemical 

Manufacturing 

Mar. 1984, 

Dec. 1984 and 

Aug. 1993 

443 (9/5/96) 

464 (7/23/98) 

443: Adopted 9/5/96; Approved 11/9/98 

464: Adopted 7/23/98; Approved 4/19/00 

Wood Coating (Flat 

Wood Paneling) 

June 1978 No Sources 

Wood Furniture 

Coating 

Apr. 1996 463 (7/23/98) Adopted 12/5/96; No EPA Action 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 4 

Staff reviewed the permitting records of sources within the District to compile a list of major sources 

of VOC and/or NOx. Because the District is classified as a serious nonattainment area for the 8-

hour ozone standard, major sources are those for which the potential-to-emit exceeds 50 tons per 

year of either VOC or NOx. Table 2 lists the major sources within the District. 

Table 2 – Major Sources of VOC and NOx within SMAQMD 

Major Source Major Pollutant(s) 

Aerojet VOC, NOx 

Campbell Soup NOx 

Carson Energy NOx 

Chevron VOC 

Kiefer Landfill VOC, NOx 

Procter and Gamble VOC 

Sacramento Cogeneration Authority NOx 

Santa Fe Pacific Pipeline VOC 

SMUD Cosumnes Power Plant NOx 

UCD Med Center NOx 

Because many of the major sources contain emission units that do not fall into one of the CTG 

categories, it was necessary to perform analysis of additional source categories. Table 3 lists the 

additional categories that were analyzed. 

Table 3 – Additional (Non-CTG) Source Categories Applicable to Major Sources 

Source Category 

SMAQMD 

Rule No. 

(Most Recent 

Amendment) 

SIP Status 

Architectural Coatings 442 (5/24/01) Adopted 9/5/96; Approved 11/9/98 

Boilers, Process 

Heaters, and Steam 

Generators 

411 (10/27/05) Adopted 2/2/95; Approved 2/9/96 

Adopted 1/9/97; No EPA Action 

Adopted 10/27/05; No EPA Action 

Gas Turbines 413 (3/24/05) Adopted 5/1/97; Approved 2/11/99 

IC Engines 412 (6/1/95) Adopted 6/1/95; Approved 4/30/96 

Municipal Landfill Gas NSPS Subpart WWW 

NESHAP Subpart AAAA 

N/A 

Organic Chemical 

Manufacturing – Tanks 

≤ 40,000 Gallons 

464 (7/23/98) Adopted 7/23/98; Approved 4/19/00 

Organic Chemical 

Manufacturing – 

Wastewater 

464 (7/23/98) Adopted 7/23/98; Approved 4/19/00 

Solvent Cleaning (other 

than Degreasers) 

466 (5/23/02) Not yet submitted 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 5 

CONCLUSION 

Based on the analysis performed in Appendices A, B, and C, Staff finds that the District has fulfilled 

the requirements of RACT, as applicable to the 8-hour ozone standard, for all CTG source 

categories and for all major sources of VOC and NOx, with the following exception. At the Kiefer 

Landfill, a major source of NOx, the emissions of NOx from the flare are not limited by a SIPapproved rule. 

The RACT deficiency will be remedied by submitting for inclusion in the SIP the portions of the 

permit that require a NOx limit of 0.06 lb/mmBtu for the flare and the associated testing and 

recordkeeping requirements. The permit to be submitted is included in Appendix D. 

The District has no sources in the following CTG categories, based on a review of District permitting 

records, yellow pages, and the District’s enforcement program for unpermitted sources: 

• Automobile Coating (the CTG applies only to automotive assembly plants, not refinishing 

operations) 

• Dry Cleaning (Petroleum Solvent) 

• Graphic Arts (Rotogravure) 

• Large Appliance Coating 

• Magnetic Wire Coating 

• Metal Coil Coating 

• Natural Gas/Gasoline Processing (the CTG applies to plants that separate and/or 

fractionate natural gas liquids from field gas, and does not apply to compression stations 

and dehydration units alone) 

• Paper and Fabric Coating 

• Resin Manufacturing – High Density Polyethylene, Polypropylene, and Polystyrene 

• Refineries 

• Rubber Tire Manufacturing 

• Ship Coating 

• Wood Coating (Flat Wood Paneling) 

ENVIRONMENTAL REVIEW AND COMPLIANCE 

The proposed SIP revision will make the existing NOx emission limit for the Kiefer Landfill flare 

federally enforceable. The source already meets the emission limit. Therefore, Staff has 

determined that the adoption of these rule commitments is exempt from the California 

Environmental Quality Act (CEQA) under Section 15061(b)(3) of the State CEQA Guidelines 

because it can be seen with certainty that there is no possibility that the activity in question may 

have a significant adverse effect on the environment. 

APPENDICES 

Appendix A: RACT Analysis of CTG Source Categories 

Appendix B: RACT Analysis of Non-CTG Source Categories Applicable to Major Sources 

Appendix C: RACT Analysis of Major Sources 

Appendix D: Permit to Operate 17359 for the Kiefer Landfill Flare 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 6 

Appendix A 

RACT Analysis of CTG Source Categories 

CTG Category 

Page 

Number

Aerospace Assembly and Component Coating Operations 7 

Cutback Asphalt 12 

Gasoline Service Stations 14 

Gasoline Tank Trucks and Bulk Plants (Liquid Loading) 16 

Graphic Arts Operations 19 

Metal Can Coating 22 

Surface Coating of Metal Furniture 25 

Surface Coating of Miscellaneous Metal Parts and Products 27 

Storage of Petroleum Products (> 40,000 gallons) 30 

Pharmaceuticals Manufacturing 33 

Solvent Cleaning (Degreasers) 35 

Organic Chemical Manufacturing. Process Vents from Reactor Processes, 

Distillation Operations, and Other Separation and Production Equipment 

38 

Leaks from Synthetic Organic Chemical and Polymer Manufacturing 41 

Wood Furniture Manufacturing (Surface Coating) 44 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 7 

Category: Aerospace Assembly and Component Coating Operations 

EPA RACT Guidance

Guideline Series: Control of Volatile Organic Compound Emissions from Coating 

Operations at Aerospace Manufacturing and Rework Operations. U.S. EPA Publication 

No. EPA-453/R-97-004, December 1997. 

Applicability 

The CTG applies to the manufacture or rework of commercial, civil, or military aerospace 

vehicles or components. 

The model rule exempts the following from VOC limits: 

• Cleaning and coating associated with research and development, quality control, 

laboratory testing, and electronic parts and assemblies (except for cleaning and 

coating of completed electronic assemblies). 

• Manufacturing and rework operations involving space vehicles, antique 

aerospace vehicles and components. 

• Touch up, aerosol, and Department of Defense “classified” coatings (protected 

against unauthorized disclosure for national security purposes). 

• Coatings used in volumes of 50 gallons per year or less of each formulation, not 

to exceed 200 gallons per year for all exempt coatings combined. 

RACT Requirements

The CTG establishes the presumptive RACT for the following coatings by referring to the 

VOC limits in the aerospace NESHAP (40 CFR 63, subpart GG): 

Coating Type 

VOC Content Grams/Liter (Lbs/Gal) 

less water and exempt compounds 

Chemical Milling Maskant - Type I 622 (5.2) 

Chemical Milling Maskant - Type II 160 (1.3) 

Primer 350 (2.9) 

Primer – General aviation rework 540 (4.5) 

Topcoat 420 (3.5) 

Topcoat – General aviation rework 540 (4.5) 

In addition, the CTG establishes VOC limits for 57 specialty coating categories that are 

exempt from the VOC and HAP limits in the aerospace NESHAP. These limits are listed 

in Table A at the end of this analysis. 

The CTG also includes the following requirements: 

• Hand wipe cleaning operations: use aqueous cleaners or cleaners with a VOC 

composite vapor pressure no greater than 45 mmHg at 20 C. (13 types of 

cleaning operations are exempt from this requirement). 

• Flush cleaning: capture non-aqueous solvents in closed containers or with wipes 

that are kept in closed containers. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 8 

• Spray gun cleaning: use enclosed gun cleaners or work practices that avoid open 

atomized spraying of VOC solvent. 

• Housekeeping practices to reduce VOC emissions from non-aqueous solvents, 

wipes, and spills. 

Other Federal Requirements

The NESHAP (40 CFR 63, subpart GG) for Aerospace Manufacturing and Rework 

Facilities establishes coating limits for organic HAP and VOC that are identical. These 

limits are presented in the earlier table summarizing presumptive RACT. 

SMAQMD Requirements

District Rule 456 Implements RACT with the emission limits listed in the following table 

and the work practice requirements in the bullets below: 

Coating Type 

VOC Content: Grams/Liter (Lbs/Gal) 

less water and exempt compounds 

Ablative 600 (5.0) 

Adhesive 600 (5.0) 

Adhesive Bonding Agent 780 (6.5) 

Conformal 600 (5.0) 

Electrostatic Discharge 612 (5.1) 

Extreme Performance 750 (6.3) 

Fire Resistant/Retardant 600 (5.0) 

Flight Test 420 (3.5) 

Fuel Tank 650 (5.4) 

High Temperature 420 (3.5) 

Maskants: 

 Type I - Chemical Milling 622 (5.2) 

 Type II - Chemical Milling 160 (1.3) 

 All Others 850 (7.1) 

Mold Release 762 (6.4) 

Part Marking 850 (7.1) 

Pretreatment Wash Primer 780 (6.5) 

Primer 350 (2.9) 

Radiation Effect 600 (5.0) 

Rain Erosion Resistant: 

 Fluoroelastomer 800 (6.7) 

 All Other 600 (5.0) 

Sealant 600 (5.0) 

Sealant Adhesion Promoter 750 (6.3) 

Self-priming Topcoat 420 (3.5) 

Solid Film Lubricant 880 (7.3) 

Space Vehicle: 

 Electrostatic Discharge 880 (7.3) 

 All Other 1000 (8.3) 

Temporary Protective 250 (2.1) 

Thermal Expansion Release 762 (6.4) 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 9 

Coating Type 

VOC Content: Grams/Liter (Lbs/Gal) 

less water and exempt compounds 

Thermocontrol 600 (5.0) 

Topcoat: 

 Acrylic Lacquer for F-111 780 (6.5) 

 All Other 420 (3.5) 

Wet Fastener Installation 620 (5.2) 

• Coating removers: no more than 300 g VOC/liter of material (2.5 lb/gal), or a 

composite vapor pressure greater than 9.5 mm Hg at 68 F. 

• High transfer-efficiency application equipment (e.g., HVLP, roll coater, dip coater, 

flow coater, electrostatic deposition). 

• Work practices for material storage and equipment cleaning. 

• Cleaning and surface prep solvents: no more than 200 g VOC/liter of material 

(1.67 lb/gal), or a composite vapor pressure no greater than 45 mmHg at 68 F. 

SMAQMD Exemptions

Rule 456 provides the following exemptions: 

• Non-compliant materials that total no more than 200 gallons per facility per year. 

• Non-refillable aerosol containers holding 1 liter (1.1 quarts) or less. 

• Other exemptions for lettering, touch up and repair, cleaning of space vehicles, 

and cleanup prior to adhesive bonding. 

Conclusion

Rule 456 establishes VOC limits that are at least as stringent as the CTG, with some 

exceptions. The following limits are included in the CTG, but not in Rule 456, and the 

CTG limits are more stringent than the otherwise applicable limit in Rule 456: 

Coating Type CTG Limit g/liter 

(lb/gallon) 

SMAQMD Applicable 

Limit 

g/liter (lb/gallon) 

Adhesive – Nonstructural 360 (3.0) 600 (5.0) 

Adhesive – Structural Autoclavable 60 (0.5) 600 (5.0) 

Sealant – Extrudable, Rollable, 

Brushable 

280 (2.3) 600 (5.0) 

There is only one source (Aerojet) within the District that is subject to Rule 456. Staff 

has verified that they do not use materials in the above three categories. Therefore, it is 

not necessary to adopt specific limits for these materials. 

In addition, records verify that Aerojet does not use noncompliant materials in amounts 

exceeding either 55 gallons per year for individual material or 200 gallons per year total. 

Therefore, the Rule 456 low usage exemption limit of 200 gallons per year is functionally 

as stringent as the CTG. 

Rule 456 satisfies RACT for this source category.
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 10 

Table A 

VOC Content Limits for Specialty Coatings from the Aerospace CTG 

Coating Type 

VOC Content: Grams/Liter (Lbs/Gal) 

less water and exempt compounds 

Ablative 600 (5.0) 

Adhesion Promoter 890 (7.4) 

Adhesive Bonding Primers 

Cured at 250 F or below 850 (7.1) 

Cured above 250 F 1,030 (8.6) 

Adhesive: 

 Commercial Interior Adhesive 760 (6.3) 

 Cyanoacrylate Adhesive 1,020 (8.5) 

 Fuel Tank Adhesive 620 (5.2) 

 Nonstructural Adhesive 360 (3.0 

 Rocket Motor Bonding Adhesive 890 (7.4) 

 Rubber-based Adhesive 850 (7.1) 

 Structural Autoclavable Adhesive 60 (0.5) 

 Structural Non-Autoclavable Adhesive 850 (7.1) 

Antichafe Coating 660 (5.5) 

Bearing Coating 620 (5.2) 

Caulking and Smoothing Compounds 850 (7.1) 

Chemical Agent-Resistant Coating 550 (4.6) 

Clear Coating 720 (6.0) 

Commercial Exterior Aerodynamic Structure 

Primer 

650 (5.4) 

Compatible Substrate Primer 780 (6.5) 

Corrosion Prevention Compound 710 (5.9) 

Cryogenic Flexible Primer 645 (5.4) 

Dry Lubricative Material 880 (7.3) 

Cryoprotective Coating 600 (5.0) 

Electrical or Radiation-Effect Coating 800 (6.7) 

Electrostatic Discharge and Electromagnetic 

Interference EMI) Coating 

800 (6.7) 

Elevated Temperature Skydrol Resistant 

Commercial Primer 

740 (6.2) 

Epoxy Polyamide Topcoat 660 (5.5) 

Fire Resistant (interior) Coating 800 (6.7) 

Flexible Primer 640 (5.3) 

Flight Test: 

 Missile or single use aircraft 420 (3.5) 

 All other 840 (7.0) 

Fuel Tank Coating 720 (6.0) 

High Temperature 850 (7.1) 

Insulation Covering 740 (6.2) 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 11 

Coating Type 

VOC Content: Grams/Liter (Lbs/Gal) 

less water and exempt compounds 

Intermediate Release Coating 750 (6.25) 

Lacquer 830 (6.9) 

Maskants 

 Bonding Maskant 1,230 (10.25) 

 Critical Use and Line Sealer Maskant 1,020 (8.5) 

 Seal Coat Maskant 1,230 (10.25) 

Metallized Epoxy Coating 740 (6.2) 

Mold Release 780 (6.5) 

Optical Anti-Reflective Coating 750 (6.25) 

Part Marking 850 (7.1) 

Pretreatment Coating 780 (6.5) 

Rain Erosion Resistant: 850 (7.1) 

Rocket Motor Nozzle Coating 660 (5.5) 

Scale Inhibitor 880 (7.3) 

Screen Print Ink 840 (7.0) 

Sealants: 

 Extrudable/Rollable/Brushable 280 (2.3) 

 Sprayable 600 (5.0) 

Silicone Insulation Material 850 (7.1) 

Solid Film Lubricant 880 (7.3) 

Specialized Function Coating 890 (7.4) 

Temporary Protective Coating 230 (1.9) 

Thermal Control Coating 800 (6.7) 

Wet Fastener Installation 675 (5.6) 

Wing Coating 850 (7.1) 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 12 

Category: Cutback Asphalt 

EPA RACT Guidance

Control of Volatile Organic Compounds from Use of Cutback Asphalt, EPA-450/2-77-

037, December 1977. 

Applicability

The RACT guidance applies to the application of cutback asphalt. Cutback asphalt is a 

blend of asphalt cement and solvent. The solvent ranges in volatility depending upon 

the need for rapid cure (uses highly volatile gasoline or naphtha), medium cure (uses 

less volatile kerosene), or slow cure (uses low volatile oils). The VOCs evaporate when 

the cutback asphalt cures, and can range from 20 to 50 percent by volume, averaging 35 

percent. 

 

RACT Requirements

The RACT guidance requires the substitution of an emulsifying agent and water for the 

solvent, resulting in a VOC emission reduction of nearly 100%. The RACT guidance 

states that the emulsifier is composed of non-volatile organic chemicals. This product 

combining asphalt cement, emulsifying agent, and water is known as emulsified asphalt. 

As a practical matter, although the CTG specifies the use of materials containing no 

VOCs, asphalt itself is composed of organic compounds that meet the regulatory 

definition of VOC, however low in volatility they may be. Therefore, rules to limit solvent 

content in asphalt paving materials rely on distillation test methods (percent evaporation 

versus temperature) to distinguish between asphalt and added solvents. 

 

Other Federal Requirements or Guidance

No other Federal requirements have been established for this category. However, 

EPA’s “Bluebook” (Issues Relating to VOC Regulation Cutpoints, Deficiencies, and 

Deviations, May 25, 1988, revised January 11, 1990) which contains guidance on 

developing VOC RACT rules, includes a section on cutback and emulsified asphalt. The 

guidance recommends that the maximum solvent content of emulsified asphalt, as 

determined by ASTM Method D-244, be limited to 7% for all applications, or limited 

between 3% - 12% depending on application. An exemption for cutback asphalt used as 

a prime penetrating coat is allowed. 

SMAQMD Requirements

District Rule 453, Cutback and Emulsified Asphalt Paving Materials, prohibits the 

manufacture and use of rapid and medium cure cutback asphalt, as well as slow cure 

cutback asphalt containing organic compounds that evaporate at 500°F or lower (as 

determined by ASTM Method D-402). 

In addition, Rule 453 limits the manufacture for sale or use of emulsified asphalt 

containing VOC that evaporates at 500°F or lower, in excess of 3% by volume (as 

determined by ASTM D-244). 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 13 

SMAQMD Exemptions

Rule 453 exempts the manufacture of cutback or emulsified asphalt when it will be 

immediately shipped for use outside of Sacramento County. (As noted in the CTG, the 

vast majority of emissions from cutback asphalt occur after application, not during 

manufacture). Also, medium cure cutback asphalt is allowed for use as a penetrating 

prime coat (i.e., application of asphalt to an absorptive surface to penetrate that surface, 

to bind the aggregate, and/or promote adhesion to new construction), although the rule 

states that this exemption will be evaluated annually to determine if an acceptable 

substitute material has been identified. 

Conclusion

The requirements of Rule 453 meet or exceed the requirements specified in the CTG, as 

clarified in the EPA “Bluebook.” 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 14 

Category: Gasoline Service Stations 

EPA RACT Guidance

1. Design Criteria for Stage I Vapor Control Systems – Gasoline Service Stations 

(CTG), November 1975.

2. Technical Guidance – Stage II Vapor Recovery Systems for Control of Vehicle 

Refueling Emissions at Gasoline Dispensing Facilities, EPA -450/3-91-022a&b, 

November 1991.

3. Gasoline Vapor Recovery Guidelines – Minimum SIP Requirements for EPA Region 

IX to Approve a Phase I or Phase II Gasoline Transfer Rule for Ozone 

Nonattainment Areas, EPA Region IX, April 24, 2000. 

Applicability

The CTG applies to the control of gasoline vapors during storage tank filling at gasoline 

service stations (Stage I sources). The CTG does not apply to vehicle fueling at 

gasoline service stations (Stage II sources). Emissions are the result of displaced 

organic vapor-laden air being forced out of the storage tank by liquid gasoline. 

 

RACT Requirements

The CTG prohibits the release of more than 10 percent by weight of displaced organic 

vapors (90 percent reduction). The CTG indicates that this control efficiency can be 

obtained using vapor recovery systems that incorporate a number of design features 

including submerged fill pipe, submerged gauge well drop tube, sufficiently sized vapor 

return lines and connections, vapor tight caps, vapor tight tank trucks, interlocks to 

prevent fuel delivery until the vapor hose is connected, pressure/vacuum valves, and 

other requirements. 

The EPA technical guidance on Stage II vapor recovery (document #2 above) specifies 

that gasoline dispensing facilities use Stage II vapor recovery systems that have at least 

95% control of displaced vapors. 

The EPA Region 9 guidelines (document #3 above) specify that RACT rules in California 

meet the following requirements: 

• Require that Phase I and Phase II systems use CARB-certified vapor recovery 

equipment. 

• List the Phase I and Phase II vapor recovery system defects contained in 

California Code of Regulations (CCR) 94006 or cite CCR 94006 as a reference 

for these defects. 

• Prohibit operation of a Phase I or Phase II vapor recovery equipment that has 

liquid leaks, vapor leaks, fails to pass tests, or contains CCR 94006 defects that 

substantially impair effectiveness of vapor recovery equipment. 

• Require that Phase I gasoline storage tanks be equipped with submerged liquid 

fill pipes. 

• Require that Phase II systems have a warning posted prohibiting topping-off, 

which may cause spillage of gasoline. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 15 

Other Federal Requirements

No other Federal requirements have been established for this category. 

SMAQMD Requirements

District Rule 448 (Gasoline Transfer into Stationary Storage Containers) prohibits the 

transfer of gasoline from a tank truck or trailer unless the container has a permanent 

submerged fill pipe and the displaced vapors are processed by a vapor recovery system 

with at least a 95 percent control efficiency. The vapor recovery system must be CARBcertified. Rule 448 also requires that gasoline delivery vessels must be leak-free and 

vapor-tight, and the purging of vapors from a delivery vessel to the atmosphere is 

prohibited. 

Rule 448 also requires vapor-tight caps on the storage container fill and vapor adapters, 

a dry break in the vapor adapter and space, and a functioning spring mechanism in the 

coaxial fill tube that causes the dry break to form a vapor-tight seal. Any vapor recovery 

system is required to have a pressure vacuum valve on all open vents with the following 

settings: a minimum pressure setting of 3.0 ± 0.5 inches of H2O and a minimum vacuum 

setting of 8.0 ± 2.0 inches of H2O. 

District Rule 449 (Transfer of Gasoline into Vehicle Fuel Tanks) requires that gasoline 

transfer into motor vehicle fuel tanks be performed only when equipped with Stage II 

vapor recovery systems with efficiencies of at least 95%, and requires that these 

systems be CARB-certified. Rule 449 also includes the requirements for defects, 

equipment leaks and failures, and posting of operating instruction that are specified in 

the EPA Region 9 guidance. 

SMAQMD Exemptions

Rule 448 exempts the transfer of gasoline into the following stationary containers: 

• Containers smaller than 250 gallons. 

• Containers used primarily for the fueling of implements of husbandry (i.e., a 

vehicle used exclusively in the conduct of agricultural operations) if equipped with 

a permanent submerged fill pipe. 

Rule 449 exempts fuel dispensing equipment for: 

• Emergency motor vehicles 

• Odd fill configurations 

• Implements of husbandry 

Conclusion

Rules 448 and 449 meet or exceed the requirements of the CTG and the EPA guidance 

documents, and satisfy RACT for this source category. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 16 

Category: Gasoline Tank Trucks and Bulk Plants (Liquid Loading) 

EPA RACT Guidance

CTG #1 - Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals, EPA450/2-77-026, October 1977. 

CTG #2 – Control of Volatile Organic Emissions from Bulk Gasoline Plants, EPA-450/2-77-

035, December 1977. 

CTG #3 – Control of Volatile Organic Compound Leaks from Gasoline Tank Trucks and 

Vapor Collection Systems, EPA-450/2-78-051, December 1978. 

Applicability

The RACT Guidance in CTG #1 applies to the loading of gasoline tank trucks at tank 

truck terminals with a daily gasoline throughput of greater than 76,000 liters. 

The RACT Guidance in CTG #2 applies to loading of gasoline tank trucks at bulk 

gasoline plants with a daily gasoline throughput of less than 76,000 liters. 

The RACT Guidance in CTG #3 applies to gasoline tank trucks that are equipped for 

vapor collection, and to vapor collection systems at bulk terminals, bulk plants, and 

service stations. 

RACT Requirements

In CTG #1, presumptive RACT for loading of tank trucks at terminals is identified as 

vapor collection systems with emissions of no more than 80 mg hydrocarbon per liter of 

gasoline loaded. CTG #1 indicates that this 80 mg limit can be met with vapor collection 

and recovery or oxidation control systems. 

In CTG #2, two RACT alternatives are presented for loading of account (tank) trucks at 

bulk gasoline plants: 

• submerged filling of account trucks, or 

• submerged filling and vapor balance systems to control VOC displaced by filling 

account trucks. 

The CTG indicates that submerged filling of account trucks is equivalent to 60% control 

relative to uncontrolled splash filling, and that vapor balance systems provide 90% VOC 

control. The CTG indicates that consideration should be given to the compatibility of 

bulk plants with Stage I service station regulations, as well as potential economic 

impacts and retrofit difficulty. 

CTG #3 establishes presumptive RACT for gasoline tank trucks and vapor collection 

systems. Loading is limited to only vapor-tight tank trucks, established using a pressurevacuum test (included in Appendix A of CTG #2). The vapor collection and vapor 

processing equipment should be designed and operated to prevent tank truck gauge 

pressure from exceeding 4500 pascals (18 inches of H2O) and the tank truck vacuum 

from exceeding 1500 pascals (6 inches of H2O). 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 17 

Vapor collection systems must be operated below the lower explosive limit (i.e., LEL, 

measured as propane) measured at 2.5 centimeters around the perimeter of a potential 

leak source (e.g., piping, seals, hoses, connections, pressure-vacuum vents, etc.) using 

the methodology included in Appendix B of CTG #3. In general, there should be no 

avoidable visible liquid leaks. However, the CTG acknowledges that there will invariably 

be a few drops of liquid resulting from the disconnection of dry breaks in liquid lines and 

the raising of well-maintained top loading vapor head; CTG #3 indicates that these drops 

are allowable. 

Other Federal Requirements

The bulk gasoline terminal NSPS (40 CFR 60 subpart XX) applies to loading of gasoline 

tank trucks at bulk terminals (throughput > 75,700 liters/day). It contains the same 

emission limit as CTG #1 (80 mg TOC/liter of gasoline loaded) for facilities with existing 

vapor processing systems (60.502(c)). The NSPS has a more stringent limit than CTG 

#1 (35 mg TOC/liter of gasoline loaded) for loading of tank trucks at new facilities that do 

not already have an existing vapor processing system. The NSPS limits loading to only 

vapor-tight tank trucks. The vapor collection and loading equipment must be designed 

and operated to prevent gauge pressures in the delivery tank from exceeding 4500 

pascals (18 inches of H2O). The NSPS also requires monthly visual inspection of the 

vapor processing system and gasoline loading racks for leaks, and repair of any leaks 

detected. 

The NESHAP for gasoline distribution facilities (40 CFR 63 subpart R) applies to loading 

of tank trucks at bulk terminals that are major sources of HAP. It limits emissions from 

vapor collection and processing systems to 10 mg TOC/liter of gasoline loaded. It limits 

loading to only vapor-tight tank trucks. It also requires monthly leak inspection and repair 

for equipment (pumps, valves, pressure relief devices, connectors, etc.) that transfers 

gasoline or is part of the vapor processing system. 

SMAQMD Requirements

District Rule 447 (Organic Liquid Loading) prohibits the transfer of organic liquids into 

any tank truck, trailer, or railroad tank car unless the emissions do not exceed certain 

limits (i.e., 0.08 lbs VOC per 1,000 gallons of transferred organic liquids for bulk 

terminals and 0.6 lbs VOC per 1,000 gallons of transferred organic liquids for bulk 

plants). 

Rule 447 requires that all equipment associated with the loading facility must be 

maintained to be leak-free and vapor-tight, determined using visual and instrument 

monitoring methods as defined in the rule. 

 

In addition, Rule 447 requires that the diaphragms used in vapor storage tanks must be 

maintained such that the VOC concentration in the airspace above the diaphragm does 

not exceed 3,000 ppm (expressed as methane). 

Rule 448 prohibits operation of a gasoline delivery vessel that is not leak-free and vaportight. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 18 

SMAQMD Exemptions

Rule 447 exempts the loading of organic liquids with low vapor pressures (i.e., less than 

0.5 psia) under actual loading conditions. 

Conclusion

District Rule 447 control requirements are more stringent than the CTG for gasoline 

terminals (CTG #1). The presumptive RACT from CTG #1, when converted to the same 

units as Rule 447, is 0.668 lbs hydrocarbon per 1,000 gallons loaded. The Rule 447 

limits (i.e., 0.08 lbs VOC per 1,000 gallons of transferred organic liquids for bulk 

terminals and 0.6 lbs VOC per 1,000 gallons of transferred organic liquids for bulk 

plants) are more stringent. (This comparison assumes that the definition of hydrocarbon 

under the CTG #1 RACT is equivalent to VOC.) Rule 447 is also consistent with the 

CTG for bulk gasoline plants (CTG #2), which requires, as a minimum, submerged fill 

(and potentially requires a vapor balancing system). From a practical standpoint, the 

emission limits in Rule 447 are more stringent than CTG #1. 

The Rule 447 requirement that all equipment associated with the loading facility must be 

maintained to be leak-free and vapor-tight is consistent with the CTG #3 provision that 

limits visible equipment leaks. 

The Rule 448 requirement that requires gasoline delivery vessels to be leak-free and 

vapor-tight is consistent with the requirements in the CTG and the NSPS to load only 

vapor-tight tank trucks. 

Rules 447 and 448 satisfy the RACT requirement for liquid loading using gasoline tank 

trucks. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 19 

Category: Graphic Arts Operations

EPA RACT Guidance

OAQPS Guideline Series – Control of Volatile Organic Emissions from Existing 

Stationary Sources – Volume VIII: Graphic Arts – Rotogravure and Flexography, U.S. 

EPA Publication No. EPA-450/2-78-033, December 1978. 

Applicability

The CTG applies to both the flexographic and rotogravure processes as applied to both 

publication and packaging printing. The guideline document does not apply to offset 

lithography or letterpress printing. 

RACT Requirements

The guidance document specifies two alternatives for presumptive RACT: Add-on 

control devices, or water-borne and high solids inks. For add-on control (carbon 

adsorption or incineration), the CTG requires a capture and control system as specified 

in the following table: 

Graphic arts 

operation 

VOC capture 

efficiency (%) 

Control device VOC 

reduction efficiency 

(%) 

Overall VOC control 

and capture 

efficiency (%) 

Publication 

rotogravure 

75-85 90 75 

Packaging 

rotogravure 

70-80 90 65 

Flexography printing 65-70 90 60 

For water-borne and high solids inks, comparable emission limits to add-on control 

options listed above can be achieved when the solvent portion of the ink consists of 75 

percent (by volume) water and 25 percent (by volume) organic solvent. 

Other Federal Requirements

Subpart QQ of 40 CFR part 60 (Standards of Performance for the Graphics Arts 

Industry: Publication Rotogravure Printing) limits VOC emissions to less than 16 percent 

of the total mass of VOC solvent and water used at the facility. 

Subpart FFF of 40 CFR part 60 (Standards of Performance for Flexible Vinyl and 

Urethane Coating and Printing) specifies either VOC limitations or VOC percent 

reductions for rotogravure printing lines used to print or coat flexible vinyl or urethane 

products. The NSPS requires either of the following: 1) Use inks with VOC content of 

less than 1.0 kg VOC per kg of ink solids; or 2) reduce VOC emissions with a combined 

capture and control efficiency of 85 percent. 

Subpart KK of 40 CFR part 63 (National Emissions Standards for Hazardous Air 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 20 

Pollutant Emissions from the Printing and Publishing Industry) limits hazardous air 

pollutant (HAP) emissions as follows: 

Graphic Arts Operation type: HAP Emissions standard: 

Publication rotogravure printing Limits organic HAP emissions to 8% of 

total volatile matter used; or combined 

capture and control efficiency of at least 

92% of organic HAP used. 

Packaging rotogravure and flexographic 

printing 

Limit emissions to: 

- No more than 5% of the organic 

HAP applied; or 

- No more than 4% of the mass of 

materials applied; or 

- No more than 20% of the mass of 

solids applied; or 

- No more than a calculated 

equivalent allowable mass. 

SMAQMD Requirements

District Rule 450 (Graphics Arts Operations) limits the VOC content for 17 categories of 

graphics arts materials (e.g., inks, adhesives, coatings), and 8 categories of cleaning 

compounds (e.g., general cleaning, screen printing, ultraviolet inks). Some cleaning 

compounds have VOC partial pressure limits also. For lithographic and letter press 

printing, Rule 450 limits the volume of cleaning solution to be used for cleaning 

operations other than blanket and roller washes. Additionally, VOC materials and VOCcontaining cloth, sponges, and other materials used for solvent cleaning must be stored 

in closed containers when not in use. 

As an alternative to the VOC content limits, emissions control equipment may be used 

provided that the control device efficiency is 95 % or more on a mass basis, and the 

collection efficiency is at least 70 %. 

Rule 450 also prohibits the sale of noncompliant materials for use in graphics arts 

operations except to facilities using emission control devices. Sellers are required to 

provide product information, including the maximum VOC content, at the time of sale. 

SMAQMD Exemptions

Rule 450 does not apply to gravure printing, business and personal printers, and graphic 

arts sources that have actual emissions of 60 pounds VOC or less per quarter. The 

VOC limitations do not apply to aerosol adhesives used by 1) screen printing operations, 

provided the adhesive complies with the VOC limits specified under Section 300 of 

District Rule 460 – ADHESIVES AND SEALANTS; or 2) graphic arts operations that 

have facility VOC emissions less than 660 pounds per month. 

Conclusion

Based on a comparison of the capture and control efficiencies, Rule 450 is at least as 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 21 

stringent as the CTG for flexography printing, and meets the requirements of RACT. 

There are no sources in the District using gravure printing, and a negative declaration 

will be submitted for that portion of this source category.
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 22 

Category: Metal Can Coating

EPA RACT Guidance

Control of Volatile Organic Emissions from Existing Stationary Sources – Volume II: 

Surface Coating of Cans, Coils, Paper, Fabrics, Automobile, and Light-Duty Trucks U.S. 

EPA Publication No. EPA-450/2-77-008, May 1977. 

Applicability

The CTG applies to two and three-piece can manufacturing processes, can fabrication 

processes, and end coating operations. 

RACT Requirements

The CTG identifies five control alternatives, as shown in the following table: 

Control Technology VOC Percent Reduction 

Catalytic and non-catalytic incineration 90 

Carbon adsorption 90 

Water-borne and high-solids coatings 60-90 

Ultraviolet curing Up to 100 

Powder coating 100 

For various technical reasons, not all RACT alternatives apply to each can 

manufacturing process. Therefore, the CTG specifies the controls that are feasible for 

each process operation, as shown below: 

Can Coating Operation: Available controls: 

2-piece exterior coating Incineration, water-borne and high solid 

coatings, UV curing 

2-piece interior spray coating Incineration, water-borne and high solid 

coatings, powder coating, carbon 

adsorption 

3-piece sheet coating, interior Incineration, water-borne and high solid 

coatings 

3-piece sheet coating, exterior Incineration, water-borne and high solid 

coatings, UV curing 

Can fabricating, side seam spray coating Water-borne and high solid coatings, 

powder coating 

Can fabricating, interior spray coating Incineration, water-borne and high solid 

coatings, powder coating, carbon 

adsorption 

End coating, sealing compound Water-borne and high solid coatings 

End coating, sheet coating Carbon adsorption, incineration, waterborne and high solid coatings 

The CTG specifies presumptive RACT as the following numeric VOC limits, based on 

the water-borne and high solids coatings control alternative: 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 23 

Can Coating Operation: VOC limit (g/L of coating, minus water) 

Sheet basecoat, overvarnish, 2-piece 

exterior 

340 

2 and 3-piece interior spray, 2-piece end 510 

3-piece side seam spray 660 

End sealing 440 

Prime topcoat or single coat 310 

Other Federal Requirements

Subpart WW of 40 CFR part 60 (Standards of Performance for the Beverage Can 

Surface Coating Industry) limits VOC emissions as shown in the following table. The 

facility may use low VOC materials and/or capture and control systems to meet the 

limits. Limits for the specific operations are as follows: 

Operation type: VOC limit (g VOC/L coating solids) 

2-piece exterior (except clear base coat) 290 

2-piece exterior clear base coat and 

overvarnish coating 

460 

2-piece interior spray coating 890 

Subpart KKKK of 40 CFR part 63 (National Emissions Standards for Hazardous Air 

Pollutants: Surface Coating of Metal Cans) specifies hazardous air pollutant (HAP) 

emissions limitations for new and existing can coating operations. The following table 

summarizes the standards for existing sources (there are multiple subcategories within 

most operations, each with a unique limit. For brevity, a range is presented): 

Operation type: HAP Emissions limit (kg HAP/L solids): 

1 and 2-piece body coating 0.06-0.12 

Sheetcoating 0.03 

3-piece can assembly 0.29-1.94 

End coating 0.00-2.06 

As an alternative compliance option, facilities may meet a HAP capture and control 

efficiency of 95% or overall HAP emission concentration of 20 ppmv at the control device 

outlet. 

Note: There are no sources in the District that are subject to either the NSPS or the 

NESHAP. 

SMAQMD Requirements

District Rule 452 (Can Coating) limits the VOC content for 11 categories of can coating 

materials as shown in the table below. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 24 

Operation type: 

VOC limit (g/L coating as applied, 

excluding water and exempt compounds) 

Interior base coating 225 

Interior base coating overvarnish 225 

Exterior base coating 225 

Exterior base coating overvarnish 225 

2-piece can exterior base coating 250 

2-piece can exterior base overvarnish 250 

2-piece can interior spray 440 

3-piece interior spray 510 

2-piece can exterior end coating 250 

3-piece can side seam spray 660 

End sealing compound 440 

Emissions control equipment may be used instead of VOC content limits, provided that 

the control device efficiency is 95% or more on a mass basis, and the collection 

efficiency is at least 90%. Rule 452 also specifies a 200 g/L limit for cleaning materials 

used for container assemble equipment. Additionally, all VOC-materials and VOCcontaining cloth, sponges, and other materials used for solvent cleaning must be stored 

in closed containers when not in use. 

SMAQMD Exemptions

None. 

Conclusion

Rule 452 is as stringent, or more stringent, than the CTG presumptive RACT limits for 

coatings. The CTG specifies emission control as an alternative to the coating limits. The 

CTG does not specify capture efficiency, but concludes that at least 90% control 

efficiency is achievable for incineration and carbon adsorption. Rule 452 specifies a 

capture efficiency of 90 percent and control efficiency of 95%, which exceeds the CTG 

specification. 

Rule 452 satisfies the RACT requirement for this category. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 25 

Category: Surface Coating of Metal Furniture 

EPA RACT Guidance

Guideline Series: Control of Volatile Organic Compound Emissions from Existing 

Stationary Sources – Volume III: Surface Coating of Metal Furniture. U.S. EPA 

Publication No. EPA-450/2-77-032, December 1977. 

Applicability 

The CTG applies to any facility that performs surface coating (finishing) of metal 

furniture, including any furniture made of metal or any metal parts that will be assembled 

with other non-metal parts to form a furniture piece. 

Federal RACT Requirements

The CTG does not include a model rule, but establishes presumptive RACT for metal 

furniture surface coating operations as a VOC limit of 360 g VOC emitted/liter coating, 

minus water (3.0 lb VOC emitted/gallon coating, minus water). The CTG does not 

distinguish between baked and air dried coatings. 

Other Federal Requirements

40 CFR part 60, subpart EE, specifies Standards of Performance for Surface Coating of 

Metal Furniture. The NSPS applies to any metal furniture surface coating operation 

using 3,842 liters (1,015 gallons) or more of organic coating per year. The emission limit 

in subpart EE is 0.90 kg of VOC per liter of coating solids applied to the part (i.e., the 

denominator does not include solids lost as over spray). 

40 CFR Part 63, subpart RRRR specifies NESHAP for metal furniture surface coating 

operations at major HAP sources. Existing major sources must emit no more than 0.10 

kg organic HAP/liter coatings solids used (0.83 lb/gal). The denominator of the NESHAP 

emission limits does not include solids lost as over spray. New and reconstructed major 

sources must emit no organic HAP, unless the permitting authority approves use of an 

alternative limit of 0.094 kg organic HAP/liter coatings solids used (0.78 lb/gal) for 

certain specialty applications. The new source standards were based on facilities that 

use powder coatings or liquid coatings that contained no organic HAP. Since powder 

coatings also contain little or no VOC, sources that are complying with the new source 

limits in subpart RRRR may also have very low VOC emissions. 

SMAQMD Requirements

District Rule 451, Surface Coating of Miscellaneous Metal Parts and Products, sets 

emission limits for metal furniture coatings under the category “all other coatings,” as 

shown in the table below: 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 26 

VOC Limits 

g/liter, 

less water and exempt compounds 

(lbs/gallon) 

Coating Air Dried Baked 

Aluminum coating for window frames and 

door frames 

420 (3.5) 420 (3.5) 

Camouflage 420 (3.5) 360 (3.0) 

Electrical Insulating 340 (2.8) 275 (2.3) 

Extreme High Gloss 420 (3.5) 360 (3.0) 

Extreme Performance 420 (3.5) 420 (3.5) 

Heat Resistant 420 (3.5) 360 (3.0) 

Metallic Iridescent 420 (3.5) 420 (3.5) 

Non-skid 420 (3.5) 360 (3.0) 

Prefabricated Architectural Component 420 (3.5) 275 (2.3) 

Pretreatment wash primer 420 (3.5) 420 (3.5) 

Silicone release coating 420 (3.5) 420 (3.5) 

Solar Absorbent 420 (3.5) 360 (3.0) 

All other coatings 340 (2.8) 275 (2.3) 

• Coating removers (strippers): no more than 200 g VOC/liter of material (1.7 

lb/gal). 

• High efficiency applications equipment (e.g., HVLP, roll oater, dip coater, flow 

coater, electrodeposition). 

• Work practices for material storage and equipment cleaning. 

• Product cleaning or surface prep solvents: no more than 72 g VOC/liter of 

material (0.6 lb/gal). 

SMAQMD Exemptions

Rule 451 exempts facilities that use 55 gallons of coating per year, consistent with the 

EPA Region IX “Little Bluebook” (Guidance Document for Correcting Common VOC & 

Other Rule Deficiencies, April 1, 1991, revised August 21, 2001). 

Conclusion

District Rule 451 regulates metal furniture coatings under the VOC limit for “all other 

coatings,” which is more stringent than the CTG limit for metal furniture coating. Rule 

451 satisfies the RACT requirement for this category. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 27 

Category: Surface Coating of Miscellaneous Metal Parts and Products 

EPA RACT Guidance

Guideline Series: Control of Volatile Organic Compound Emissions from Existing 

Stationary Sources – Volume VI: Surface Coating of Miscellaneous Metal Parts and 

Products. U.S. EPA Publication No. EPA-450/2-78-015, June 1978. 

Applicability

The CTG applies to any facility that performs surface coating (finishing) on 

miscellaneous metal parts. The CTG specifically excludes surface coating of metal 

cans, coils, wire, automobiles and light duty trucks, metal furniture, and large appliances. 

 The CTG includes emission limits which represent RACT, but does not include a model 

rule. 

 

Federal RACT Requirements

The CTG establishes presumptive RACT for metal part surface coating operations as 

the following emission limits: 

Surface Coating Operation VOC limit 

g/liter, minus water 

(lb/gallon) 

Air or forced air-dried items: 

Parts too large or too heavy for practical size ovens and/or 

sensitive heat requirements. 

Parts to which heat-sensitive materials are attached. 

Equipment assembled prior to top coating for specific 

performance or quality standards. 

420 (3.5) 

Clear Coat 520 (4.3) 

No or infrequent color Powder coatings 50 (0.4) 

changes, or small numbers of 

colors applied Others 360 (3.0) 

Outdoor or harsh exposure or extreme performance 

characteristics 

420 (3.5) 

Frequent color change or large number of colors applied, or 

first coat applied on untreated ferrous substrate 

360 (3.0) 

The CTG estimated the cost-effectiveness of complying with the limits using waterborne 

coatings, higher solids coatings, powder coating, and electrodeposition coating. The 

costs, in 1977 dollars, ranged from a savings $191/ton ($630/ton in today’s dollars) of 

VOC reduced to a cost of $6,600/ton ($21,800/ton in today’s dollars) of VOC reduced. 

The median value for 47 scenarios examined was a cost of $625/ton ($2,060/ton in 

today’s dollars). Sources also can use add-on controls to meet the limits. The CTG 

made no policy statements regarding acceptable cost effectiveness levels for RACT. 

Other Federal Requirements
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 28 

Subpart MMMM of 40 CFR Part 63 specifies NESHAP for miscellaneous metal parts and 

products manufacturing surface coating operations at major HAP sources. These 

standards are in terms of lb organic HAP per gallon solids used. Since many VOC are 

not HAP, these limits for HAP establish no practical limits on VOC content or VOC 

emissions from these operations. 

SMAQMD Requirements

District Rule 451, Surface Coating of Miscellaneous Metal Parts and Products 

implements sets the following emission limits and work practices: 

 

VOC Limit 

g/liter, 

less water and exempt compounds 

(lbs/gallon) 

Coating Air Dried Baked 

Aluminum coating for window frames and 

door frames 

420 (3.5) 420 (3.5) 

Camouflage 420 (3.5) 360 (3.0) 

Electrical Insulating 340 (2.8) 275 (2.3) 

Extreme High Gloss 420 (3.5) 360 (3.0) 

Extreme Performance 420 (3.5) 420 (3.5) 

Heat Resistant 420 (3.5) 360 (3.0) 

Metallic Iridescent 420 (3.5) 420 (3.5) 

Non-skid 420 (3.5) 360 (3.0) 

Prefabricated Architectural Component 420 (3.5) 275 (2.3) 

Pretreatment wash primer 420 (3.5) 420 (3.5) 

Silicone release coating 420 (3.5) 420 (3.5) 

Solar Absorbent 420 (3.5) 360 (3.0) 

All other coatings 340 (2.8) 275 (2.3) 

• Coating removers (strippers): no more than 200 g VOC/liter of material (1.7 

lb/gal). 

• High efficiency applications equipment (e.g., HVLP, roll coater, dip coater, flow 

coater, electrostatic spray coating). 

• Work practices for material storage and equipment cleaning. 

• Product cleaning or surface prep solvents: no more than 72 g VOC/liter of 

material (0.6 lb/gal). 

SMAQMD Exemptions

Rule 451 contains the following exemptions: 

• Prefabricated architectural components not coated in a shop. 

• Motor vehicles. 

• Aircraft or aerospace vehicles. 

• Cans, coils, and magnet wire. 

• Adhesives and sealants. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 29 

• Magnetic data storage disks. 

• Safety indicating coatings. 

• Stencil coatings. 

• Conformal coatings. 

• Hand lettering. 

• Any coating used at less than 55 gallons per year per source, consistent with the 

EPA Region IX “Little Bluebook” (Guidance Document for Correcting Common 

VOC & Other Rule Deficiencies, April 1, 1991, revised August 21, 2001). 

• Aluminum coatings for window frames and door frames used at less than 200 

gallons per year per source. 

• Pre-treatment wash primers at less than 200 gallons per year per source. 

Conclusion

The emission limits in Rule 451 are at least as stringent as those in the CTG. The 

District performed a “5% analysis” for the low usage exemptions when Rule 451 was 

submitted for SIP approval, which demonstrated that excess emissions allowed by the 

exemptions are less than 5% of the total emissions allowed by the CTG. Rule 451 

satisfies the RACT requirement for this source category. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 30 

Category: Storage of Petroleum Products (> 40,000 gallons) 

EPA RACT Guidance

Control of Volatile Organic Emissions from Storage of Petroleum Liquids in Fixed-Roof 

Tanks. EPA-450/2-77-036, December 1977. 

Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating 

Roof Tanks. EPA-450/2-78-047, December 1978. 

Alternative Control Techniques Document: Volatile Organic Liquid Storage in Floating 

and Fixed Roof Tanks. EPA-453/R-94-001, January 1994. 

Applicability

Both CTGs apply to tanks with capacities greater than 150,000 liters containing 

petroleum liquids with a true vapor pressure (VP) greater than 10.5 kPa. 

The ACT provided costs and emission reductions for various tank sizes and vapor 

pressures. No model rule or applicability requirements are provided. 

 

RACT Requirements

The CTGs establish presumptive RACT for External Floating Roof Tanks and Fixed Roof 

tanks, as shown in the following table: 

CTG Applicability Tank type Requirement Exemptions 

Vapor 

pressure 

(VP) >27.6 

kPa 

Welded external 

floating roof tank 

equipped with 

primary metallic 

shoe or liquid 

mounted seals 

VP >10.5 

kPa 

Welded external 

floating roof tank 

equipped with 

primary vapor 

mounted seals 

External 

floating roof 

(EFR) tanks 

VP >10.5 

kPa 

Riveted external 

floating roof tank 

equipped with 

primary metallic 

shoe or liquid 

mounted seals 

Retrofit with a rimmounted 

secondary seal 

Gap area of gaps 

exceeding 0.32 

cm in width 

between 

secondary seal 

and the tank wall 

be < 6.5 cm2 per 

0.3 m of tank 

diameter. 

Openings are to 

be equipped with 

a cover, seal, or 

lid. 

External 

floating roof 

tanks with 

capacities < 

1,600,000 

liters that store 

crude oil and 

condensate 

Tanks 

equipped with 

metallic-type 

shoe seal in a 

welded tank 

which has a 

shoe mounted 

secondary 

seal. 

Fixed roof 

tanks 

VP >10.5 

kPa 

 Retro-fitted with 

internal floating 

roofs equipped 

with closure seals 

Fixed roof 

tanks with 

capacities < 

1,600,000 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 31 

CTG Applicability Tank type Requirement Exemptions 

Openings are to 

be equipped with 

a cover, seal, or 

lid. 

liters used to 

store crude oil 

and 

condensate 

Other Federal Requirements

Three new source performance standards (NSPS) were promulgated for storage 

vessels: 40 CFR Part 60, subpart K, Ka, and Kb. The most recent NSPS is subpart Kb. 

The following table lists the requirements for subpart Kb: 

Applicability Requirement 

Volume ≥ 151 m3 (about 

40,000 gallons) and 

VP 5.2 kPa to 76.6 kPa 

Three options are allowed: 

1. Internal floating roof (IFR) or fixed roof retrofitted 

with an IFR. Equip with a foam or liquid filled seal 

mounted in contact with the liquid or a mechanical 

shoe seal or 2 seals mounted one above the other to 

form a continuous enclosure. Openings are to be 

equipped with a cover, seal, or lid. 

2. External Floating Roof Equipped with a closure 

device that has specified types of seals between the 

wall of the tank and the roof edge. Openings are to be 

equipped with a cover, seal, or lid. 

3. A closed vent system routed to a control device that 

achieves at least 95% reduction. 

The NSPS specifies extensive fitting requirements for 

various types of openings and cover penetrations. 

Volume ≥ 75 m3 and 

VP ≥76.6 kPa 

A closed vent system routed to a control device that 

achieves at least 95% reduction 

The Hazardous Organic NESHAP, 40 CFR 63, subpart G, applies to storage vessels in 

organic HAP service. For vessels larger than 151 m3

, the NESHAP applicability levels 

and control requirements for existing storage vessels are the same as in NSPS subpart 

Kb. For new storage vessels, the control requirements are the same as the NSPS, but 

apply to storage of liquids with a vapor pressure of 0.7 kPa or more. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 32 

SMAQMD Requirements

District Rule 446, Storage of Petroleum Products applies to storage tanks storing liquids 

with vapor pressures greater than 10.3 kPa. 

• Storage vessels in excess of 150,000 liters (about 40,000 gallons) must be under 

pressure or equipped with a floating roof, internal floating roof or vapor recovery 

system that achieves at least 95 % reduction in emissions. 

• A vapor recovery system that achieves at least 95 % reduction in emissions must 

be used if the liquid stored has a VP of 75.9 kPa or more. 

• Floating roofs must have 2 seals. 

• All openings in the roof shall be equipped with a cover, seal or lid which shall 

remain closed at all times. 

• The gap between the primary and secondary seal shall not exceed 0.15 cm. 

• Rule 446 also has seal requirements for metallic shoe seals, weld tanks with 

metallic shoe seals, and resilient toriod seals. 

SMAQMD Exemptions

Rule 446 does not apply to tanks having a capacity of less than or equal to 150,000 

liters. The rule also exempts tanks when undergoing periodic maintenance or the 

process of replacing seals. 

Conclusion

Rule 446 has slightly more stringent control requirements than the CTG. Fewer 

exemptions are allowed and the gap allowed between primary and secondary seals is 

smaller. Rule 446 is as stringent as the NSPS Subpart Kb and the NESHAP for storage 

tanks to which the CTG applies. Sources which are subject to the NSPS and/or 

NESHAP comply with those requirements, and the District has been delegated the 

authority to enforce these federal standards. Rule 446 satisfies the RACT requirement 

for this source category. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 33 

Category: Pharmaceuticals Manufacturing 

EPA RACT Guidance

Control of Volatile Organic Emissions from Manufacture of Synthesized Pharmaceutical 

Products, EPA-450/2-78-029, December 1978. 

Applicability

The guidance applies to unit operations at facilities manufacturing synthesized 

pharmaceuticals. These unit operations include reactors, distillation operations, 

crystallizers, centrifuges, vacuum dryers, and associated storage tanks and transfer 

operations. 

RACT Requirements

The CTG establishes presumptive RACT for the following sources at facilities that 

manufacture synthesized pharmaceuticals. 

Emission Point Applicability Criteria VOC Limit 

Process vents at reactors, 

distillation operations, 

crystallizers, centrifuges, and 

vacuum dryers 

Emitting more than 15 lb/day 

of VOC 

Surface condensers or 

equivalent controls 

Emitting 330 lbs/day VOC or 

more 

90 percent VOC 

reduction 

Air dryers and production 

equipment exhaust systems 

Emitting less than 330 

lbs/day VOC 

Emission limit of 33 

lbs/day VOC 

Storing VOC with a vapor 

pressure > 4.1 psi and 

volume > 2000 gallons 

90 percent vapor 

balance 

Storage tanks 

Storing VOC with vapor 

pressure > 1.5 psi 

Pressure conservation 

vents set at 0.2 kPa 

Centrifuges, rotary vacuum 

filters, and other filters having 

an exposed liquid surface 

Applies to liquids with a total 

VOC vapor pressure of 0.5 

psi 

Enclose equipment 

In process tanks All Covers on tanks 

Equipment leaks Liquid leaks (visible) Repair as soon as 

practicable 

Other Federal Requirements

The NESHAP for pharmaceuticals production (40 CFR Part 63, subpart GGG) regulates 

organic HAP emissions from process vents, storage vessels, equipment leaks, and 

wastewater treatment systems. The rule contains provisions for emissions averaging 

and pollution prevention alternatives. The rule has applicability cutoffs for each emission 

point, but those criteria would not be relevant for VOC emissions. The control 

requirements are presented below. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 34 

Emission Point HAP Limits 

Storage tanks Store applicable liquids in an internal floating roof, external 

floating roof, or fixed roof tank that sends emissions to a 

control device that reduces emissions by 90 or 95 percent 

(depending on tank size and vapor pressure of HAP stored), or 

comply with a vapor balancing alternative 

Process vents Reduce HAP by 98 percent by weight for each large process 

vent, and by 93 percent by weight for all remaining vents 

combined. As an alternative, reduce outlet concentrations to 

20 ppmv, or use a flare. 

Equipment Leaks Liquid leak visual inspection and repair requirements 

SMAQMD Requirements

District Rule 455, Pharmaceuticals Manufacturing, implements the RACT emission limits 

as recommended by the EPA’s CTG. The Rule 455 emission limits are the same as the 

limits in the CTG. Rule 455 also applies to cosmetics manufacturing plants. 

SMAQMD Exemptions

Rule 455 exempts facilities that emit, at the design production rate, 15 lb/day or less of 

VOC. This exemption level is consistent with the CTG and EPA’s “Bluebook” (Issues 

Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations, May 25, 1988, 

revised January 11, 1990). 

Conclusion

The VOC emission control requirements in District Rule 455 are the same as those 

specified in the CTG. 

The NESHAP applies to pharmaceutical manufacturing that is located at major sources 

of HAPs. There are no facilities within the District to which the NESHAP applies. 

Although the NESHAP requires process vents to reduce organic HAP emissions by 93 – 

98%, this requirement does not apply to total VOC emissions. Rule 455 is as stringent 

as the NESHAP for total VOC emissions from emission points to which the CTG applies. 

Rule 455 satisfies the RACT requirement for this source category. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 35 

Category: Solvent Cleaning (Degreasers)

EPA RACT Guidance

Control Techniques Guidelines (CTG) Document - Control of Volatile Organic Emissions 

from Solvent Metal Cleaning, U.S. EPA Publication No. EPA-450/2-77-022, November 

1977. 

Alternative Control Technology (ACT) Document - Halogenated Solvent Cleaners, U.S. 

EPA Publication No. EPA-450/3-89-030, August 1989. 

Applicability

The CTG document applies to cold cleaners, open top vapor degreasers, and 

conveyorized degreasers. 

The ACT document for halogenated solvent cleaners applies to cold, open-top, and inline (i.e., conveyorized) degreasers using 1,1,1-trichloroethane, trichloroethylene, 

perchloroethylene, methylene chloride, and trichlorotrifluoroethane. 

RACT Requirements

The CTG identifies machine design specifications, control devices, and work practices to 

reduce solvent losses from diffusion and convection, carryout, leaks, downtime, solvent 

transfer, water contamination, and waste disposal for each type of degreaser. The CTG 

does not specify a single control strategy, but defines a number of measures at two 

levels of cost that can be combined to form an effective control strategy depending on 

the level of control needed. The types of controls are summarized generally below: 

Cold cleaners: Covers on machine openings, parts draining requirements to avoid carryout, labeling of work practices, 0.7 freeboard ratio (alternatives: water cover or control 

device), and work practices for waste disposal. 

Vapor degreasers: More stringent cover and carry-out controls, work practice 

requirements for vapor cleaning, labeling, automatic shut-off switches in case of 

operating deviations, leak checks, 0.75 freeboard ratio (alternatives: refrigerated chiller, 

carbon adsorber, enclosed design, or other control device), and work practices for 

separator water and waste disposal. 

Conveyorized degreasers: Refrigerated chiller or carbon adsorber, carry-out controls, 

automatic shutoff switches, minimized machine openings, downtime covers, and work 

practices for separator water and waste disposal. 

The controls listed in the ACT document are the same as the CTG and include a few 

additional design or work practice standards that are more explicit than the CTG, but not 

substantially different or more stringent. 

Other Federal Requirements

The National Emission Standards for Halogenated Solvent Cleaning (40 CFR Part 63, 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 36 

Subpart T) applies to batch vapor, in-line vapor, in-line cold, and batch cold solvent 

cleaning machines that use any solvent containing at least five percent, by weight, of 

carbon tetrachloride, chloroform, perchloroethylene, 1,1,1-trichloroethane, 

trichloroethylene, or methylene chloride (either alone or in combination). The NESHAP 

is based on the same controls as the CTG, but specifies a number of alternative 

combinations of control measures for each type of degreaser. 

SMAQMD Requirements

District Rule 454 (Degreasing Operations) specifies design and work practice standards 

for non-vapor degreasers, vapor degreasers, remote reservoir degreasers, and 

conveyorized degreasers. Rule 454 is equivalent to or more stringent than the CTG 

guidance. In addition, Rule 454 limits the VOC content of solvent used in non-vapor 

degreasers. As an alternative to the work practice standards, Rule 454 allows the use of 

airtight/airless cleaning systems or emission collection and control devices to reduce 

VOC emissions. 

SMAQMD Exemptions

The provisions of Rule 454 do not apply to: 

• Wipe cleaning. 

• Products subject to the Air Resources Board Consumer Products Regulations 

(Subchapter 8.5, Article 2, Section 94507-94517 of Title 17 of the California Code 

of Regulations). 

• Solvent degreasing operations using exempt compounds mixed with VOC if the 

mixture does not contain more than 5 percent VOC (by weight). 

• Solvent degreasing operations that are subject to the NESHAP for Halogenated 

Solvent Cleaning (40 CFR Part 63, Subpart T). Carbon tetrachloride and 

chloroform are the two VOC covered by the NESHAP. 

• Non-vapor degreasers which use solvents containing 50 g/L VOC or less 

(including water and exempt compounds). 

Rule 454 also provides exemptions from some work practice standards for certain types 

of degreasers. Open-top vapor degreasers are not subject to the solvent flow operating 

standards if the solvent spray is kept at least 4 inches below the air-vapor interface and 

liquid solvent does not splash above the air-vapor interface. Also, non-vapor degreasers 

are not subject to the solvent VOC content limit (50 g/L) when degreasing tools, 

equipment, and machinery regulated under Rule 456 (Aerospace Assembly and 

Component Coating Operations) and when degreasing aerospace products using 

solvents that comply with the surface preparation and cleanup VOC limits of Rule 456 

(Aerospace Assembly and Component Coating Operations). 

Conclusion

District Rule 454 requires equipment design and work practice standards that are 

equivalent to or more stringent than the CTG guidance for RACT, and the ACT guidance 

for halogenated solvent controls. 

Rule 454 exempts sources that are subject to the NESHAP. Sources within the District 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 37 

that are subject to the NESHAP will comply with the NESHAP requirements. The District 

has been delegated the authority to enforce the NESHAP. 

Rule 455, in combination with the District’s NESHAP authority, satisfies the RACT 

requirement for this source category. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 38 

Category: Organic Chemical Manufacturing. Process Vents from Reactor 

Processes, Distillation Operations, and Other Separation and Production 

Equipment 

EPA RACT Guidance

1. Control of Volatile Organic Compound Emissions from Air Oxidation Processes in the 

Synthetic Organic Chemical Manufacturing Industry, EPA-450/3-84-015, December 

1984. 

2. Control of Volatile Organic Compound Emissions from Reactor Processes and 

Distillation Operations in the Synthetic Organic Chemical Manufacturing Industry, EPA450/4-91-031, August 1993. 

3. Control of Volatile Organic Compound Emissions from Batch Processes – Alternative 

Control Techniques Information Document, EPA-453/R-93-017, February 1994. 

Applicability

The CTGs apply to continuous process vent streams emitted from air oxidation reactors, 

other reactors, and distillation operations at synthetic organic chemical manufacturing 

industry (SOCMI) process units. The CTG documents provide lists of chemicals affected 

by each CTG and by the Air Oxidation, Reactor Processes, and Distillation NSPS (see 

document #2 above, table 7-1). 

The ACT applies to reactors, distillations columns, filters, dryers, extractors, crystallizers, 

and other process vent emissions within batch processes. 

RACT Requirements

The CTGs establish presumptive RACT for process vents by specifying vent stream 

applicability criteria and VOC limits. 

Process vents from air oxidation reactors, other reactor processes, and distillation 

operations must be controlled if the Total Resource Effectiveness (TRE) index value is 

less than or equal to 1.0. The TRE is a measure of the relative cost effectiveness of 

applying combustion controls. It is calculated using equations in the CTGs. Inputs to the 

TRE calculation are the vent stream flowrate, heating value, and VOC emission rate 

measured after any product recovery devices (e.g., condensers, absorbers, adsorbers) 

through which the reactor or distillation vent stream is discharged. For the air oxidation 

CTG, a TRE of 1.0 is roughly equivalent to a cost effectiveness of $1,600/Mg VOC 

reduced (early 1980s dollars). For the reactor processes and distillation operations CTG, 

a TRE of 1.0 is roughly equivalent a cost of $2,500/Mg (early 1990s dollars). 

The presumptive RACT VOC limit for process vent streams is 98% VOC reduction or 20 

ppmv at the outlet of the combustion control device, corrected to 3% oxygen. A flare 

meeting the design and operational requirements of 40 CFR 60.18 can also be used. 

Product recovery devices (e.g., condensers, absorbers, adsorbers) cannot be used to 

meet the 98% reduction requirement. However a facility could add a recovery device or 

improve recovery efficiency to reduce the VOC emission rate (measured at the outlet of 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 39 

the recovery device) to the point where the TRE became greater than 1.0, and thereby 

avoid the need to install combustion controls. This feature of the RACT guidance 

encourages pollution prevention. 

For batch processes, the ACT presents three alternative control levels of 90%, 95%, or 

98% VOC reduction. The 98% level is based on combustion control. The 90% and 95% 

levels allow for use of recovery devices. The ACT does not recommend process vent 

applicability criteria, but instead provides optional methodologies for individual or 

aggregated batch vents based on emission rates, flow rates, and costs. The model rule 

exempts batch process trains if combined vent emissions are less than 10,000 lb/yr 

VOC. 

Other Federal Requirements

The NSPS for SOCMI air oxidation processes (40 CFR 60 subpart III), SOCMI distillation 

operations (40 CFR 60 subpart NNN), and SOCMI reactor processes (40 CFR 60, 

subpart RRR) specify vent stream applicability criteria that are a bit more stringent than 

the CTGs (a TRE of 1.0 for the NSPS equates to a cost of $3,000/Mg VOC reduced in 

early 1990s dollars). The control requirements are the same as the CTGs. 

The Miscellaneous Organic NESHAP (40 CFR 63 subpart FFFF) controls HAP 

emissions from a specific list of organic chemical processes. The control requirements 

for batch processes apply if uncontrolled organic HAP emissions from all batch process 

vents at the facility, including vents from reactors, filters, and centrifuges, are greater 

than 10,000 lb/yr. Overall batch process vent emissions must be reduced by 98 percent 

or to 20 ppmv using control devices, or by 95% using recovery devices. 

SMAQMD Requirements

District Rule 464, Organic Chemical Manufacturing Operations, requires any reactor, 

distillation column, crystallizer, evaporator or enclosed centrifuge that emits more than 

15 lb/day of maximum uncontrolled VOC to be vented to a VOC capture and control 

system that has a combined system efficiency of at least 85% and a control efficiency of 

at least 90%. 

Rule 464 also requires capture and control of emissions from any centrifuge, rotary 

vacuum filter, or other device at an organic chemical plant that has an exposed liquid 

surface if the liquid contains VOC above a specified vapor pressure and emits more than 

15 lb/day maximum uncontrolled VOC. The rule also requires capture and control of 

dryer or other production equipment exhaust systems that emit 330 lb/day or more of 

maximum uncontrolled VOC emissions. The required combined capture and control 

system efficiency is at least 85% and the control efficiency must be at least 90%. 

SMAQMD Exemptions

Rule 464 exempts facilities that emit 15 lb/day or less of maximum uncontrolled VOC 

emissions. 

The rule also exempts vent streams from reactors, distillation columns, evaporators, 

crystallizers, and centrifuges with maximum uncontrolled VOC emissions of 15 lb/day or 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 40 

less, and separation devices (except at pharmaceutical plants) with maximum 

uncontrolled VOC emissions of 15 lb/day or less. 

Research and development operations including bench scale laboratory and pilot plant 

operations that emit, cumulatively, at design production ratings, 15 lb/day maximum 

uncontrolled VOC emissions are also exempt. 

Conclusion

Rule 464 is consistent with the ACT guidance for batch processes. Rule 464 requires 

90% control for emissions from batch process vents including reactors, distillation 

columns, crystallizers, evaporators, centrifuges, and dryers. The ACT suggests a range 

of control from 90% to 98%. 

There is only one source (Procter and Gamble) within the District to which the CTG 

applies, based on the specific list of chemicals covered by the CTG. Although the 

requirements in Rule 464 are less stringent than the Miscellaneous Organic NESHAP in 

some areas, the Procter and Gamble facility is subject to this NESHAP, for which the 

District has been delegated enforcement authority. The NESHAP requires full 

compliance by May 10, 2008. 

Rule 464, in combination with the District’s NESHAP authority, satisfies the RACT 

requirement for this source category. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 41 

Category: Leaks from Synthetic Organic Chemical and Polymer Manufacturing 

EPA RACT Guidance

Control of Volatile Organic Compound Leaks from Synthetic Organic Chemical and 

Polymer Manufacturing Equipment. EPA-450/3-83-006, March 1984. 

Applicability

This CTG applies to equipment in VOC service in process units operated to produce 

synthetic organic chemicals or polymers. The polymer manufacturing industries to which 

the CTG is applicable are polyethylene, polypropylene, and polystyrene. 

 

RACT Requirements

The EPA guidance document establishes presumptive RACT for equipment leaks as 

follows: 

Equipment Service 

Monitoring Frequency using 

EPA Method 21 

Other requirements 

Valves Gas 

Light liquid 

- 

Pumps Light liquid Weekly visual 

inspection of leaks 

Compressors Gas - 

Pressure relief 

valves 

Gas 

Quarterly at a leak definition 

of 10,000 ppmv 

- 

Open-ended 

lines 

All None Caps or plugs 

Flanges All None Repair visual leaks 

Leaking equipment is required to be repaired within 15 days after the date the leak is 

detected. 

Other Federal Requirements

Subpart VV of 40 CFR Part 60 specifies new source performance standards (NSPS) for 

equipment leaks of VOC in the synthetic organic chemical manufacturing industry as 

follows: 

Equipment Service 

Monitoring Frequency using 

EPA Method 21 

Other requirements 

Valves Gas 

Light liquid 

Decreased 

monitoring 

frequency with good 

performance 

Pumps Light liquid 

Monthly at a leak definition of 

10,000 ppmv Weekly visual 

inspection of leaks 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 42 

Equipment Service 

Monitoring Frequency using 

EPA Method 21 

Other requirements 

Compressors Gas None Equip with seal 

system that 

prevents leaks or 

has no detectable 

emissions 

Pressure relief 

valves 

Gas None No detectable 

emissions 

Open-ended 

lines 

All None Caps or plugs 

Flanges All None Repair visual leaks 

The Miscellaneous Organic NESHAP (40 CFR 63 subpart FFFF) contains requirements 

for equipment leaks in specific chemical manufacturing process units. The NESHAP 

requirements are as follows: 

Equipment Service 

Monitoring Frequency using 

EPA Method 21 

Other requirements 

Valves Gas 

Light liquid 

Monthly at 10,000 ppm 

decreasing to 500 ppm (2.5 

years later) 

Decreased 

monitoring 

frequency with good 

performance 

Pumps Light liquid Monthly at 10,000 ppm 

decreasing to 1,000 ppm (2.5 

years later) 

Weekly visual 

inspection of leaks 

Compressors Gas None Equip with seal 

system that prevents 

leaks or has no 

detectable 

emissions 

Pressure relief 

valves 

Gas None No detectable 

emissions 

Open-ended 

lines 

All None Caps or plugs 

Connectors 

(including 

flanges) 

Gas/light liquid Annually at 500 ppm Decreased 

monitoring 

frequency with good 

performance 

The NESHAP provides that valves and pumps at process units with more than 2 percent 

leaks must meet a quality improvement program, which requires removal and inspection 

of failed equipment, identification of superior technology, and an equipment replacement 

program to achieve less than 2 percent leaks. 

SMAQMD Requirements

District Rule 443, Synthetic Organic Chemical and Polymer Manufacturing, implements 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 43 

the presumptive RACT rule specified in the CTG. Rule 443 is somewhat more stringent 

because Rule 443 requires monitoring of flanges (annually) and requires leaking 

equipment to be repaired more quickly (within 2 working days). Rule 443 allows process 

units with less than 2 percent leaking valves for five consecutive quarters to monitoring 

valves annually, rather than monthly. 

SMAQMD Exemptions

Rule 443 does not apply to equipment operated under a vacuum or to VOCs with a 

vapor pressure less than 0.3 kPa. 

Conclusion

Rule 443 has slightly more stringent requirements than the presumptive RACT guidance 

in the CTG. However, Rule 443 is less stringent than the NSPS and NESHAP, both of 

which require more frequent monitoring and specify lower leak definitions. 

There is only one source (Procter and Gamble) within the District to which the CTG 

applies, based on the specific list of chemicals covered by the CTG. Although the 

requirements in Rule 443 are less stringent than the Miscellaneous Organic NESHAP in 

some areas, the Procter and Gamble facility is subject to this NESHAP, for which the 

District has been delegated enforcement authority. The NESHAP requires full 

compliance by May 10, 2008. The NESHAP is more stringent than the NSPS. 

Rule 443, in combination with the District’s NESHAP authority, satisfies the RACT 

requirement for this source category. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 44 

Category: Wood Furniture Manufacturing (Surface Coating) 

EPA RACT Guidance

Guideline Series: Control of Volatile Organic Compound Emissions from Wood Furniture 

Manufacturing Operations, U.S. EPA Publication No. EPA-453/R-96-007, April 1996. 

Applicability

The CTG applies to any facility that performs surface coating (finishing) on wood 

furniture, or performs cleaning or wash-off operations associated with wood furniture 

finishing operations. Wood furniture includes residential furniture, cabinets, office 

furniture, public building furniture (e.g., benches, bleachers, church furniture), and office 

and store fixtures (e.g., partitions, shelves, lockers). 

RACT Requirements

The EPA guidance document establishes presumptive RACT for wood furniture surface 

coating operations as the following emission limits and work practices: 

Surface Coating Operation VOC limit 

Topcoat 0.8 lb VOC/lb solids, as 

applied 

Sealers 1.9 lb VOC/lb solids, as 

applied 

Sealer 2.3 lb VOC/lb solids, as 

applied 

Acid-cured alkyd amino vinyl sealers and acidcured alkyd amino conversion varnish topcoats 

Topcoat 2.0 lb VOC/lb solids, as 

applied 

Sealer 1.9 lb VOC/lb solids, as 

applied 

Sealer other than an acid-cured alkyd amino 

vinyl sealer; and using acid-cured alkyd amino 

conversion varnish topcoats 

Topcoat 2.0 lb VOC/lb solids, as 

applied 

Sealer 2.3 lb VOC/lb solids, as 

applied 

Acid-cured alkyd amino vinyl sealer and a 

topcoat other than an acid-cured alkyd amino 

conversion varnish topcoat 

Topcoat 1.8 lb VOC/lb solids, as 

applied 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 45 

Surface Coating Operation VOC limit 

Strippable booth coatings 0.8 lb VOC/lb solids, as 

applied 

Work practice standards and Work practice implementation plan to include: 

Operator training course 

Leak inspection and maintenance plan 

Cleaning and washoff solvent accounting system 

Storage requirements 

Application equipment requirements 

Line cleaning 

Gun cleaning 

Wash off operations 

The CTG estimated the nationwide cost-effectiveness of the model rule at $1200/ton of 

VOC reduced (1991 dollars). The cost per model plant ranged from a savings of 

$900/ton of VOC reduced to a cost of $3,600/ton. 

Other Federal Requirements

Subpart JJ of 40 CFR Part 63 specifies National Emission Standards for Hazardous Air 

Pollutants (NESHAP) for wood furniture manufacturing operations at major sources. 

These standards are in terms of lb volatile organic HAP per lb solids applied. Since 

many VOC are not HAP, these limits for HAP establish no practical limits on VOC 

content or emissions from these operations. Work practices in Subpart JJ, which are 

essentially equal to those in the CTG model rule, would reduce VOC as well as HAP 

emissions. 

 

SMAQMD Requirements

District Rule 463, Wood Products Coatings, applies to any person who uses, 

manufactures, blends, sells, repackages, distributes, or specifies the use of wood 

products coatings or strippers. Rule 463 covers coatings used in both new furniture 

manufacturing and in refinishing. Since the CTG covers only new manufacturing 

operations, only the limits for new manufacturing from Rule 463 are presented here. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 46 

Coating 

VOC Limits 

g/liter, 

less water and less exempt compounds 

(lbs-VOC/lbs Solids) 

Clear Topcoats 275 (0.35) 

Conversion varnish 550 (1.20) 

Filler 275 (0.18) 

High Solid Stain 350 (0.42) 

Inks 500 (0.96) 

Mold Seal Coating 750 (4.20) 

Multi-Colored Coating 275 (0.33) 

Pigmented Coating 275 (0.25) 

Sealer 275 (0.36) 

Sealer applied where the topcoat does not 

exceed 275 grams/liter 

680 

Coating VOC Limits 

g/liter 

(lbs-VOC/lbs-solids) 

Low-Solids Stains, Toners, Washcoats 120 (1.00) 

Strippers (analogous to Washoff 

operations in CTG) 

350 (or has a partial composite vapor 

pressure less than 2 mm Hg at 20 o

C) 

Surface preparation or cleanup 200 

Work Practice Requirements include the following: 

• Application equipment requirements 

• Spray gun cleaning requirements 

• Disposal of cloth/paper used for surface preparation, cleanup, or coating removal 

SMAQMD Exemptions

Rule 463 contains the following exemptions: 

• Sources using less than 55 gallons per year. 

• Wood products coatings sold in non-refillable aerosol-spray containers. 

• Coating operations associated with the manufacture of finished wood panels 

intended for attachment to walls. 

• Coating of architectural components when not done in a shop environment. 

• Stencil coatings used to comply with U.S. Military Specifications. 

Conclusion

District Rule 463 establishes VOC limits that are more stringent than the limits in the 

CTG model rule for all coating categories. One difference is that the CTG contains a 

limit for strippable booth coatings, but no limit is included in Rule 463. However, 

strippable booth coatings would be subject to Rule 442, Architectural Coatings, in the 

categories of flat (100 g/L , approx. 0.12 lb VOC/lb solids) or nonflat coatings (150 g/L , 

approx. 0.18 lb VOC/lb solids) which are more stringent than the CTG. 

 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 47 

Rule 463 includes some coating categories not included in the CTG (clear topcoat, filler, 

high-solid stain, multi-colored coating, and pigmented coating). These coatings are 

subcategories of the ones in the CTG, and the VOC limits in Rule 463 are more stringent 

than the most stringent limits in the CTG. Rule 463 also includes limits for inks and mold 

release coatings. These two categories are not addressed in the CTG. 

The work practices in Rule 463 are equivalent to the CTG, except that Rule 463 does 

not include the requirement for an operator training course. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 48 

Appendix B 

RACT Analysis of Non-CTG Source Categories Applicable to Major Sources 

Non-CTG Category 

Page 

Number

Architectural Coatings 49 

Boilers 51 

Stationary Gas Turbines 53 

IC Engines 55 

Municipal Landfill Gas 58 

Organic Chemical Manufacturing - Process Tanks, Liquid Transfer, and 

Storage Tanks (≤40,000 gallons) 

60 

Organic Chemical Manufacturing - Wastewater 63 

Solvent Cleaning (other than Degreasers) 66 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 49 

Category: Architectural Coatings

EPA RACT Guidance

The EPA has not published a Control Techniques Guideline (CTG) or Alternative Control 

Technology (ACT) Document for this source category. 

Applicability

Not applicable. 

RACT Requirements

Not applicable. 

Other Federal Requirements

Subpart D of 40 CFR part 59 (National Volatile Organic Compound Emission Standards 

for Architectural Coatings) specifies VOC content limits (g/L, lb/gal) for 61 categories of 

architectural coatings (i.e., coatings recommended for application to stationary 

structures, their appurtenances, to portable buildings, to pavement, and to curbs). 

Subpart D applies to manufacturers and importers of architectural coatings. The VOC 

content limits are based on “best available controls,” as specified in §183(e) of the Clean 

Air Act. 

Subpart D does not apply to coatings that are: 

• manufactured exclusively for sale or distribution outside the United States, 

• manufactured prior to September 13, 1999, 

• sold in nonrefillable aerosol containers, 

• collected and redistributed at paint exchanges in accordance with this rule, 

• sold in containers with a volume of one liter or less. 

The regulation contains two exemptions. Manufacturers and importers may sell a 

limited quantity of coatings that do not meet the standards, if the total mass of VOC 

contained in those coatings does not exceed the mass limits specified in the rule. The 

rule also allows manufacturers and importers to pay a fee for each gram (or ton) of VOC 

in excess of the applicable VOC limit rather than complying with the content limits. 

SMAQMD Requirements

District Rule 442 (Architectural Coatings) limits the VOC content for 47 categories of 

architectural coatings and specifies work practice standards (e.g., application methods, 

thinning) for coating applications. Rule 442 applies to any person who supplies, sells, 

offers for sale, or manufacturers any architectural coating for use within the SMAQMD 

and to any person who applies or solicits the application of any architectural coating 

within the SMAQMD. 

In most cases, the categories covered under Rule 442 are the same as the categories 

covered under 40 CFR 59. For each coating category, the VOC content limits in Rule 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 50 

442 are the same or more stringent than those specified in 40 CFR 59. However, the 

following 14 coating categories in 40 CFR 59 do not have specific VOC limits in Rule 

442: 

• anti-graffiti coatings, 

• calcimine recoaters, 

• chalkboard resurfacers, 

• concrete protective coatings, 

• concrete surfaced retarders, 

• conversion varnish, 

• extreme high durability coatings, 

• heat reactive coatings, 

• impacted immersion coatings, 

• non-ferrous ornamental metal lacquers and surface protectants, 

• nuclear coatings, 

• repair and maintenance thermoplastic coatings, 

• stain controllers, and 

• thermoplastic rubber coatings and mastics. 

For coating categories that are not specifically listed in Rule 442, the VOC content limits 

for either flat or non-flat coatings apply (depending on gloss). The flat and non-flat 

coatings limits in Rule 442 are more stringent than the 40 CFR 59 limits for each of the 

14 categories listed above. 

Rule 442 also regulates the following coating categories that are not specifically 

identified in 40 CFR 59: 

• recycled coatings; 

• specialty primers, sealers, and undercoaters; 

• swimming pool repair and maintenance coatings; and 

• temperature-indicator safety coatings. 

SMAQMD Exemptions

Rule 442 does not apply to: 

• Any architectural coating that is sold or manufactured for use outside the 

Sacramento Metropolitan Air Quality Management District or for shipment to 

other manufacturers for reformulation or repackaging; 

• Any aerosol coating product; or 

• Any architectural coating that is sold in a container with a volume of one liter 

(1.057 quart) or less. 

Rule 442 does not contain the tonnage or fee exemption contained in 40 CFR 59. 

Conclusion

For all architectural coating categories, the VOC limits specified in District Rule 442 are 

at least as stringent as the limits specified 40 CFR 59, subpart D. Therefore, Rule 442 

satisfies the RACT requirement for this source category. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 51 

Category: Boilers

EPA RACT Guidance

Alternative Control Techniques Document – NOx Emissions from 

Industrial/Commercial/Institutional (ICI) Boilers, U.S. EPA Publication No. EPA-453/R94-022, March 1994. 

Applicability

The guidance applies to boiler, steam generators, and process heaters fired with 

gaseous or liquid fuels. 

RACT Requirements

The EPA guidance document does not establish presumptive RACT for this category. 

However, the ACT document discusses four control techniques for NOx that can be 

applied to natural gas-fired, packaged watertube boilers and estimates achievable 

performance as follows: 

Control Technique Achievable NOx Level 

Water injection w/ oxygen trim 49 ppmv @3% O2

Low NOx burners 66 ppmv @3% O2

Low NOx burners w/ flue gas recirculation 49 ppmv @3% O2

SCR 16 ppmv @3% O2

Other Federal Requirements

Subpart Db of 40 CFR Part 60 specifies New Source Performance Standards (NSPS) for 

industrial, commercial, and institutional steam generating units > 100 mmBtu/hr input 

that were constructed, modified, or reconstructed after June 19, 1984. Low heat release 

rate units are limited to approximately 82 ppmv NOx @ 3% O2, while high heat release 

rate units are limited to approximately 164 ppmv NOx @ 3% O2 firing natural gas or 

distillate oil fuel. These standards are substantially less stringent than the achievable 

levels presented in the ACT document. 

SMAQMD Requirements

In 1991, the ARB issued a RACT determination document for industrial, institutional, and 

commercial boilers, steam generators, and process heaters. The ARB analysis 

considered the achievable performance levels and cost effectiveness of various NOx 

control strategies as applied to different size units. The analysis also took in account the 

variation in NOx emissions between gaseous and liquid fuels. The ARB concluded that 

RACT for units with ratings of 5 mmBtu/hr and larger, using 90,000 therms of fuel or 

more per year, is a NOx emission limit of 70 ppmv @ 3% O2 when firing on gaseous fuel 

and 115 ppmv @ 3% O2 when firing on liquid fuel. 

District Rule 411, NOx from Boilers, Process Heaters and Steam Generators, originally 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 52 

went beyond the RACT emission limits for natural gas and liquid fuels as recommended 

by the ARB guidance. Units with rated heat inputs ≥ 5 mmBtu/hr and using ≥ 90,000 of 

fuel per year were required to meet NOx emission limits of 30 ppmv @ 3% O2 when 

firing gaseous fuel and 40 ppmv @ 3% O2 when firing liquid fuel. This version of the rule 

was approved into the SIP by EPA on February 9, 1996. 

On October 27, 2005, the District amended Rule 411 to establish NOx limits for units 

rated between 1 mmBtu/hr and 5 mmBtu/hr, and to set more stringent standards for 

units rated ≥ 5 mmBtu/hr when firing gaseous fuel. Units rated from1-5 mmBtu/hr are 

limited to NOx emissions of 30 ppmv @ 3% O2; units rated from 5-20 mmBtu/hr are 

limited to NOx emissions of 15 ppmv @ 3% O2; and units rated > 20 mmBtu/hr are 

limited to NOx emissions of 9 ppmv @ 3% O2. The implementation of these revised 

limits will phase in starting on October 27, 2007. This amended version of Rule 411 has 

been submitted to EPA for inclusion in the SIP. 

SMAQMD Exemptions

The original, SIP-approved version of Rule 411 contained an exemption for units with 

annual fuel usage less than 90,000 therms. When Rule 411 was amended on October 

27, 2005, exemptions from the more stringent emission limits were added because of 

cost-effectiveness and technological concerns. Units rated between 1 and 2.5 mmBtu/hr 

are exempt from emission limits if they have annual fuel consumption less than 40,000 

therms. Units rated between 2.5 and 5 mmBtu/hr are exempt from emission limits if they 

have annual fuel consumption less than 70,000 therms. 

Units rated between 5 and 100 mmBtu/hr are not subject to the more stringent emission 

limits (but are still subject to the previous emission limits) if they have annual fuel 

consumption less than 200,000 therms. Units rated at 100 mmBtu/hr and greater are 

not subject to the more stringent emission limits (but are still subject to the previous 

emission limits) if they have annual fuel consumption less than 300,000 therms. Finally, 

gas fire reformer furnaces, units fired on landfill gas, and load following units not subject 

to the more stringent NOx limits (but are still subject to the previous emission limits). 

Conclusion

District Rule 411 requires NOx emission limits that more stringent than the range of 

achievable levels as specified in the EPA guidance document and more stringent than 

the NSPS. The NOx limits in Rule 411 are also more stringent than the ARB 

determination of RACT and apply to smaller units. 

 

Rule 411 satisfies the RACT requirement for this source category. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 53 

Category: Stationary Gas Turbines 

EPA RACT Guidance

Alternative Control Techniques (ACT) Document – NOx Emissions from Stationary Gas 

Turbines, U.S. EPA Publication No. EPA-453/R-93-007, January 1993. 

Applicability

The guidance applies to stationary gas turbines fired with gaseous or liquid fuels. 

RACT Requirements

The EPA guidance document does not establish presumptive RACT for stationary gas 

turbines. However, the ACT document discusses three control techniques for NOx and 

estimates achievable performance as follows: 

 

Control Technique Achievable NOx Level 

Wet injection 25 - 42 ppmv @15% O2

Dry low-NOx combustion 25 - 42 ppmv @15% O2

SCR w/ combustion controls (wet injection or dry low-NOx) 9 ppmv @15% O2

Other Federal Requirements

Subpart GG of 40 CFR Part 60 specifies New Source Performance Standards (NSPS) 

for stationary gas turbines ≥ 10 mmBtu/hr input (approximately 1 MW output) that were 

constructed, modified, or reconstructed after October 3, 1977. Turbines with rated heat 

inputs between 10 and 100 mmBtu/hr are limited to approximately 150 ppmv NOx (with 

upward adjustments for efficiency and fuel-bound nitrogen). Turbines with rated heat 

inputs between > 100 mmBtu/hr are limited to approximately 75 ppmv NOx. These 

standards are substantially less stringent than the achievable levels presented in the 

ACT document. 

SMAQMD Requirements

In 1992, the ARB issued a RACT/BARCT determination document for stationary gas 

turbines. The ARB analysis considered the achievable performance levels and cost 

effectiveness of various NOx control strategies as applied to different sizes of gas 

turbines. The analysis also took in account the variation in NOx emissions between 

gaseous and liquid fuels. The ARB concluded that RACT for gas turbines with ratings of 

0.3 MW and larger is a NOx emission limit of 42 ppmv @ 15% O2 when firing on 

gaseous fuel and 65 ppmv @ 15% O2 when firing on liquid fuel. More stringent levels of 

control were considered as BARCT. 

District Rule 413, Stationary Gas Turbines, implements the RACT and BARCT emission 

limits as recommended by the ARB guidance. The Rule 413 emission limits are listed in 

the table below. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 54 

NOx Emission Limit 

(ppmv @ 15% O2) Requiremen

t 

Type

Annual 

Hours of 

Operation 

(hr/yr)

Unit Size 

Rating 

(MW)

Gaseous 

Fuel

Liquid 

Fuel

RACT any ≥0.3 42.0 65.0 

any ≥0.3 to <2.9 42.0 65.0 

<877 ≥2.9 42.0 65.0 

≥877 ≥2.9 to <10 25.0 65.0 

≥877 ≥10.0 (no SCR) 15.0 42.0 

BARCT

≥877 ≥10.0 (w/ SCR) 9.0 25.0 

SMAQMD Exemptions

Rule 413 contains exemptions that were included in the ARB determination of 

RACT/BARCT: 

• Laboratory units used in research and testing for the advancement of gas turbine 

technology. 

• Units used to provide emergency electrical power, emergency water pumping for 

flood control or fire fighting, emergency potable water pumping, or emergency 

sewage pumping, provided they are limited to an annual total of 200 hours of 

operation (100 hours for maintenance). 

Startup and shutdown periods are exempt from Rule 413. Shutdown periods are not to 

exceed 1 hour. Startup periods are not to exceed 1 hour, except for turbines ≥ 160 MW 

output that are part of a combined cycle process, for which the one-hour period was 

determined to be technologically infeasible. These units are allowed up to 4 hours for a 

startup that follows a shutdown of 72 hours or more, and up to 3 hours for a startup that 

follows a shutdown of between 8 and 72 hours. 

Conclusion

District Rule 413 requires NOx emission limits that are in the range of achievable levels 

as specified in the EPA guidance document. The requirements are in accordance with 

the ARB determination of RACT for gas turbines rated between 0.3 and 2.9 MW. More 

stringent BARCT emission limits are required for gas turbines rated greater than 2.9 

MW. 

Rule 413 satisfies the RACT requirement for this source category. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 55 

Category: IC Engines

EPA RACT Guidance

Alternative Control Techniques Document – NOx Emissions from Stationary 

Reciprocating Internal Combustion Engines, U.S. EPA Publication No. EPA-453/R-93-

032, July 1993. 

Applicability

The guidance applies to spark-ignited and compression ignition stationary engines. 

RACT Requirements

The EPA guidance document does not establish presumptive RACT for this category. 

However, the ACT document discusses the control techniques for NOx that can be 

applied to rich burn spark-ignited engines, lean burn spark-ignited engines, and diesel 

engines, and estimates achievable performance as follows: 

Rich Burn Engines, 80-hp to 8,000-hp 

Control Technique Achievable NOx Level 

Air/Fuel Adjustment 640-940 ppmv @15% O2

Ignition Timing Retard 640-1,060 ppmv @15% O2

Air/Fuel Adjustment plus Ignition Timing Retard 640-940 ppmv @15% O2

Prestratified Charge 135 ppmv @15% O2

Nonselective Catalytic Reduction 20-110 ppmv @15% O2

Low-Emission Combustion 135 ppmv @15% O2

Lean Burn Engines, 200-hp to 11,000-hp 

Control Technique Achievable NOx Level 

Air/Fuel Adjustment 860-1,170 ppmv @15% O2

Ignition Timing Retard 980-1,260 ppmv @15% O2

Air/Fuel Adjustment plus Ignition Timing Retard 740-980 ppmv @15% O2

Selective Catalytic Reduction 125 ppmv @15% O2

Low-Emission Combustion 150 ppmv @15% O2

Diesel Engines, 80-hp to 8,000-hp 

Control Technique Achievable NOx Level 

Ignition Timing Retard 610-700 ppmv @15% O2

Selective Catalytic Reduction 90-175 ppmv @15% O2

SMAQMD Requirements

District Rule 412, Stationary Internal Combustion Engines Located at Major Stationary 

Sources of NOx, sets emission standards for engines greater than 50 horsepower (hp) 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 56 

at major sources of NOx. The rule establishes the following NOx emission limits: 

Engine Type 

NOx Emission Limit 

(ppmv @15% O2) 

Spark Ignited, Rich Burn 50 

Spark Ignited, Lean Burn 65 

Compression Ignited 700 

In addition, spark ignited rich burn engines and compression ignited engines are 

required to meet more stringent emission limits if they are operated more than a 

specified number of annual hours, depending on engine size: 

 

Engine Type 

More Stringent 

NOx Emission Limit 

(ppmv @15% O2) 

Spark Ignited, Rich Burn 25 

Compression Ignited 80 

The above limits apply to engines with annual operating hours exceeding those shown in 

the table below: 

Engine Type Size (hp) 

Annual Hours of 

Operation 

Spark Ignited, Rich Burn > 50 to 75 200 

Spark Ignited, Rich Burn > 75 to 125 120 

Spark Ignited, Rich Burn > 125 to 155 100 

Spark Ignited, Rich Burn > 155 to 200 80 

Spark Ignited, Rich Burn > 200 to 300 60 

Spark Ignited, Rich Burn > 300 to 400 45 

Spark Ignited, Rich Burn > 400 to 525 40 

Spark Ignited, Rich Burn > 525 0 

Compression Ignited > 50 to 75 1,435 

Compression Ignited > 75 to 125 830 

Compression Ignited > 125 to 155 565 

Compression Ignited > 155 to 200 460 

Compression Ignited > 200 to 300 365 

Compression Ignited > 300 to 400 250 

Compression Ignited > 400 to 525 200 

Compression Ignited > 525 0 

SMAQMD Exemptions

The following types of engines are exempt from Rule 412: 

• Emergency standby engines 

• Agricultural engines 

• Engines on test stands 

• Research engines 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 57 

• Nonroad (portable) engines 

• Motor vehicle engines 

• Engines used to support flight line operations 

Conclusion

District Rule 412 requires NOx emission limits that either within or more stringent than 

the range of achievable levels as specified in the EPA guidance document. 

Rule 412 satisfies the RACT requirement for this source category. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 58 

Category: Municipal Landfill Gas 

EPA RACT Guidance

The EPA has not published a Control Techniques Guideline (CTG) or Alternative Control 

Technology (ACT) Document for this source category. 

Applicability

Not Applicable. 

RACT Requirements

Not Applicable. 

Other Federal Requirements

Subpart WWW of 40 CFR Part 60 specifies New Source Performance Standards 

(NSPS) for municipal solid waste landfills that commenced construction, modification, or 

reconstruction on or after May 30, 1991. Landfills with design capacities of at least 2.5 

million Mg and 2.5 million m3

 must calculate nonmethane organic compound (NMOC) 

emissions annually. When calculated uncontrolled NMOC emissions reach 50 Mg/year, 

the landfill must install a landfill gas collection and control system within 30 months. The 

gas collection system must meet specified design criteria or the equivalent. The control 

system must reduce NMOC by 98% or to an outlet concentration of 20 ppmv (if using an 

enclosed combustion device). Use of a flare meeting NSPS design and operating 

criteria, or use of a gas treatment system that treats landfill gas for subsequent sale or 

use as a fuel are also allowed. 

Subpart Cc of 40 CFR Part 60 specified Emission Guidelines that apply to landfills that 

both (1) have accepted waste since November 8, 1987 or have additional design 

capacity available for future waste deposition, and (2) commenced construction, 

modification or reconstruction before May 30, 1991 (i.e., are not subject to the NSPS). 

The landfill gas collection and control requirements in the Emission Guidelines are 

identical to the NSPS. The Emission Guidelines are implemented through State Plans 

that are approved by EPA. 

Subpart AAAA of 40 CFR Part 63 specifies National Emission Standards for Hazardous 

Air Pollutants (NESHAP) for new and existing municipal solid waste landfills that have 

accepted waste since November 8, 1987 or have additional design capacity available for 

future waste deposition. The gas collection and control requirements are identical to the 

NSPS. The only difference is that landfills that are operated as bioreactors must collect 

and control gas earlier because they emit more gas sooner than conventional landfills. 

Bioreactors are defined as landfills that add liquids other than leachate to reach a 

minimum waste moisture content of 40% to accelerate anaerobic biodegradation of the 

waste. For a bioreactor located at a landfill that has a design capacity of at least 2.5 

million Mg and 2.5 million m3

, gas collection and control systems must be installed 

before initiating liquids addition and these systems must begin operation within 180 days 

after initiating liquids addition or within 180 days after reaching 40% waste moisture 

content. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 59 

SMAQMD Requirements

District Rule 485, Municipal Landfill Gas, implements the 40 CFR Part 60 Subpart Cc 

Emission Guidelines for municipal solid waste landfills described in the preceding 

section. Rule 485 is identical to the Subpart Cc Emission Guidelines except that Rule 

485 does not allow passive gas collection systems or open flares. Landfills that meet the 

design capacity and NMOC emission rate criteria for requiring controls must use active 

collection systems and control devices or treatment systems, other than flares, that meet 

the requirements in the NSPS and Emission Guidelines. 

SMAQMD Exemptions

Rule 485 exempts sources that are subject to the NSPS subpart WWW. 

Conclusion

There is only one major source (Kiefer Landfill) within the District for which RACT must 

be demonstrated in this source category. The Kiefer Landfill is subject to the NSPS 

subpart WWW, and is therefore exempt from Rule 485. This source is also subject to 

the NESHAP subpart AAAA. 

The NSPS and NESHAP contain the most stringent requirements that are applicable to 

municipal landfill gas, and meet or exceed the requirements of RACT. The District has 

been delegated the authority to enforce the NSPS and NESHAP. The RACT 

requirement has been satisfied for this source category. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 60 

Category: Organic Chemical Manufacturing - Process Tanks, Liquid Transfer, and 

Storage Tanks (≤40,000 gallons) 

EPA RACT Guidance

The EPA has not published a CTG or ACT for process tanks, liquid transfer, or storage 

tanks with capacities ≤40,000 gallons for this source category. 

(RACT for volatile organic liquid storage tanks > 40,000 gallons is analyzed as a 

separate category.) 

Applicability

Not applicable 

RACT Requirements

Not applicable 

Other Federal Requirements

Process tanks: There are no NSPS covering in-process tanks at synthetic organic 

chemical manufacturing industry (SOCMI) facilities. The Miscellaneous Organic 

NESHAP (40 CFR Part 63, Subpart FFFF) controls surge control vessels and bottoms 

receivers at existing sources if the vessels are larger than 75 m3

 (20,000 gallons) and 

have a maximum true vapor pressure of organic HAP above specified levels (see 40 

CFR 63.170 and table 2 of 40 CFR 63 subpart H). Such vessels must be either (1) 

routed through a closed vent system to a 95% efficient control device, or (2) equipped 

with an internal floating roof (IFR) or external floating roof (EFR) with the seals and 

fittings specified in 40 CFR 63.119. 

Liquid transfer: There are no NSPS covering liquid transfer from SOCMI facilities. The 

NESHAP (40 CFR Part 63, Subpart FFFF) covers transfer racks that load liquid 

containing organic HAP into tank trucks or railcars. Control is required only for racks 

that load at least 0.65 million liters/yr (170,000 gallons/yr) and have average vapor 

pressures of at least 10.3 kPa (1.5 psia). These racks require vapor collection systems 

and controls. There are 3 control options: (1) control devices (e.g., combustion devices 

or recovery devices) that reduce organic HAP emissions by 98% or to 20 ppmv, (2) 

flares that meet the design and operational requirements of 40 CFR 60.18, or (3) a vapor 

balance system that routes collected vapors back to a storage vessel or to a process. 

Storage Tanks (≤ 40,000 gallons): The NSPS subpart Kb applies to storage vessels 

with a volume between 19,800 gallons and 40,000 gallons. Tanks with a vapor pressure 

between 27.6 kPa and 76.6 kPa must be controlled with either an internal floating roof 

(IFR), an external floating roof (EFR), or by routing emissions to a control device that 

achieves at least 95%VOC reduction. IFR tanks, or fixed roof tanks retrofitted with an 

IFR, must be equipped with a foam or liquid filled seal mounted in contact with the liquid 

or a mechanical shoe seal or 2 seals mounted one above the other to form a continuous 

enclosure. EFR tanks are to be equipped with a closure device that has specified types 

of seals between the wall of the tank and the roof edge. For IFR and EFR tanks, 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 61 

openings must be equipped with covers, seals, or lids. The NSPS specifies extensive 

fitting requirements for the various types of openings and cover penetrations. 

All tanks with volumes greater than 19,800 gallons and vapor pressures greater than 

76.6 kPa are required to route vent streams to a control device that achieves at least 

95% VOC reduction. 

The NESHAP (40 CFR Part 63, Subpart FFFF) also applies to storage vessels in 

organic HAP service. The requirements for NESHAP storage vessels are the same as 

in subpart Kb. Tanks with volumes between 75 m3 (20,000 gallons) and 151 m3

 (40,000 

gallons) with vapor pressures greater or equal to 13.1 kPa are required to be controlled. 

 

SMAQMD Requirements

Process Tanks: District Rule 464, Organic Chemical Manufacturing Operations, 

prohibits process tanks with a VOC composite vapor pressure over 26 mm Hg (0.5 psi) 

unless it is a closed container that is kept tightly covered. Any process tanks with vapor 

pressures over 26 mm Hg (0.5 psi) that emit more than 15 lb/day maximum uncontrolled 

VOC must be vented to a capture and control system with a combined system efficiency 

of at least 85% and a control efficiency of at least 90%. Process tanks include surge 

control vessels, bottoms receivers and other in-process tanks as defined in the rule. 

 

Liquid Transfer: Rule 464 requires control of transfer operations that load liquid with a 

VOC composite partial vapor pressure of 26 mm Hg (0.5 psi) into tank trucks, trailers, 

railcars, or storage tanks of 2000 gallons capacity or greater. There are 3 control 

options: (1) a vapor balancing system that captures and routes vapors back to a supply 

storage tank, (2) a capture and control system with a combined efficiency of at least 

85% and a VOC control efficiency of at least 90%, or (3) an IFR or EFR that complies 

with 40 CFR 63.119 and 63.120 (NESHAP storage vessel requirements). 

Storage Tanks (≤40,000 gallons): Rule 464 requires storage tanks with capacities 

greater than 55 gallons and less than or equal to 40,000 gallons that store materials with 

a VOC composite partial vapor pressure greater than 78 mm Hg (1.5 psi) to install a 

pressure/vacuum valve on all tank vents. Storage tanks with capacities of 55 gallons or 

less and vapor pressures greater than 78 mm Hg (1.5 psi) must be closed containers 

that are kept tightly covered. 

SMAQMD Exemptions

Rule 464 exempts facilities that emit 15 lb/day or less of maximum uncontrolled VOC 

emissions. 

Rule 464 exempts process tanks that emit 15 lb/day or less of maximum uncontrolled 

VOC emissions. 

Research and development operations including bench scale laboratory and pilot plant 

operations that emit, cumulatively, at design production ratings, 15 lb/day maximum 

uncontrolled VOC emissions are also exempt. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 62 

Conclusion

There is only one major source (Procter and Gamble) within the District for which RACT 

must be demonstrated in this source category. The Procter and Gamble facility is also 

subject to the NESHAP (40 CFR Part 63, Subpart FFFF), for which the District has been 

delegated enforcement authority. The NESHAP contains more stringent requirements in 

some areas, and full compliance with the NESHAP is required by May 10, 2008. The 

NESHAP is more stringent than NSPS subpart Kb. 

Rule 464, in combination with the District’s NESHAP authority, satisfies the RACT 

requirement for this source category. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 63 

Category: Organic Chemical Manufacturing - Wastewater 

EPA RACT Guidance

1. Control Techniques Guidelines (CTG) Document - Control of Volatile Organic 

Compound Emissions from Industrial Wastewater, EPA-453/D-93-056, Draft. 

September 1992. 

2. Alternative Control Technology (ACT) Document - Air Emissions from Industrial 

Wastewater. April 1994. 

Applicability

The draft CTG document addresses RACT for control of VOC emissions from the 

collection and treatment of industrial wastewater generated from the organic chemicals, 

plastics, and synthetic fibers industry and other industries. A final version of the CTG 

was not published. 

The ACT document updates the draft CTG to be consistent with the provisions of the 

final NESHAP for the Synthetic Organic Chemical Manufacturing Industry (40 CFR 63, 

subparts F and G). The NESHAP serves as the model rule for the draft CTG document. 

 The ACT contains revised factors for estimating emissions from wastewater streams 

and treatment devices and revised impact tables (i.e., emissions, emission reductions, 

and control costs for various concentration and flow rate applicability cutoffs) for States 

to use in selecting RACT. 

RACT Requirements

The draft CTG specifies presumptive RACT as (1) suppression of emissions from the 

point of generation through final treatment, (2) treatment of wastewater streams to 

remove VOC, and (3) control of VOC emissions from any vents from the wastewater 

collection system or treatment devices. The treatment technology that is the basis for 

RACT is steam stripping (or an equivalent technology such as biological treatment). 

Table A summarizes the design and control requirements for wastewater collection 

system components and treatment processes in the draft CTG. The presumptive RACT 

applies to wastewater streams with a VOC concentration of at least 500 parts per million 

by weight (ppmw) and a flow rate of 1 liter per minute (lpm) or more, or a VOC 

concentration of at least 10,000 ppmw at any flow rate. 

Other Federal Requirements

The Miscellaneous Organic NESHAP (40 CFR 63 subpart FFFF) applies to wastewater 

streams generated by specific chemical processes located at major sources. The 

NESHAP requirements (see Table A) are essentially the same as the draft CTG (i.e., 

suppression or control of emissions from collection system components and control of 

emissions from treatment processes). The requirements include 40 CFR 63 subparts F 

and G by reference. The control requirements apply to wastewater streams with HAP 

concentrations of at least 1,000 ppmw and flow rates of at least 10 lpm, and streams 

with HAP concentrations of 10,000 ppmw or more at any flow rate. Different applicability 

cutoffs (10 ppmw and greater, 0.02 lpm and greater) apply to wastewater streams 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 64 

containing very volatile HAP at new sources. 

SMAQMD Requirements

District Rule 464, Organic Chemical Manufacturing Operations, regulates any 

wastewater stream with a total VOC concentration of at least 5 ppmw and a flow rate of 

at least 0.02 lpm, or a total VOC concentration at least 10,000 ppmw at any flow rate. 

Rule 464 requires the same types of suppression and control techniques for wastewater 

collection system components as specified in the draft CTG and the NESHAP (see 

Table A). Rule 464, however, does not require treatment of the wastewater to remove 

VOC. 

SMAQMD Exemptions

Rule 464 exempts organic chemical plants that emit 15 lb/day or less of maximum 

uncontrolled VOC emissions. Research and development operations that emit 15 lb/day 

or less of maximum uncontrolled VOC emissions also are exempt. 

Conclusion

The Rule 464 criteria (i.e., concentration and flow rate) for determining which wastewater 

streams are subject to the control requirements are more stringent than the draft CTG 

and the NESHAP. Therefore, Rule 464 would regulate more waste streams than the 

CTG or NESHAP. The Rule 464 suppression requirements for wastewater collection 

system components are more stringent than the draft CTG and are essentially the same 

as those specified in the NESHAP. However, the required destruction efficiency of 

devices used to control any vented emissions from wastewater collection system 

components is not as high as the draft CTG or the NESHAP. Rule 464 requires 90 

percent destruction while the NESHAP requires at least 95 percent destruction. 

The draft CTG and the NESHAP both require removal of VOC from wastewater streams, 

which is not required by Rule 464. 

There is only one major source (Procter and Gamble) within the District for which RACT 

must be demonstrated in this source category. The Procter and Gamble facility is also 

subject to the NESHAP (40 CFR Part 63, Subpart FFFF), for which the District has been 

delegated enforcement authority. The NESHAP contains more stringent requirements in 

some areas, and full compliance with the NESHAP is required by May 10, 2008. 

Rule 464, in combination with the District’s NESHAP authority, satisfies the RACT 

requirement for this source category.
Staff Report 

RACT SIP Analysis September 26, 2006, Page 65 

Table A. Summary of Wastewater Management Unit Requirements 

This type of Must be equipped with a . . . 

equipment . . Draft CTG Miscellaneous Organics NESHAP 

(40 CFR 63 Subpart FFFF) 

SMAQ

Tanks • Fixed roof, 

• Floating roof, or • Cover vented to a control device

Fixed roofa Fixed roofa

Surface impoundments 

Floating membrane cover • Floating membrane coverb, or 

• Cover vented to a control deviceb

Cover vented to a contro

Separators • Fixed roof, or 

• Floating roof 

• Fixed roof vented to a control device, or • Floating roof 

• Fixed roof vented to • Floating roof, • Solid, sealed, gask• Solid, vapor-tight, fu

Containersc Not addressed in the draft CTG • Leak-less cover, 

• Container meeting Dept. of 

Transportation (DOT) standardsd, or 

• Cover vented to a control deviced

Cover 

Individual drain system components 

Leak-less cover • Leak-less covers, 

• Cover vented to a control device, or • Drains, junction boxes, and sewer lines 

that meet design standards 

• Vapor-tight cover, o• Cover vented to a c

Wastewater treatment devices 

Steam stripping (or equivalent technology) Steam stripping (or equivalent technology) Not specified 

Emission control devices 

95 - 99.5% destruction 95% destruction (or an outlet concentration of 

< 20 ppmv - for enclosed combustion devices 

only) 

90% destruction 

aIf used to mix (e.g., by air sparging), heat, or treat wastewater with an exothermic reaction, then the tank must be equipped with a floating roobAir emission controls (e.g., covers) are not required for surface impoundments that are used for open biological treatment processes. cThe NESHAP and SMAQMD Rule 464 require submerged fill pipes for containers with capacities of 0.42 m3 or more. dOnly for containers with capacities less than 0.42 m3. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 66 

Category: Solvent Cleaning (other than Degreasers) 

EPA RACT Guidance

ACT Document - Industrial Cleaning Solvents, U.S. EPA Publication No. EPA-453/R-94-

015, February 1994. 

Applicability

The ACT document applies to the use of solvents to remove contaminants (e.g., 

adhesives, inks, paint, dirt, soil, oil, and grease) in unit operations involving techniques 

such as wiping, spraying, brushing, purging, and dipping, The ACT document does not 

address remote reservoir cold cleaners or vapor, in-line, or batch-loaded degreasers. 

RACT Requirements

The ACT document essentially specifies an environmental management program for 

reducing VOC emissions from industrial cleaning solvents. The program consists of 

solvent accounting and plant management actions. The accounting practices raise 

awareness of solvent use practices by measuring and recording the use, fate, and cost 

of all cleaning solvents used at a facility. The knowledge gained from the solvent 

accounting practices would be used by facility managers to develop techniques for 

reducing emissions (e.g., alternative cleaning solutions, work practices and equipment 

changes to reduce solvent use, use of control devices). The ACT does not evaluate 

specific work practices or emission limits. 

Other Federal Requirements

No Federal requirements have been established for this category, but a Control 

Techniques Guidelines (CTG) document for industrial solvent cleaning is currently under 

development and, by court order, must be published by September 2006. 

SMAQMD Requirements

District Rule 466 (Solvent Cleaning) implements the recommendations of the ACT by 

specifying VOC content limits for solvents; labeling requirements; and work practices for 

solvent cleaning devices and for solvent storage and disposal. Rule 466 applies to 

users and sellers of VOC cleaning materials and to persons that store and dispose of 

VOC-containing materials used in solvent cleaning. 

Rule 466 specifies a VOC content limit of 50 g/liter of solvent (including water and 

exempt solvents) for general wipe cleaning and maintenance cleaning. The limits range 

from 300 to 800 g/liter for certain specialized applications. 

As an alternative to meeting the VOC content, cleaning device, and cleaning method 

standards, Rule 466 allows the use of a vent system that collects at least 90 percent of 

the mass emissions generated by the solvent cleaning operations and a control device 

that meets either a 95-percent control efficiency or achieves and outlet concentration 

less than 50 parts per million as carbon. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 67 

For sellers of solvent, the rule requires that the following information be provided to the 

purchaser at the time of the sale: 

• Solvent type by name/code/manufacturer; 

• Maximum VOC content (g VOC/L of solvent, or lb VOC/gal) of the cleanup 

solvent as applied (including water and exempt compounds); and 

• Recommendations regarding thinning, reducing, or mixing with any solvent (if 

applicable). 

SMAQMD Exemptions

District Rule 466 exempts the following solvent cleaning operations: 

• Cleaning of solar cells, laser hardware, scientific instruments, and high-precision 

optics; 

• Cleaning of cotton swabs to remove cottonseed oil before cleaning of highprecision optics; 

• Cleaning of paper-based gaskets and clutch assemblies where rubber is bonded 

to metal by means of an adhesive; 

• Cleaning of application equipment used to apply coatings on satellites and 

radiation effect coatings; 

• Cleaning of electrostatic coating application equipment; and 

• Janitorial cleaning, including graffiti removal. 

• Cleaning of sterilization ink indicating equipment if the solvent usage is less than 

1.5 gallons per day; and 

• Cleaning with aerosol if 160 fluid ounces or less of aerosol product are used per 

day, per stationary source. 

District Rule 466 also exempts solvent cleaning operations that are covered by the 

District rules listed below. The requirements for cleaning solvents in these rules are 

summarized in Table 1 at the end of this report. 

• Rule 444 (Petroleum Solvent Dry Cleaning); 

• Rule 450 (Graphic Arts Operations); 

• Rule 451 (Surface Coating Of Miscellaneous Metal Parts and Products); 

• Rule 452 (Can Coating); 

• Rule 454 (Degreasing Operations); 

• Rule 456 (Aerospace Assembly and Component Coating 

Operations); 

• Rule 459 (Automotive, Truck and Heavy Equipment Refinishing 

Operations); 

• Rule 460 (Adhesives and Sealants); 

• Rule 463 (Wood Products Coating); 

• Rule 464 (Organic Chemicals Manufacturing Operations); and 

• Rule 465 (Polyester Resin Operations). 

Conclusion

District Rule 466 establishes VOC content limits and work practice standards that 

conform to the types of management practices identified in the ACT. The solvent 

cleaning requirements for the rules summarized in Table 1 also conform to the ACT. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 68 

Rule 466 has broader coverage than the ACT because it applies to sellers of cleaning 

solvents as well as users and to anyone that stores or disposes of cleaning solvents. 

Rule 466 satisfies goes beyond the RACT requirements specified in the ACT for this 

source category. Rule 466 specifies emission limits and work practice standards, which 

the ACT does not. This rule has not yet been submitted for inclusion in the SIP, but will 

be submitted. 
Staff Report 

RACT SIP Analysis September 26, 2006, Page 69 Table 1. Control Requirements for Solvent Cleaning Operations District Rule Number Source Category Summary of Solvent Cleaning Requireme444 Petroleum Solvent Dry Cleaning - Does not regulate solvents used to clean equipment. 

- Dry cleaning solvent must be stored in closed containers equipped with vents approved by the Air Pollution Control 

450 Graphic Arts Operations - Specifies VOC content limits of 72 g/L for general cleanin

other limits for 8 categories of application equipment clean- As an alternative to VOC content limits, a collection syste75%) plus control device (efficiency of 95%) may be used. - For lithographic and letterpress cleaning other than blankwashes, the rule specifies limit on total monthly usage of c- Specifies closed storage for VOC cleaning solvent when the disposal of VOC-containing cloth, sponges, etc. 

451 Surface Coating Of Miscellaneous 

Metal Parts and Products 

- Specifies VOC content of 72 g/L for product cleaning and preparation materials. - Specifies VOC content of 72 g/L for application equipmenmaterials (exempts electrostatic spray guns) or use of an ecleaner. -As an alternative to VOC content limits and spray gun limcollection and control system with overall system efficiency used. - Spray gun nozzles may be soaked in solvent-based matetightly closed container 5 gallons or less in size. - Specifies closed storage for VOC cleaning solvent when the disposal of VOC-containing cloth, sponges, etc. 

452 Can Coating - Specifies VOC content of 200 g/L for cleanup solvents. 

- Specifies closed storage for VOC cleaning solvent when the disposal of VOC-containing cloth, sponges, etc. 

454 Degreasing Operations - Regulates solvent use in degreasing machines. Does no
Staff Report 

RACT SIP Analysis September 26, 2006, Page 70 District Rule Number Source Category Summary of Solvent Cleaning Requireme

requirements for solvents used in other types of cleaning owipe cleaning). - Specifies closed storage for VOC cleaning solvent when the disposal of VOC-containing cloth, sponges, etc. 

456 Aerospace Assembly and Component 

Coating 

- Specifies VOC content of 200 g/L for application equipmematerials (exempts electrostatic spray guns) or use of an ecleaner. - Specifies VOC content of 200 g/L or composite VOC partlimit of 45 mm Hg for surface preparation and cleaning. - As an alternative to VOC content limits, an emission collesystem with overall system efficiency of 85% must be used- Specifies closed storage for VOC cleaning solvent when the disposal of VOC-containing cloth, sponges, etc. 

459 Automotive, Truck and Heavy 

Equipment Refinishing Operations 

- Specifies VOC content of 72 g/L for surface preparation, content limit of 780 g/L is specified for hand-held spray botsolvent to remove road tar, engine oil, grease, overspray, o- Specifies closed storage for VOC cleaning solvent when the disposal of VOC-containing cloth, sponges, etc. - Specifies VOC content of 72 g/L for application equipmengun nozzles may be soaked in solvent-based materials witcontainer 5 gallons or less in size. 

460 Adhesives and Sealants - Specifies VOC content limits and/or composite partial vap

of: 70 g/L for unenclosed equipment cleaning, 45 mm Hg fcleaning and cleaning of equipment other than adhesive oapplication, and 9.5 mm Hg for soaking application equipmcontainer. - As an alternative to VOC content limits, a collection systeefficiency of 90% and an emission control device of 95% remay be used. 
Staff Report 

RACT SIP Analysis September 26, 2006, Page 71 District Rule Number Source Category Summary of Solvent Cleaning Requireme

- Must use wipe cleaning or non-propellant spray bottles. - Specifies closed storage for VOC cleaning solvent when the disposal of VOC-containing cloth, sponges, etc. 

463 Wood Products Coating - Specifies VOC content of 200 g/L for cleanup solvents. 

- Specifies that may not use VOC-containing cleaning mateequipment cleaning unless equipment is disassembled and enclosed gun cleaner. - Specifies closed storage for VOC cleaning solvent when the disposal of VOC-containing cloth, sponges, etc. 

464 Organic Chemicals Manufacturing 

Operations 

- Specifies VOC content of 200 g/L and VOC partial pressufor in-line solvent cleanup of process units and piping (with for 15 lb/day or less FDA-regulated applications). As an altcontent limits, an emission collection and control system wefficiency of 85% and 90% control device efficiency must b- Specifies a 50 g/L VOC content limit for maintenance of mand work area cleaning (with the limited exception for labo- Specifies closed storage for VOC cleaning solvent when the disposal of VOC-containing cloth, sponges, etc. 

465 Polyester Resin Operations - Specifies VOC content of 204 g/L for cleaning materials, 

enclosed gun cleaner. Exempts cleaning of molds, spray edispensing equipment used in gel coat or specialty resin ocome in direct contact with polyester resin, provided that thof exempt cleaning materials does not exceed 16 gallons. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 72 

Appendix C 

RACT Analysis of Major Sources 

Major Source 

Page 

Number

Aerojet 73 

Campbell Soup Supply Co. 80 

Carson Cogeneration Project 82 

Chevron 84 

Cosumnes Power Plant (SMUD) 86 

Kiefer Landfill 87 

Procter & Gamble 90 

Sacramento Cogeneration Authority 93 

Santa Fe Pacific Pipeline 95 

UC Davis Medical Center 97 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 73 

Major Source: Aerojet 

Potential to Emit

VOC: 83.5 ton/yr (major) 

NOx: 163.8 tons/yr (major) 

Facility Description

Aerojet manufactures liquid and solid propulsion systems and aerospace components in 

support of government and commercial contracts. Aerojet also manufactures ordnance items in 

support of government and commercial contracts. The plant consists of the following 

components that emit VOC or NOx: 

8 Emergency IC engine/generators - diesel 

14 Emergency IC engines/fire pumps – diesel 

One Emergency IC engines/electrical generator – propane 

39 Small boilers (<5.0 mmBtu/hr) 

20 Large boilers 

One Autoclave unit 

60 Space heaters 

15 Rocket testing stands 

5 Aerospace coating operations (NESHAP) 

7 Aerospace coating operations (non-NESHAP) 

Two RDX drying facilities 

Two Cold cleaning operations 

Two Bowl cleaning operations 

One Liquid waste volume reduction operation 

One Gasoline Dispensing Facility 

Air Pollution Controls and Emission Limits

This facility is a major source of NOx and VOC. Emissions of NOx are produced from 

combustion of fossil fuels in the engines, boilers, autoclave, space heaters, and rocket test 

stands. VOC emissions are generated by the coating operations, the cleaning operations, the 

RDX drying, and as a byproduct of the combustion of fossil fuels in the engines, boilers, 

autoclave, space heaters, and rocket test stands. 

IC Engines: The engines are all designated for emergency use, and are limited to a 

maximum of 100 hours of non-emergency use. These engines do not have any external 

controls, and are not subject to any rule based emissions limits. The engines are permitted 

to the following emission limits:

Permit Number NOx Limit (grams/hp-hr) VOC Limit (grams/hp-hr) 

10294 14.1 1.14

10421 14.1 1.14

10422 14.1 1.14
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 74 

Permit Number NOx Limit (grams/hp-hr) VOC Limit (grams/hp-hr) 

10423 14.1 1.14

10426 14.1 1.14

10779 14.1 1.14

14748 6.02 1.14

15335 6.9 1

10408 14.1 1.14

10434 14.1 1.14

10435 14.1 1.14

10436 14.1 1.14

10437 14.1 1.14

10438 14.1 1.14

10439 14.1 1.14

10440 14.1 1.14

10441 14.1 1.14

10442 14.1 1.14

10443 14.1 1.14

10444 14.1 1.14

10445 14.1 1.14

10446 14.1 1.14

10424 12 0.72

Boilers: The boilers at the facility are all used for either steam or hot water. They are fired 

on a variety of fuels, and are not required to be equipped with external controls. The 

following boilers, all with capacities greater than or equal to 1 mmBtu/hr and less than 5 

mmBtu/hr, are subject to the following NOx emission limits:

 

Permit 

Number 

NOx Rule Limit 

(lb/mmBtu) 

NOx Limit 

(lb/mmBtu) 

VOC Limit 

(lb/mmBtu) 

3255 n/a 0.1 0.006

3256 n/a 0.1 0.006

6440 n/a 0.1 0.006

10303 n/a 0.1 0.006

10304 n/a 0.1 0.006

10305 n/a 0.1 0.006

10306 n/a 0.1 0.006

10307 n/a 0.1 0.006

10308 n/a 0.1 0.006

10309 n/a 0.1 0.006

10310 n/a 0.1 0.006

10314 n/a 0.1 0.006

10315 n/a 0.1 0.006

10317 n/a 0.1 0.006

10319 n/a 0.1 0.006

10321 n/a 0.1 0.006

10322 n/a 0.1 0.006

10326 n/a 0.164 0.007

10327 n/a 0.164 0.007
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 75 

Permit 

Number 

NOx Rule Limit 

(lb/mmBtu) 

NOx Limit 

(lb/mmBtu) 

VOC Limit 

(lb/mmBtu) 

10330 n/a 0.164 0.007

10331 n/a 0.164 0.007

10332 n/a 0.1 0.006

10333 n/a 0.1 0.006

10334 n/a 0.164 0.007

10337 n/a 0.1 0.006

10339 n/a 0.1 0.006

10341 n/a 0.164 0.007

10342 n/a 0.164 0.007

10353 n/a 0.1 0.006

10355 n/a 0.164 0.007

10356 n/a 0.164 0.007

10358 n/a 0.1 0.006

10361 n/a 0.1 0.006

12918 n/a 0.1 0.006

12933 n/a 0.164 0.006

13556 n/a 0.1 0.006

13558 n/a 0.1 0.006

14603 n/a 0.0364 0.005

16049 n/a 0.1 0.006

12357 0.036 0.036 0.003

12358 0.036 0.036 0.003

12363 0.036 0.036 0.004

12364 0.036 0.036 0.004

12366 0.036 0.036 0.004

12367 0.036 0.036 0.004

12368 n/a 0.093 0.004

12369 n/a 0.093 0.004

12370 n/a 0.093 0.004

12376 0.036 0.036 0.004

12377 0.036 0.036 0.005

12378 0.036 0.036 0.004

12935 0.036 0.036 0.005

13560 0.036 0.036 0.006

13561 0.036 0.036 0.006

13562 0.036 0.036 0.006

14064 0.051 0.051 0.002

14611 0.051 0.051 0.001

15436 0.036 0.036 0.005

18053 0.036 0.036 0.006

Autoclave: The autoclave includes a 1.8 mmBtu/hr natural gas fired burner, and is used to 

sterilize products. The burner is not equipped with any controls, and is not subject to any 

rule based emissions limits. The burner is permitted to the following emission limits: 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 76 

Permit 

Number 

NOx Limit 

(lb/mmBtu) 

VOC Limit 

(lb/mmBtu) 

Annual NOx 

Emission 

(lb/yr) 

Annual VOC 

Emissions 

(lb/yr) 

13563 0.1 0.006 1592 88 

Space Heaters: The space heaters are used to heat indoor spaces, and are fired on 

natural gas. The space heaters are not equipped with any controls, and are not subject to 

any rule based emissions limits. Permit 12127 includes 36 units rated at 3.6 mmBtu/hr total 

for all units. Permit 13660 includes 24 units rated at 3 mmBtu/hr total for all units. The 

space heaters are permitted to the following emission limits: 

Permit 

Number 

NOx Limit 

(lb/mmBtu) 

VOC Limit 

(lb/mmBtu) 

Annual NOx 

Emission 

(lb/yr) 

Annual VOC 

Emissions 

(lb/yr) 

12127 0.1 0.006 3180 176 

13660 0.094 0.011 1000 116 

Rocket Testing Stands: The rocket testing stands are used to test rocket engines, and 

generate NOx and VOC emissions. The testing stands are not subject to any rule based 

emissions limits or permit emission limits. Some of the testing stands are equipped with the 

controls for pollutants other than VOC or NOx.

Aerospace Coating Operations: The aerospace coating operations generate VOC 

emissions. The coating operations utilize coatings that comply with the VOC content limits 

contained in Rule 456. Some of the coating operations are further limited to the following 

permit emission limits:

Permit 

Number 

VOC Emission 

Limit 

150 -- 

153 40 lb/day 

5811 40 lb/day 

6893 39.7 lb/day 

6981 39.7 lb/day 

7497 -- 

8217 -- 

8444 -- 

15602 10 lb/day 

17204 39.7 lb/day 

17205 39.7 lb/day 

17830 9.7 lb/day 

RDX Drying Facilities: The RDX (cyclotrimethylenetrinitramine) drying rooms generate 

VOC emissions from the drying of the RDX. The rooms are equipped with condensers for 

VOC control. The drying rooms are permitted to the following emission limits:
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 77 

Permit 

Number 

VOC Emission 

Limit 

7779 150 lb/day 

7780 150 lb/day 

Cold Cleaning Operations: The cold cleaning operations are used to degrease parts and 

generate VOC emissions from the solvents used. The cold cleaning operations both employ 

water covers for VOC control, and are subject to the equipment requirements of Rule 454, 

Degreasing Operations.

Bowl Cleaning Operations: The bowl cleaning operations are used to clean rocket fuel 

mixing bowls, and generate VOC emissions from the cleaning solvents. The cleaning 

operations comply with Rule 456, which requires that the solvent either contains ≤ 200 g/l of 

VOC or has a VOC composite vapor pressure ≤ 45 mmHg at 68 °F. 

Liquid Waste Volume Reduction Operation: The liquid waste volume reduction operation 

utilizes an evaporative tower, and generates VOC emissions from the material contained in 

the liquid being reduced. The reduction operation is not subject to any rule based emissions 

limits, and is permitted to the following emissions limit. 

Permit 

Number 

VOC Emission 

Limit 

Annual VOC 

Emissions 

18118 105 lb/qtr 420 lb/yr 

Gasoline Dispensing Facility: The gasoline dispensing facility generates VOC emissions. 

The dispensing operation is equipped with vapor control equipment for VOC control as required 

by Rule 448 and 449. 

RACT Discussion

The equipment at Aerojet is subject to the following rules: 

Source Category Applicable Rules SIP Status 

IC Engines 412 Approved 4/30/96 

Boilers 411 Submitted 1/9/97 

Autoclave n/a 

Space Heaters n/a 

Rocket Testing Stands n/a 

Aerospace Coating Operations (NESHAP) 456 Approved 11/9/98 

Aerospace Coating Operations (Non-NESHAP) 456 Approved 11/9/98 

RDX Drying Facilities n/a 

Cold Cleaning Operations 454 Approved 4/2/99 

Bowl Cleaning Operations 456 Approved 11/9/98 

Liquid Waste Volume Reduction Operation n/a 

Gasoline Dispensing Facility 449 Approved 3/24/03 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 78 

The IC engines are subject to Rule 412 – Stationary Internal Combustion Engines Located at 

Major Stationary Sources of NOx, which has been determined to satisfy the RACT requirement 

for this source category. 

The boilers are subject to Rule 411 – NOx from Boilers, Process Heaters, and Steam 

Generators, which has been submitted to EPA for approval. Boilers between 1 mmBtu/hr and 5 

mmBtu/hr will be required to meet more stringent emission limits under the recently amended 

Rule 411 in a phase-in from 2007 to 2009. 

The aerospace coating operations and bowl cleaning are subject to Rule 456 – Aerospace 

Assembly and Component Coating Operations, which has been determined to satisfy the RACT 

requirement for this source category. 

The cold cleaning operations are subject to Rule 454 – Degreasing Operations, which has been 

determined to satisfy the RACT requirement for this source category. 

The gasoline dispensing facility is subject to Rule 449 – Transfer of Gasoline into Vehicle Fuel 

Tanks, which has been determined to satisfy the RACT requirement for this source category. 

There is no EPA guidance on RACT that is applicable to the rocket test stands. There are no 

New Source Performance Standards (NSPS) or District rules that apply to the test stands. 

Control of emission from rocket test stands would require enclosures to capture the rapid 

release of rocket exhaust, which is not technically feasible for reasons of safety. 

There is no EPA guidance on RACT that is applicable to the small natural gas combustors, 

used in the autoclave and space heaters. There are no New Source Performance Standards 

(NSPS) or District rules that apply to small natural gas combustors. In the recent amendments 

to Rule 411, the cost effectiveness of retrofit controls on boilers rated at 1 mmBtu/hr was 

estimated to be $55,000/ton of NOx reduced, which far exceeds what could be considered 

RACT. 

There is no EPA guidance on RACT that is applicable to the liquid waste reduction. There are 

no New Source Performance Standards (NSPS) or District rules that apply to the reduction 

system. While the permitted emissions are 420 lb/yr, the actual emissions are below 54 lb/yr. 

Because the VOC content of the wastewater stream is very low (about 20 ppmw), there are no 

cost effective controls that can be applied to this process. In addition, the daily emissions are 

well below the 15 lb/day cut-off level for RACT recommended in EPA’s “Bluebook” (Issues 

Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations, May 25, 1988, revised 

January 11, 1990). 

EPA guidance for the RDX dryers is contained in the 1994 ACT for batch processes, EPA453/R-93-017. The model rule included with the ACT exempts batch processes when the 

aggregate emissions from the batch train are less than 10,000 lb/yr. Recent operating records 

show that the RDX dryers are used infrequently. In 2004, no RDX drying occurred. In 2005, 

one batch of RDX was dried, and a total of 255 pounds of VOC were emitted over the 19-day 

drying period. Because the annual emissions are significantly less than the 10,000 lb/yr cut off 

recommended in the ACT document, no further controls on this operation should be required to 

meet RACT. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 79 

Conclusion

The RACT requirements have been satisfied for the IC engines, boilers, aerospace coating 

operations, bowl cleaning, cold cleaning operations, and gasoline dispensing operations 

because these units are subject to SIP-approved rules that have been determined to satisfy 

RACT. 

Small natural gas combustion units, rocket test stands, and the liquid waste volume reduction 

operation are not covered by a CTG or District rule. These units either have no cost-effective 

controls available, or have minimal emissions. 

Annual emissions from the RDX dryers are below EPA’s ACT guidance for RACT control of 

batch processes. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 80 

Major Source: Campbell Soup Supply Co. 

Potential to Emit

VOC: 5.2 ton/yr (non-major) 

NOx: 62 tons/yr (major) 

Facility Description

The Campbell Soup Supply Company is a food processing facility that produces canned fruits 

and juices including tomato juices, tomato sauces, and soups. The plant contains five permitted 

emission units: 

• Three natural gas-fired boilers, Cleaver Brooks model DLDH94, rated at 100 mmBtu/hr 

input each. These boilers can also fire on backup diesel fuel. 

• One natural gas-fired boiler, Cleaver Brooks model CA28, rated at 139 mmBtu/hr input. 

This boiler can also fire on backup diesel fuel. 

• One 136-horsepower, emergency standby diesel engine, Cummins model V-378-F2, 

driving an emergency water pump for fire control. 

Air Pollution Controls and Emission Limits

This facility is a major source of NOx. Emissions of NOx are produced from fuel combustion in 

the four boilers and the emergency standby engine. The controls discussed below are subject to 

federally enforceable permit conditions under Title V Permit No. 2005-03-01. 

The four boilers are subject to NOx emission limits of 30 ppmv @ 3% O2 when firing natural gas 

and 150 ppmv @ 3% O2 when firing diesel fuel. The boiler can fire on diesel fuel only when 

natural gas is unavailable, and each boiler is limited to 168 hours per calendar year (including 

up to 48 hours per year for equipment and emissions testing) of operation on diesel fuel. 

 

The emergency standby engine is limited to 40 hours per year of operation for maintenance 

purposes and 200 hours per year for operation for all operation (maintenance and emergency). 

RACT Discussion

The four boilers are subject to Rule 411 – NOx from Boiler, Process Heaters and Steam 

Generators, which has been determined to satisfy the RACT requirement for this source 

category. The applicable NOx emission limit in Rule 411 is 30 ppmv @ 3% O2 when firing on 

natural gas. When firing on diesel fuel, Rule 411 limits NOx emissions to 150 ppmv @ 3% O2, 

provided that each boiler is limited to 168 hours per calendar year (including up to 48 hours per 

year for equipment and emissions testing) of operation on diesel fuel. 

The emergency standby engine is subject to Rule 412 – Stationary Internal Combustion 

Engines at Major Stationary Sources of NOx, which has been determined to satisfy the RACT 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 81 

requirement for this source category. However, emergency standby engines are exempt from 

the emission limits of Rule 412 as long as they are operated no more 100 hours per year for 

maintenance purposes. There is no guidance on RACT emission limits that is applicable to 

emergency standby engines, as such controls would not be cost effective. 

Conclusion

The RACT requirements have been satisfied for the boilers and the emergency standby engine 

because these units are subject to SIP-approved rules that have been determined to satisfy 

RACT. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 82 

Major Source: Carson Cogeneration Project 

Potential to Emit

VOC: 18.3 ton/yr (non-major) 

NOx: 53.4 tons/yr (major) 

Facility Description

The Carson Cogeneration Project is a combined cycle, cogeneration power plant with an 

electrical generating capacity of 171 MW. The facility also supplies up to 90,000 lb/hr of steam 

to a nearby chemical plant. The plant consists of the following components: 

• One combined cycle gas turbine, General Electric model LM6000, rated at 42 MW (450 

mmBtu/hr input), and fired with a combination of natural gas and digester gas. 

• One heat recovery steam generator, incorporating a 99.9 mmBtu/hr duct burner, to 

produce steam from the hot turbine exhaust gas. 

• One 17 MW steam turbine. 

• One simple cycle peaking gas turbine, General Electric model LM6000, rated at 42 MW 

(450 mmBtu/hr input), and fired with a combination of natural gas and digester gas. 

• One 830-horsepower, emergency standby diesel engine, Detroit Diesel model 12V92TA, driving an emergency electrical generator. 

• One cooling tower designed to circulate 22,000 gal/min of water. 

Air Pollution Controls and Emission Limits

This facility is a major source of NOx. Emissions of NOx are produced from combustion of 

natural gas and digester gas in the two gas turbines and the duct burners, and from combustion 

of diesel fuel in the emergency standby engine. 

The two gas turbines are equipped with selective catalytic reduction (SCR) to control NOx 

emissions to a permit limit of 5 ppmv @ 15% O2. The duct burners are upstream of the SCR 

system, such that NOx emissions from the duct burners are also controlled to 5 ppmv @15% 

O2. 

The emergency standby engine applies a 4° injection timing retard in order to reduce NOx 

emissions. This engine is also limited to 30 hours per year of operation for maintenance purposes 

and 200 hours per year for operation for all operation (maintenance and emergency). 

RACT Discussion

The gas turbines are subject to Rule 413 – Stationary Gas Turbines, which has been 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 83 

determined to satisfy the RACT requirement for this source category. The applicable NOx 

emission limit in Rule 413 is 9 ppmv @ 15% O2. 

The emergency standby engine is subject to Rule 412 – Stationary Internal Combustion 

Engines at Major Stationary Sources of NOx, which has been determined to satisfy the RACT 

requirement for this source category. However, emergency standby engines are exempt from 

the emission limits of Rule 412 as long as they are operated no more 100 hours per year for 

maintenance purposes. There is no guidance on RACT emission limits that is applicable to 

emergency standby engines, as such controls would not be cost effective. 

 

There is no EPA guidance on RACT that is applicable to the duct burners. There are, however, 

two New Source Performance Standards (NSPS) that apply to duct burners in combined cycle 

systems: Subparts Da and Db of 40 CFR Part 60. In each of these subparts, the NOx standard 

for duct burners is 0.2 lb/mmBtu, which is equivalent to approximately 55 ppmv @15% O2. 

The duct burners fire into the hot turbine exhaust, and their emissions are therefore combined 

with the emissions from the turbines upstream of the emission controls. It is not feasible to 

operate the duct burners without operating the turbines. Therefore, the emissions from the duct 

burners are also subject to the NOx limit of Rule 413, 9 ppmv @ 15% O2. This level of control 

satisfies the requirements of RACT for this source type. 

Conclusion

The RACT requirements have been satisfied for the gas turbines, duct burners, and the 

emergency standby engine because these units are subject to SIP-approved rules that have 

been determined to satisfy RACT. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 84 

Major Source: Chevron 

Potential to Emit

VOC: >50 ton/yr (major) 

NOx: 0 tons/yr (non-major) 

Facility Description

The Chevron Sacramento Terminal is a bulk gasoline terminal that receives, stores and 

distributes diesel fuel, jet fuel and gasoline in the Sacramento area. The Chevron Sacramento 

Terminal also supplies these products to a large area of northern California. A pipeline from the 

Chevron Refinery in Richmond, California supplies the Sacramento terminal's storage tanks. 

Chevron is a major supplier of jet fuel in the Sacramento area, with fuel storage facilities at both 

Sacramento Metropolitan and Sacramento Executive airports. The Sacramento terminal 

supplies jet fuel to the two airports. 

The majority of fuel products are received via a pipeline from the Chevron Richmond refinery 

and pumped into large storage tanks. The Techroline and ethanol additives for gasoline are 

received by tank truck and are also pumped into large storage tanks. From the storage tanks 

the fuel is loaded into cargo tank trucks at a loading rack equipped with vapor collection 

equipment vented to an absorption/carbon adsorption vapor recovery system. Vapors from the 

loading racks at the nearby Phillips terminal are also routed to Chevron's vapor recovery unit. 

The plant contains seven permitted emission units: 

• A 1,772,736 gallon, internal floating roof storage tank, storing organic liquid with a vapor 

pressure less than 11 psi. 

• A 1,030,092 gallon, internal floating roof storage tank, storing organic liquid with a vapor 

pressure less than 11 psi. 

• A 54,894 gallon, fixed roof storage tank, vented to a vapor recovery system, and storing 

organic liquid with a vapor pressure less than 11 psi. 

• A 2,023,702 gallon, internal floating roof storage tank, storing organic liquid with a vapor 

pressure less than 11 psi. 

• A 2,028,658 gallon, internal floating roof storage tank, storing organic liquid with a vapor 

pressure less than 11 psi. 

• An organic liquid loading rack, consisting of 15 gasoline loading spots with three pumps, 

5 diesel loading spots with one pump, and 3 Jet A loading spots with one pump, all 

vented to a vapor recovery system. 

• An absorption/carbon adsorption vapor recovery system, John Zink model AA-2475-12-

10, with a capacity of 12,700 gallons per minute. 

Air Pollution Controls and Emission Limits

This facility is a major source of VOC. Emissions of VOC are produced from working and 

standing losses from the storage tanks, the loading rack, and the vapor recovery system. The 

controls discussed below are subject to federally enforceable permit conditions under Title V 

Permit No. 2002-06-01B. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 85 

The storage tanks are subject to Rule 446, Storage of Petroleum Products. Each of the tanks 

has a capacity greater than 40,000 gallons and stores organic liquids with a vapor pressure 

greater than 1.5 psi. The rule requires such tanks to be equipped with floating roofs or be 

vented to a control device with an overall efficiency of at least 95% by weight. Four of the tanks 

have internal floating roofs that comply with the rule requirements. The fixed roof tank is vented 

to the absorption/carbon adsorption vapor recovery system that is required to maintain an 

overall efficiency of at least 95% by weight. 

The loading rack is subject to Rule 447, Organic Liquid Loading. The loading rack is limited to 

VOC emissions of 0.08 pounds per 1,000 gallons of organic liquid transferred. This requirement 

is met by venting the loading rack to the absorption/carbon adsorption vapor recovery system. 

RACT Discussion

The VOC emission units at this facility are subject to two District rules that require controls that 

meet or exceed the requirements of RACT: 

• Rule 446, Storage of Petroleum Products 

• Rule 447, Organic Liquid Loading 

There are no sources of VOC that are not controlled under one of these two rules. 

Conclusion

The RACT requirements have been satisfied for the emission units at the Chevron bulk terminal, 

because all VOC emission units are subject to SIP-approved rules that have been determined to 

satisfy RACT. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 86 

Major Source: Cosumnes Power Plant (SMUD) 

Potential to Emit

VOC: 30 ton/yr (non-major) 

NOx: 125.6 tons/yr (major) 

Facility Description

The SMUD Cosumnes Power Plant is a combined cycle power plant with an electrical 

generating capacity of 500 MW. The plant consists of the following components: 

• Two combined cycle, natural gas-fired General Electric model 7FA gas turbines, rated at 

171.2 MW (1,865 mmBtu/hr input) each. 

• Two heat recovery steam generators to produce steam from the hot turbine exhaust gas. 

• One 180 MW steam turbine. 

• Two cooling towers, each designed to circulate 126,000 gal/min of water. 

Air Pollution Controls and Emission Limits

This facility is a major source of NOx. Emissions of NOx are produced from natural gas 

combustion in the two gas turbines. The two gas turbines are equipped with dry low NOx 

combustors and selective catalytic reduction (SCR) to control NOx emissions to a permit limit of 

2 ppmv @ 15% O2. 

RACT Discussion

The gas turbines are subject to Rule 413 – Stationary Gas Turbines, which has been 

determined to satisfy the RACT requirement for this source category. The applicable NOx 

emission limit in Rule 413 is 9 ppmv @ 15% O2. 

The gas turbines are also subject to the less stringent requirements of Title 40 of the Code of 

Federal Regulations, Part 60, Subpart GG – Standards of Performance for Stationary Gas 

Turbines. The applicable NOx limit from this regulation in 94 ppmv @ 15% O2, based on a heat 

input rate of 11.5 kJ/w-hr. 

Conclusion

The RACT requirements have been satisfied for the gas turbines because these units are 

subject to a SIP-approved rule that has been determined to satisfy RACT. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 87 

Major Source: Kiefer Landfill 

Potential to Emit

VOC: 472 ton/yr (major) 

NOx: 108 tons/yr (major) 

Facility Description

The Kiefer Landfill is a municipal solid waste landfill owned and operated by the County of 

Sacramento, Department of Waste Management and Recycling. Decomposing waste within the 

landfill produces landfill gas that contains VOCs. A landfill gas collection system captures the 

landfill gas and sends it to be combusted in a flare or to be used a fuel in one of five internal 

combustion engines, which drive electrical generators designed to produce up to 15 MW of 

electricity. The Kiefer Landfill contains ten permitted emission units: 

• A landfill gas collection system, consisting of perimeter well, interior wells, associated 

piping, and two 125-horsepower blowers (electric). 

• A landfill gas flare, John Zink model ZTOF, with a maximum heat input of 150 mmBtu/hr 

and a maximum gas flow rate of 5,000 scfm. 

• Five landfill gas-fired internal combustion engines, Caterpillar model G3616, each rated 

at 4,230 horsepower. Each engine drives a 3.05-MW electrical generator. 

• A gasoline dispensing facility (GDF), consisting of a 2,500-gallon aboveground storage 

tank and one dispensing nozzle. 

• A trommel screen, Wildcat Manufacturing Co. model 626 Cougar. 

• A 158-horsepower diesel engine, portable (nonroad), Deutz Model BF6L914C, which 

drives the trommel screen. 

• A green waste grinder, Peterson Pacific Corp. model HC5400. 

• A 860-horsepower diesel engine, portable (nonroad), Caterpillar model 3412, which 

drives the green waste grinder. 

• A 99-horsepower diesel engine, portable (nonroad), John Deere model 4045TF270, 

which provides auxiliary power to a street sweeper to operate the vacuum system and 

sweeping brushes. 

Nonroad engines are exempt from RACT requirements because the District is preempted from 

establishing emission standards by Section 209(e) of the federal Clean Air Act. Therefore, 

there will be no further discussion of the nonroad engines. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 88 

Air Pollution Controls and Emission Limits

This facility is a major source of both VOC and NOx. Both of these pollutants are emitted from 

the flare, the five landfill gas-fired engines, and the two diesel engines. VOC is also emitted 

from the landfill gas collection system and the gasoline dispensing facility. The emission limits 

and controls discussed below are subject to federally enforceable permit conditions under Title 

V Permit No. 96-10-03. 

The landfill gas collection system is consists of 59 perimeter wells and 73 interior wells with 

provisions for future expansion. Landfill gas is drawn through the wells and sent either to the 

flare or the five landfill gas-fired IC engines. The landfill gas collections system is subject to a 

permit requirement to maintain the methane concentration at the surface of the landfill to less 

than 500 ppm above background. 

The flare is subject to a permit requirement to maintain at least 98% destruction efficiency for 

VOC, and is subject to an emission limit for NOx of 0.06 lb/mmBtu. 

The five landfill gas-fired IC engines are subject to a NOx emission limit of 30 ppmv @15% O2. 

In addition, the IC engines are required to maintain at least 98% destruction efficiency for VOC. 

The gasoline dispensing facility is equipped with CARB-certified Phase I and Phase II vapor 

recovery systems that reduce VOC emissions by at least 95% by weight. The facility is 

permitted to dispense no more than 30,000 gallons of gasoline per calendar quarter. 

RACT Discussion

The landfill gas collection system and flare are subject to the federal requirements of both New 

Source Performance Standards (NSPS, 40 CFR Part 60, Subpart WWW) and National 

Emission Standards for Hazardous Air Pollutants (NESHAP, 40 CFR Part 63, Subpart AAAA). 

Both of these federal standards require the system to comply with the specific design and 

emission requirements of 40 CFR Sections 60.750 through 60.759. The NSPS and NESHAP 

standards are federally enforceable, and the SMAQMD has been delegated authority by U.S. 

EPA to enforce these standards. The landfill gas collection system is exempt from Rule 485, 

Municipal Landfill Gas, because rule 485 exempts sources that are subject to the NSPS. 

There are no standards within the federal or SMAQMD rules that are applicable to the NOx 

emissions from the flare. This is identified as a RACT deficiency, and will be remedied by 

submitting for inclusion in the SIP the portions of the permit that require a NOx limit of 0.06 

lb/mmBtu for the flare and the associated testing and recordkeeping requirements. 

The five landfill gas-fired engines are subject to the NSPS/NESHAP requirement to maintain a 

destruction efficiency of at least 98% for VOC. The engines are also subject to Rule 412 – 

Stationary Internal Combustion Engines Located at Major Stationary Sources of NOx. The 

applicable emission limits in Rule 412 are 65 ppmv NOx and 750 ppmv VOC @15% O2 (spark 

ignited, lean burn engines). 

The gasoline dispensing facility is subject to Rule 448, Gasoline Transfer into Stationary 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 89 

Storage Containers, and Rule 449, Transfer of Gasoline into Vehicle Fuel Tanks. These rules 

require CARB-certified Phase I and Phase II vapor recovery systems that reduce VOC 

emissions by at least 95% by weight. 

Conclusion

The RACT requirements have been satisfied for the emission units at the Kiefer landfill, with the 

exception of NOx emissions from the flare, because these units are subject to SIP-approved 

rules that have been determined to satisfy RACT, or federal NSPS and NESHAP requirements 

that have been determined to satisfy RACT. 

The RACT deficiency noted for NOx emissions from the flare will be remedied by submitting for 

inclusion in the SIP the portions of the permit that require a NOx limit of 0.06 lb/mmBtu for the 

flare and the associated testing and recordkeeping requirements. This NOx emission limit for 

the flare is equivalent to the most stringent limits in effect in other California districts. Both San 

Luis Obispo County APCD Rule 426 and Ventura County APCD Rule 74.17.1 require enclosed 

flares to meet a NOx limit of 0.06 lb/mmBtu. This emission limit is considered to meet or exceed 

the requirements of RACT. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 90 

Major Source: Procter & Gamble 

Potential to Emit

VOC: 444.9 ton/yr (major) 

NOx: 11.6 tons/yr (non-major) 

Facility Description

The Procter & Gamble Manufacturing Company (Procter & Gamble) Sacramento site is a 

complex industrial facility with many emission units and fugitive sources. It processes oils, such 

as coconut and palm kernel oil, to make a number of products. Products include fatty alcohols, 

glycerine, fatty acids, and fatty esters. Incoming oil is converted into methyl esters and 

glycerine. The glycerine is processed to remove some of the residual fatty materials and water. 

Crude esters are sent to distillation where methyl ester is separated into various fractions. 

Distilled esters are hydrogenated into fatty alcohol. The resulting crude alcohol is distilled and 

separated into various fractions. Another process in the plant converts fatty esters into fatty 

acids. This involves both reaction and purification steps. The plant sometimes processes 

intermediates shipped to and from other plants. The site contains emission sources generated 

from the oleochemical process as well as miscellaneous support equipment. 

Procter & Gamble uses two centrifuge systems (each consisting of a centrifuge, slurry tank and 

effluent tank) to separate catalyst from fatty alcohol. Air, methanol vapor, and small amounts of 

entrained fatty alcohol are pulled from each tank under a slight vacuum, combined in a single 

vent header, and drawn through the methanol absorber. The methanol absorber consists of a 

packed-column unit where the methanol is absorbed by temperature controlled water. The 

resulting alcohol/methanol/water mixture is pumped to an oil/water separator to recover the fatty 

alcohol. The methanol/water mixture is then recovered back into the manufacturing process. 

The Procter & Gamble facility contains the following permitted emission units: 

• A storage tank farm, consisting of 50 fixed-roof, organic liquid storage tanks ranging in 

capacity from 3,087 gallons to 1,115,685 gallons, and loading racks for tanker truck and 

railcars. 

• A physically refined oil process, consisting of: 4 fixed-roof, organic liquid storage tanks 

ranging in capacity from 375 gallons to 42,346 gallons; activated carbon and bleaching 

earth filter vessels; mixing tanks; and condensers. 

• A fatty acids manufacturing process, consisting of: 17 fixed-roof, organic liquid storage 

tanks ranging in capacity from 3,672 gallons to 20,383 gallons; reactor vessels; stills; 

strippers; and condensers. 

• A methyl ester/glycerine manufacturing process, consisting of: 44 fixed-roof, organic 

liquid storage tanks ranging in capacity from 185 gallons to 455,557 gallons; reactor 

vessels; centrifuges; absorbers; and condensers. 

• A fatty alcohol manufacturing process, consisting of: 42 fixed-roof, organic liquid storage 

tanks ranging in capacity from 288 gallons to 41,018 gallons; reactor vessels; stills; 

strippers; absorbers; and condensers. 

• A methanol absorber unit. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 91 

• A thermal fluid heater, Foster Wheeler model AV-5125-A, 32 mmBtu/hr, fired on natural 

gas. 

• A hydrogen heater, Foster Wheeler, 4.4 mmBtu/hr, fired on natural gas. 

• A methanol knockout drum. 

• A fire pit that sprays a water mist into vented flammable gases. 

• Two seal vent tanks. 

• Two 65-gallon, packed bed methanol scrubbers. 

• A physically refined oil process heater, GTS Energy model NUK600, 3.75 mmBtu/hr, 

fired on natural gas. 

• A 209-hp standby diesel engine, Detroit Diesel model DDFP-04AT, used for fire 

pumping. 

Air Pollution Controls and Emission Limits

This facility is a major source of VOC, which is emitted from organic liquid storage tanks, 

loading racks, reactors, stills, strippers, condensers, and process vents. In addition, fugitive 

VOC emissions result from the wastewater collection system and equipment leaks. Because 

the facility is not a major source of NOx, emissions of NOx are not discussed further. The 

emission limits and controls discussed below are subject to federally enforceable permit 

conditions under Title V Permit No. 2004-02-01. 

Organic liquid storage tanks are subject to the requirements of Rule 446, Storage of Petroleum 

Products, and Rule 464, Organic Chemical Manufacturing Operations. Rule 446 requires any 

organic liquid storage tanks with a capacity greater than 40,000 gallons and storing liquids with 

a vapor pressure greater than 1.5 psi to be equipped with VOC control devices such as internal 

or external floating roofs or other vapor recovery system with a recovery efficiency of at least 

95% by weight. Rule 464 requires all storage tanks with a capacities between 55 gallons and 

40,000 gallons and storing liquids with a vapor pressure greater than 1.5 psi to be equipped 

with pressure/vacuum valve. In addition, Rule 464 requires process tanks containing organic 

liquid with a vapor pressure greater than 0.5 psi and with uncontrolled emission greater than 15 

pounds per day of VOC to be vented to a VOC capture and control system with a combined 

efficiency of at least 85% by weight and a control efficiency of at least 90% by weight. Process 

equipment in this category is also subject to the Miscellaneous Organic NESHAP (40 CFR Part 

63, Subpart FFFF). 

Rule 464 requires all distillation columns, crystallizers, evaporators, and centrifuges which emit 

more than 15 pounds per day of uncontrolled VOC to be vented to a VOC capture and control 

system with a combined efficiency of at least 85% by weight and a control efficiency of at least 

90% by weight. Separation devices containing organic liquids with a vapor pressure greater 

than or equal to 0.5 psi and with uncontrolled emission greater than 15 pounds per day of VOC 

must be vented to a VOC capture and control system with a combined efficiency of at least 85% 

by weight and a control efficiency of at least 90% by weight. Dryers and other production 

equipment with uncontrolled VOC emissions of 330 pounds per day or more of VOC must be 

vented to a VOC capture and control system with a combined efficiency of at least 85% by 

weight and a control efficiency of at least 90% by weight. Process equipment in this category is 

also subject to the Miscellaneous Organic NESHAP (40 CFR Part 63, Subpart FFFF). 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 92 

The wastewater collection system is also subject to Rule 464. All wastewater collection and 

transport devices containing wastewater with a VOC concentration of 500 ppm by weight or 

greater and with a flow rate of 1 liter per minute or greater, or with a VOC concentration of 

10,000 ppm by weight or greater at any flow rate, are equipped with solid, vapor-tight, full 

contact fixed covers. Wastewater operations are also subject to the Miscellaneous Organic 

NESHAP (40 CFR Part 63, Subpart FFFF). 

Loading racks are subject to requirements under Rule 464. Loading operations involving 

transfer of organic liquids with a vapor pressure greater than 0.5 psi must be equipped with a 

vapor balance system or a VOC capture and control system with a combined efficiency of at 

least 85% by weight and a control efficiency of at least 90% by weight. Process equipment in 

this category is also subject to the Miscellaneous Organic NESHAP (40 CFR Part 63, Subpart 

FFFF). 

Fugitive emissions from equipment leaks are subject to the requirements of Rule 443, Leaks 

from Synthetic Organic Chemical and Polymer Manufacturing. Affected components include 

flanges, valves, pumps, compressors, open-ended lines, sampling connections, and pressure 

relief devices. Rule 443 requires an quarterly inspection and repair program to minimize the 

emissions of VOC from leaking components. A leak is defined as a liquid drip of greater than 3 

drops per minute; a reading of 10,000 ppm or greater above background on a portable 

hydrocarbon detection instrument; or a visible mist. Fugitive emissions are also subject to the 

Miscellaneous Organic NESHAP (40 CFR Part 63, Subpart FFFF). 

RACT Discussion

The VOC emission units at Procter & Gamble are subject to three District rules and a NESHAP 

that, in combination, require controls that meet or exceed the requirements of RACT: 

• Rule 443, Leaks from Synthetic Organic Chemical and Polymer Manufacturing 

• Rule 446, Storage of Petroleum Products 

• Rule 464, Organic Chemical Manufacturing Operations 

• Miscellaneous Organic NESHAP (40 CFR Part 63, Subpart FFFF) 

The District has been delegated enforcement authority for the NESHAP. Full compliance is 

required by May 10, 2008. 

There are no District rules that limit the emissions of VOC from the gas-fired combustion 

equipment. However, Staff is not aware of any cost effective controls that can be applied to 

VOC emissions from the combustion of natural gas, nor is there any federal guidance for such 

controls. The combustion process itself is inherently efficient in destroying VOC. 

Conclusion

The RACT requirements have been satisfied for the emission units at Procter & Gamble, 

because all VOC emission units are subject to SIP-approved rules and/or the NESHAP that 

have been determined to satisfy RACT. There are no applicable RACT controls for VOC 

emissions from the gas-fired combustion equipment. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 93 

Major Source: Sacramento Cogeneration Authority 

Potential to Emit

VOC: 16.8 ton/yr (non-major) 

NOx: 99.4 tons/yr (major) 

Facility Description

The Sacramento Cogeneration Authority is a combined cycle, cogeneration power plant with an 

electrical generating capacity of 171 MW. The facility also supplies up to 90,000 lb/hr of steam 

to a nearby chemical plant. The plant consists of the following components: 

• Two combined cycle, natural gas-fired General Electric model LM6000 gas turbines, 

rated at 42 MW (450 mmBtu/hr input) each. 

• Two heat recovery steam generators, each incorporating an 83.2 mmBtu/hr duct burner, 

to produce steam from the hot turbine exhaust gas. 

• One 45 MW steam turbine. 

• One simple cycle, natural gas-fired General Electric model LM6000 gas turbine, rated at 

42 MW (450 mmBtu/hr input). 

• One 108.7 mmBtu/hr auxiliary boiler to provide steam when the combined cycle turbines 

are not operating. 

• One cooling tower designed to circulate 48,850 gal/min of water. 

Air Pollution Controls and Emission Limits

This facility is a major source of NOx. Emissions of NOx are produced from natural gas 

combustion in the three gas turbines, the duct burners, and the auxiliary boiler. The controls 

discussed below are subject to federally enforceable permit conditions under Title V Permit No. 

97-12-01. 

The three gas turbines are equipped with water injection and selective catalytic reduction (SCR) 

to control NOx emissions to a permit limit of 5 ppmv @ 15% O2. The duct burners are upstream 

of the SCR systems, such that NOx emissions from the duct burners are also controlled to 5 

ppmv @15% O2. 

The auxiliary boiler is equipped with ultra low NOx rapid mix burners to control NOx emissions 

to a permit limit of 9 ppmv @ 3% O2. However, when the boiler is operating at less than 25% of 

full load, the unit is permitted to emit 30 ppmv @ 3% O2 due to technological limitations of the 

burner at low loads. 

RACT Discussion
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 94 

The gas turbines are subject to Rule 413 – Stationary Gas Turbines, which has been 

determined to satisfy the RACT requirement for this source category. The applicable NOx 

emission limit in Rule 413 is 9 ppmv @ 15% O2. 

The gas turbines are also subject to the less stringent requirements of Title 40 of the Code of 

Federal Regulations, Part 60, Subpart GG – Standards of Performance for Stationary Gas 

Turbines. The applicable NOx limit from this regulation in 96 ppmv @ 15% O2, based on a heat 

input rate of 11.3 kJ/w-hr. 

The auxiliary boiler is subject to Rule 411 – NOx from Boilers, Process Heaters, and Steam 

Generators, which has been determined to satisfy the RACT requirement for this source 

category. The applicable NOx emission limit in Rule 411 is 30 ppmv @ 3% O2. 

There is no EPA guidance on RACT that is applicable to the duct burners. There are, however, 

two New Source Performance Standards (NSPS) that apply to duct burners in combined cycle 

systems: Subparts Da and Db of 40 CFR Part 60. In each of these subparts, the NOx standard 

for duct burners is 0.2 lb/mmBtu, which is equivalent to approximately 55 ppmv @15% O2. 

The duct burners fire into the hot turbine exhaust, and their emissions are therefore combined 

with the emissions from the turbines upstream of the emission controls. It is not feasible to 

operate the duct burners without operating the turbines. Therefore, the emissions from the duct 

burners are also subject to the NOx limit of Rule 413, 9 ppmv @ 15% O2. This level of control 

satisfies the requirements of RACT for this source type. 

Conclusion

The RACT requirements have been satisfied for the gas turbines, duct burners, and the auxiliary 

boiler because these units are subject to SIP-approved rules that have been determined to 

satisfy RACT. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 95 

Major Source: Santa Fe Pacific Pipeline 

Potential to Emit

VOC: 90.1 tons/yr (major) 

NOx: 8.1 tons/yr (non-major) 

Facility Description

The Santa Fe Pacific Pipeline (SFPP) bulk terminal was constructed and placed into service in 

1957. The terminal receives refined fuels via SFPP's 10" and 12" pipelines. These fuels are 

held temporarily in storage tanks and then loaded into tank trucks to resupply surrounding retail 

gas stations and public/private businesses. Additional product can be transferred by 3" and 4" 

pipelines to the properties that were formally McClellan Air Force Base and Mather Air Force 

Base but are now non-military airports. The petroleum products stored and dispensed at the 

terminal are not owned by SFPP. SFPP only provides storage tank capacity and tank truck 

loading equipment for the amounts and types of petroleum products requested by the companies 

that use its services. 

The plant contains 15 permitted emission units: 

• A 1,985,424 gallon, external floating roof storage tank, storing organic liquid with a vapor 

pressure less than 11 psi. 

• A 1,985,298 gallon, external floating roof storage tank, storing organic liquid with a vapor 

pressure less than 11 psi. 

• A 1,978,326 gallon, external floating roof storage tank, storing organic liquid with a vapor 

pressure less than 11 psi. 

• A 1,986,390 gallon, external floating roof storage tank, storing organic liquid with a vapor 

pressure less than 11 psi. 

• A 547,092 gallon, external floating roof storage tank, storing organic liquid with a vapor 

pressure less than 11 psi. 

• A 1,079,862 gallon, external floating roof storage tank, storing organic liquid with a vapor 

pressure less than 11 psi. 

• A 193,284 gallon, internal floating roof storage tank, storing organic liquid with a vapor 

pressure less than 11 psi. 

• A 809,802 gallon, internal floating roof storage tank, storing organic liquid with a vapor 

pressure less than 11 psi. 

• A 1,515,318 gallon, internal floating roof storage tank, storing organic liquid with a vapor 

pressure less than 11 psi. 

• A 1,216,992 gallon, internal floating roof storage tank, storing organic liquid with a vapor 

pressure less than 11 psi. 

• A 808,710 gallon, internal floating roof storage tank, storing organic liquid with a vapor 

pressure less than 11 psi. 

• A loading rack consisting of 2 gasoline loading spots with 4 pumps and 2 diesel loading 

spots with 2 pumps, and vented to a vapor recovery system. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 96 

• A loading rack consisting of 2 gasoline loading spots with 3 pumps, 2 diesel loading 

spots with 1 pump, and 1 transmix loading spot with 1 pump, and vented to a vapor 

recovery system. 

• A loading rack consisting of 2 gasoline loading spots with 2 pumps, 2 diesel loading 

spots with 2 pumps, and 1 Jet A loading spot with 1 pump, and vented to a vapor 

recovery system. 

• A vapor collection refrigeration/thermal oxidizer system with a capacity of 800 cubic feet 

per minute, consisting of a refrigerated condenser, Edwards model DEC-3600, and a 

thermal oxidizer, John Zink model S76300. 

Air Pollution Controls and Emission Limits

This facility is a major source of VOC. Emissions of VOC are produced from working and 

standing losses from the storage tanks, the loading racks, and the vapor recovery system. The 

controls discussed below are subject to federally enforceable permit conditions under Title V 

Permit No. 2002-04-02. 

The storage tanks are subject to Rule 446, Storage of Petroleum Products. Each of the tanks 

has a capacity greater than 40,000 gallons and stores organic liquids with a vapor pressure 

greater than 1.5 psi. The rule requires such tanks to be equipped with floating roofs or be 

vented to a control device with an overall efficiency of at least 95% by weight. Six of the tanks 

have external floating roofs that comply with the rule requirements. The other five tanks have 

internal floating roof that comply with the rule requirements. 

The loading racks are subject to Rule 447, Organic Liquid Loading. The loading racks are 

limited to VOC emissions of 0.08 pounds per 1,000 gallons of organic liquid transferred. This 

requirement is met by venting the loading racks to the absorption/carbon adsorption vapor 

recovery system. 

RACT Discussion

The VOC emission units at this facility are subject to two District rules that require controls that 

meet or exceed the requirements of RACT: 

• Rule 446, Storage of Petroleum Products 

• Rule 447, Organic Liquid Loading 

There are no sources of VOC that are not controlled under one of these two rules. 

Conclusion

The RACT requirements have been satisfied for the emission units at the SFPP bulk terminal, 

because all VOC emission units are subject to SIP-approved rules that have been determined to 

satisfy RACT. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 97 

Major Source: UC Davis Medical Center 

Potential to Emit

VOC: 29 tons/yr (non-major) 

NOx: 91 tons/yr (major) 

Facility Description

The University of California, Davis (UC Davis) operates the UC Davis Medical Center in 

Sacramento. The UC Davis Medical Center is a health care provider for the community and a 

teaching hospital for the UC Davis School of Medicine. The university established the Medical 

Center in 1973 to support the clinical and research missions of the then new UC Davis School 

of Medicine. Licensed for 528 beds and fully accredited, UC Davis Medical Center is the 

region's dominant Level I comprehensive adult and pediatric trauma center. 

Electrical power for the facility is generated from an onsite co-generation central power plant. 

The electrical generation plant uses a natural gas fueled gas turbine to generate electricity and 

captures the heat emitted by the gas turbine to produce steam for heating and cooling. In 

addition, four large and eight small natural gas fueled boilers provide steam when the gas 

turbine capacity is exceeded or the gas turbine is out of service. Emergency electrical power is 

provided by eight diesel fueled internal combustion engines driving electrical generators. 

Emergency water pumping for fire fighting is provided by one internal combustion engine driving 

a fire pump. 

The facility contains 22 permitted emission units: 

• A gas turbine, General Electric model LM 2500, with an input capacity of 260 mmBtu/hr, 

fired on natural gas. The turbine is equipped with water injection and selective catalytic 

reduction (SCR) for NOx control, and an oxidation catalyst for CO control. 

• Four 34.1 mmBtu/hr boilers, Johnston Boiler Company model PFTA750-4LG-150S, fired 

with natural gas as primary fuel and diesel as a backup fuel. 

• Five 2,876-hp diesel engines, Caterpillar model 3516B DITA SC 140F, driving 

emergency backup electrical generators. 

• Eight 0.4 mmBtu/hr boilers, Bryan model MOD-400S-100-G, fired on natural gas, used 

for hot water heating. 

• A 750-hp diesel engine, Cummins model KTTA19G2, driving an emergency backup 

electrical generator. 

• A 156-hp diesel engine, Caterpillar model FM/ULI/3208 DINA, driving a water pump for 

fire fighting. 

• A 890-hp diesel engine, Caterpillar model 3412, driving an emergency backup electrical 

generator. 

• A 68-hp diesel engine, Cummins model 4B3.9-G, driving an emergency backup 

electrical generator. 

• A gasoline dispensing facility, consisting of two 10,000 gallon underground gasoline 

tanks, one 10,000 gallon underground diesel tank, and 3 dispensing nozzles. The 

dispensing facility is equipped with Phase I and Phase II vapor recovery. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 98 

Air Pollution Controls and Emission Limits

This facility is a major source of NOx. Emissions of NOx are produced the gas turbine, 12 

boilers, and 9 diesel engines. The controls discussed below are subject to federally enforceable 

permit conditions under Title V Permit No. 2005-16-01 

The gas turbine is equipped with water injection and SCR to control NOx emissions to a permit 

limit of 5 ppmv @ 15% O2. 

The four 34.1 mmBtu/hr boilers are equipped with low NOx burners that control NOx emissions 

to a permit limit of 30 ppmv NOx @ 3% O2 when firing on natural gas and 40 ppmv NOx @ 3% 

O2 when firing on diesel fuel. These boilers can fire on diesel fuel only when natural gas is 

unavailable, and each boiler is limited to 168 hours per calendar year (including up to 48 hours 

per year for equipment and emissions testing) of operation on diesel fuel. The eight 0.4 

mmBtu/hr boilers have permitted emissions of 100 pounds of NOx per million cubic feet of 

natural gas. 

Four of the 2,876-hp emergency standby diesel engines are limited to 50 hours per year of 

operation for maintenance purposes and 750 hours per year for operation for all operation 

(maintenance and emergency). The other 2,876-hp emergency standby diesel engine is limited 

to 50 hours per year of operation for maintenance purposes and 200 hours per year for operation 

for all operation. 

The 750-hp, 156-hp, 890-hp, and 68-hp emergency standby diesel engines are limited to 40 

hours per year of operation for maintenance purposes and 200 hours per year for operation for all 

operation. 

The gasoline dispensing facility is equipped with CARB-certified Phase I and Phase II vapor 

recovery systems that reduce VOC emissions by at least 95% by weight. The facility is 

permitted to dispense no more than 30,000 gallons of gasoline per calendar quarter. 

RACT Discussion

The gas turbine is subject to Rule 413 – Stationary Gas Turbines, which has been determined 

to satisfy the RACT requirement for this source category. The applicable NOx emission limit in 

Rule 413 is 9 ppmv @ 15% O2. 

The four 34.1 mmBtu/hr boilers are subject to Rule 411 – NOx from Boiler, Process Heaters and 

Steam Generators, which has been determined to satisfy the RACT requirement for this source 

category. The applicable NOx emission limit in Rule 411 is 30 ppmv @ 3% O2 when firing on 

natural gas. When firing on diesel fuel, Rule 411 limits NOx emissions to 150 ppmv @ 3% O2, 

provided that each boiler is limited to 168 hours per calendar year (including up to 48 hours per 

year for equipment and emissions testing) of operation on diesel fuel. 

The eight 0.4 mmBtu/hr boilers are exempt from the requirements of Rule 411 because they 

have input ratings less than 1 mmBtu/hr. The eight boilers have a combined potential to emit 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 99 

(uncontrolled) of less than 8 lb/day. Although, EPA’s “Bluebook” (Issues Relating to VOC 

Regulation Cutpoints, Deficiencies, and Deviations, May 25, 1988, revised January 11, 1990) 

does not address NOx, it does establish a de minimus level for VOC emissions from coating 

operations of 15 lb/day actual emissions. Adapting this guidance for NOx emissions, the eight 

boilers are considered to be a de minimus source of NOx. 

The emergency standby engines are subject to Rule 412 – Stationary Internal Combustion 

Engines at Major Stationary Sources of NOx, which has been determined to satisfy the RACT 

requirement for this source category. However, emergency standby engines are exempt from 

the emission limits of Rule 412 as long as they are operated no more 100 hours per year for 

maintenance purposes. There is no guidance on RACT emission limits that is applicable to 

emergency standby engines, as such controls would not be cost effective. 

The gasoline dispensing facility is subject to Rule 448, Gasoline Transfer into Stationary 

Storage Containers, and Rule 449, Transfer of Gasoline into Vehicle Fuel Tanks. These rules 

require CARB-certified Phase I and Phase II vapor recovery systems that reduce VOC 

emissions by at least 95% by weight. 

Conclusion

The RACT requirements have been satisfied for the emission units at the UC Davis Medical 

Center, because all VOC and NOx emission units are subject to or exempt from SIP-approved 

rules that have been determined to satisfy RACT. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 100 

Appendix D 

Permit to Operate 17359 for the Kiefer Landfill Flare 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 101 

Permit Description

The permit being submitted for inclusion in the SIP is the local District permit for the air pollution 

control landfill gas flare (currently P/O 17359). Permit conditions that have been left blank do 

not pertain to the NOx 0.06 lbs/mmBtu limit on the flare permit. A copy of the permit is attached 

to this document. 

Additional Conditions to be Included in the Permit: 

California Health and Safety Code Section 42301.10 states “In any district that has a permit 

system established pursuant to Section 42300, the air pollution control officer may include, in 

any permit issued to a Title V source, emission limits, standards, and other requirements that 

ensure compliance with all federal Clean Air Act “applicable requirements,” as that term is 

defined in regulations adopted by the Environmental Protection Agency pursuant to Title V, 

including those requirements specified in an applicable implementation plan as defined by 

Section 7602 (q) of Title 42 of the United States Code, and Parts C (42 U.S.C. Sec. 7470 et 

seq.) and D (42 U.S.C. Sec. 7501 et seq.) of Title I of the Clean Air Act. 

42 U.S.C. Section 7602(q) refers to 42 U.S.C. Section 7410 which includes the general SIP 

requirements. The RACT SIP is an update to the General SIP. Pursuant to Health and Safety 

Section 42301.10 the Air Pollution Control officer may include any additional conditions that are 

needed to meet the RACT SIP requirements. 

The following conditions will be added to the permit at its next update: 1) the NOx limit under 

Condition #6 shall remain in effect regardless of the permit expiring or reissuance of the permit; 

2) the emission limit satisfies the RACT requirement; 3) require copies of the source test results 

to be available at the facility for 5 years; and 4) the specific source test method that will be used 

to determine compliance with the NOx limit. 

Specific Conditions to Be Added:

RACT DETERMINATION 

28. This permit incorporates a Reasonably Available Control Technology (RACT) 

determination as required by Title I provisions of the Clean Air Act Amendments. 

29. The expiration date shown on this permit is for state purposes. For Federal 

enforcement purposes the RACT provisions of this permit that are approved by 

U.S. Environmental Protection Agency (EPA) shall remain in effect as part of the 

State Implementation Plan (SIP) until replaced pursuant to 40 CFR 51 and 

approved by the EPA. 

Specific Conditions to be Amended:

The following will be added to existing Condition 16 under the “At all times” column. 

16.F. Records of sources test plans and results to determine compliance with the NOx 

limit in Condition #6 shall be maintained for a minimum of 5 years. 
Staff Report 

RACT SIP Analysis 

September 26, 2006, Page 102 

The following will be added to Condition #27. 

27.F. Compliance with the NOX limit shall be determined using one of the following 

source test methods: 

1) ARB Method 100; 

2) EPA Method 7E; or 

3) Any other method approved by the U.S. Environmental Protection 

Agency, the California Air Resources Board, and the Air Pollution Control 

Officer.