UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

the EPA’s Notice of Proposed Rulemaking

for the

California State Implementation Plan

The EPA’s Evaluation of

Antelope Valley Air Quality Management District, 

2015 8-Hour Reasonably Available Control Technology – State Implementation Plan Analysis 

(2015 RACT SIP Analysis) - Adopted July 21, 2015

“2015 RACT SIP TSD”

Prepared by: James Shears and Stanley Tong

Reviewed by: Andrew Steckel

November 2016
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RULE IDENTIFICATION -

Agency: Antelope Valley Air Quality Management District (AVAQMD)

SIP Approved Version: There is no previous SIP approved AVAQMD RACT SIP for the 

2008 8-hour ozone standard or for the 1997 8-hour ozone 

standard.1

Subject of this TSD: AVAQMD 8-Hour Reasonably Available Control Technology – State 

Implementation Plan Analysis (2015 RACT SIP Analysis)

Adopted – July 21, 2015

Submitted – October 23, 2015

Completeness Finding: Determination of Completeness letter: March 9, 2016

BACKGROUND -

Volatile organic compounds (VOC) and nitrogen oxides (NOx) in the presence of sunlight can 

lead to the formation of ground-level ozone or “smog” which can result in significant impacts to 

human health and the environment. Section 182 of the Clean Air Act (CAA) requires areas that 

are classified as moderate or above for ozone nonattainment to implement reasonably 

available control technology (RACT) for specific types of sources. The Antelope Valley Air 

Quality Management District (AVAQMD) falls under this requirement as the District is classified 

as a severe-15 ozone nonattainment area for the 2008 ozone standard (May 21, 2012 77 FR 

30088 at 30100).

Under CAA § 182(b)(2) and (f), AVAQMD must, at a minimum, adopt RACT level controls for 

sources covered by a Control Techniques Guidelines (CTG) document and for any major 

stationary source of VOC or NOx. The EPA defines RACT as the “lowest emissions limitation 

that a particular source is capable of meeting by the application of control technology that is 

reasonably available considering technological and economic feasibility.” 44 FR 53761 

(September 17, 1979). A RACT analysis should, therefore, take into account the technological 

and economic feasibility of controls, and may differ from source to source and location to 

location.

SUBMITTAL SUMMARY –

The District adopted its RACT SIP certification for the 2008 ozone standard on July 21, 2015

and the California Air Resources Board (CARB) submitted it to the EPA on October 23, 2015. 

AVAQMD performed its RACT SIP analysis based on an ozone non-attainment classification 

 

1 On January 31, 2007, AVAQMD submitted its 2006 RACT SIP certification for the 1997 8-hour ozone standard. 

The 2006 RACT SIP is being evaluated in a separate TSD. EPA will act on both the 2006 RACT SIP and 2015 

RACT SIP submittals in a single rulemaking action.
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of “severe-15”. This classification defines a major source as those facilities that emit or have 

the potential to emit at least 25 tons per year (tpy) of VOC or NOx. See CAA Sections 

182(b)(2)(C), 182(f), and 302(j).

AVAQMD’s submittal included the following documents:

a. “8-Hour Reasonably Available Control Technology – State Implementation Plan 

Analysis (RACT SIP Analysis)”, dated July 2015 [hereinafter “2015 RACT SIP”].

b. “Final Staff Report – Adoption of the 2015 8-Hour Reasonably Available Control 

Technology – State Implementation Plan Analysis (2015 RACT SIP Analysis)”, dated 

July 21, 2015.

c. “Final Staff Report – Adoption of the Federal Negative Declarations for Twenty Control 

Techniques Guidelines Source Categories”, dated July 21, 2015.

d. Resolution 15-05, “A Resolution of the Governing Board of the Antelope Valley Air 

Quality Management District Making Findings, Certifying the Notice of Exemption, 

Adopting the 2015 8-Hour Reasonably Available Control Technology – State 

Implementation Plan Analysis (2015 RACT SIP Analysis) and Directing Staff Actions”, 

dated July 21, 2015.

e. Resolution 15-04, “A Resolution of the Governing Board of the Antelope Valley Air 

Quality Management District Making Findings, Certifying the Notice of Exemption, 

Adopting the Federal Negative Declarations for Twenty Control Techniques Guidelines 

Source Categories and Directing Staff Actions”, dated July 21, 2015.

AVAQMD’s analysis included the following areas. Further discussion is provided below.

• Review of its previous RACT analysis for the 1997 8-hour ozone standard (“2006 RACT 

SIP”) along with its March 13, 2014 supplement (“2014 Supplemental Analysis”)

• Further evaluation of selected AVAQMD Rules and Regulations

• Major sources identified 

• Negative declarations

EPA EVALUATION –

The EPA evaluated the following elements of AVAQMD’s 2015 RACT SIP:

• The bases for concluding local rules implement RACT

• Efforts to identify major non-CTG sources of VOC or NOx within the District

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

The following documents were also used to support our review:

• “Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard –

Phase 2” (70 FR 71612; November 29, 2005).

• “State Implementation Plans, General Preamble for the Implementation of Title I of the 

Clean Air Act Amendments of 1990” (57 FR 13498; April 16, 1992).
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• Enforceability - Section 110(a) of the CAA requires enforceable emission limitations and 

other control measures. Several EPA guidance documents are used to evaluate rule 

enforceability, including “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and 

Deviations,” EPA, May 25, 1988 (The Blue Book), and “Guidance Document for 

Correcting Common VOC & Other Rule Deficiencies,” EPA Region 9, August 21, 2001 

(the Little Bluebook).

• “State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for 

the Implementation of Title I of the Clean Air Act Amendments of 1990” (57 FR 55620, 

November 25, 1992) (“the NOx Supplement”).

• Memorandum from William T. Harnett to Regional Air Division Directors, (May 18, 2006), 

“RACT Qs & As – Reasonably Available Control Technology (RACT) Questions and 

Answers”.

• RACT SIPs, Letter dated March 9, 2006 from EPA Region IX (Andrew Steckel) to CARB 

(Kurt Karperos) describing Region IX’s understanding of what constitutes a minimally 

acceptable RACT SIP.

• Letter dated April 4, 2006 from EPA Region IX (Andrew Steckel) to CARB (Kurt 

Karperos) listing the EPA’s current CTGs, ACTs, and other documents which may help 

to establish RACT.

• “Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State 

Implementation Plan Requirements’’ (80 FR 12264; March 6, 2015).

• EPA’s CTGs and ACTs: https://www.epa.gov/ozone-pollution/control-techniquesguidelines-and-alternative-control-techniques-documents-reducing

• CARB’s emissions inventory database 

http://www.arb.ca.gov/app/emsinv/facinfo/facinfo.php

• AVAQMD, CARB, and EPA Region IX databases of AVAQMD rules

AVAQMD: http://avaqmd.ca.gov/rule-book

CARB: http://www.arb.ca.gov/rldb/rldb.htm

EPA: http://www.epa.gov/approved-sips/approved-sips-region-9

The following summarizes AVAQMD actions to address RACT requirements and the EPA’s 

evaluation of those actions.

1. Bases for Concluding Local Rules Implement RACT

RACT is required for source categories covered by an EPA Control Techniques Guidelines 

document (“CTG sources”) and all sources that are not covered by a CTG document but are 

“major sources” (i.e., for AVAQMD, “non-CTG sources” that emit or have the potential to 

emit at least 25 tons per year of VOCs or NOx).

AVAQMD action: 2015 RACT SIP, 2006 RACT SIP and 2014 Supplemental Analysis

AVAQMD’s 2015 RACT SIP states that the original 2006 RACT SIP Analysis (for the 1997 

8-hour ozone standard), together with the supplemental March 13, 2014 RACT SIP 

Analysis, and the 2015 RACT SIP represent a current and complete RACT SIP Analysis 

document to satisfy the District’s RACT obligation for the 1997 and 2008 8-hour ozone 
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standards.2 The 2006 RACT SIP and 2014 Supplemental Analysis are evaluated in a 

separate TSD.

In its 2015 RACT SIP, Appendix A, AVAQMD examined 14 rules, 11 of which regulate 

VOCs and are covered by CTGs. The remaining three rules regulate NOx emissions. The 

District indicated that for four of the 11 VOC categories, it did not have sources that met the 

CTGs’ applicability threshold and therefore were not subject to RACT. These categories 

were:

• Rule 463, Storage of Organic Liquids (3/11/94)

• Rule 1102, Petroleum Solvent Dry Cleaners (12/7/90)

• Rule 1104, Wood Flat Stock Coating Operations (3/1/913)

• Rule 1176, VOC Emissions from Wastewater Systems (5/13/944)

The District also states in Appendix A that it “..will not file a [Federal Negative Declaration] at 

this time but will update the rule to current Federal RACT when a source is acquired.”5

Five of the remaining seven VOC rules were identified by the District as needing to be 

updated for RACT. The 2015 RACT SIP states, in part:

• Rule 462, Organic Liquid Loading (6/9/95): to be amended to address deficiencies 

identified in EPA’s Proposed Rule: limited approval/disapproval (62 FR 26460, 

May 14, 1997).

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• Rule 1107, Coating of Metal Parts and Products (3/8/96): the rule is consistent 

with the 2008 CTG, but several VOC coating limits are less stringent than South 

Coast Air Quality Management District (SCAQMD) Rule 1107 (1/6/06), and thus, 

should be amended to meet RACT.

• Rule 1145, Plastic, Rubber and Glass Coatings (1/10/92: the rule has several 

VOC coating limits that are less stringent than SCAQMD Rule 1145 (12/4/09) and

needs updates to its definitions, transfer efficiency, and test methods sections.

 

2 AVAQMD RACT SIP Analysis, page 1, July 2015.

3 Rule 1104 (Amended 3/1/91) was approved into the SIP on 6/23/94 (59 FR 32354). 

4 Rule 1176 (Amended 5/13/94) was approved into the SIP on 8/25/94 (59 FR 43751).

5 2015 RACT SIP Appendix A, pgs A-4, A-5, and A-6. For Rule 1176, Appendix A, pg A-16 indicates a negative 

declaration was previously adopted for the 1997 8-hour ozone standard. See 76 FR 38572, July 1, 2011.

6 Antelope Valley was formed from South Coast AQMD in July 1997. We proposed approval a limited 

approval/disapproval of SCAQMD Rule 462 on May 14, 1997, prior to the separation of AVAQMD from SCAQMD. 

Our final rulemaking action on Rule 462 was published on November 13, 1997 (62 FR 60784), after Antelope 

Valley separated from SCAQMD and stated the final action was for SCAQMD and excluded Antelope Valley. 
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• Rule 1151, Motor Vehicle and Mobile Equipment Coating Operations (6/19/12): 

the rule must be amended to incorporate provisions of the Control Techniques 

Guidelines for Automobile and Light-Duty Truck Assembly Coating as applicable 

to “Heavier” vehicles, which includes all vehicles that meet the definition of the 

term “other motor vehicles”, as defined at 40 CFR 63.3176. The 2015 RACT SIP 

states that BYD Coach and Bus is not a major source but its operating permit 

allows VOC emissions above the applicability threshold for the 2008 CTG for 

Automobile and Light Duty Truck Assembly Coatings.

• Rule 1171, Solvent Cleaning Operations (11/17/98): the rule needs to be updated 

to include work practices, adjust categories for consistency with source specific 

rules, and include an alternative composite vapor pressure limit.

AVAQMD concluded that these remaining two VOC rules do not need updating at this time:

• Rule 1106.1, Pleasure Craft Coating Operations (6/13/97)

• Rule 1141.1, Coatings and Ink Manufacturing (3/6/92)

AVAQMD’s evaluation of the three NOx rules is summarized in section 3 below.

EPA Evaluation

We reviewed AVAQMD’s analysis of the 11 VOC rules. Based on a review of CARB’s 

emissions inventory, we agree with the District’s conclusion that it does not currently have 

sources subject to the CTGs covered by Rules 463, 1102, 1104, and 1176. 

• Rule 463, Storage of Organic Liquids (3/11/94)

o EPA 450/2-78-047, Emissions from Petroleum Liquid Storage in External Floating Roof Tanks

o EPA 450/2-77-036, Control of Volatile Organic Emissions from Storage of Petroleum Liquids in 

Fixed Roof Tanks

• Rule 1102, Petroleum Solvent Dry Cleaners (12/7/90)

o EPA-450/3-82-009, Control of Volatile Organic Compound Emissions from Large Petroleum 

Dry Cleaners

• Rule 1104, Wood Flat Stock Coating Operations (3/1/91)7

o EPA 450/2-78-032, Control of Volatile Organic Compounds Emissions from Existing Stationary 

Sources Volume VII: Factory Surface Coating of Flatwood Paneling

o EPA-453/R-06-004, Control Techniques Guidelines for Flat Wood Paneling Coatings

• Rule 1176, VOC Emissions from Wastewater Systems (5/13/94)

o EPA 450/2-77-025, Control of Refinery Vacuum Producing Systems, Wastewater Separators, 

and Process Unit Turnarounds

We reviewed AVAQMD’s analysis of five of the remaining seven VOC rules that need to be 

updated to meet RACT. Our evaluation follows:

 

7 AVAQMD’s 2015 RACT SIP, Table 2 lists the 2008 Flat Wood Paneling CTG as a negative declaration but does 

not list the 1978 Flat Wood CTG. Conversely, Appendix A, item 4 Wood Flat Stock Coating Operations states it 

does not have any sources that meet the CTG applicability threshold for the 1978 CTG, but does not mention the 

2008 Flat Wood CTG.
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• Rule 462, Organic Liquid Loading: we concur that this rule needs to be updated to 

revise the definition of “facility vapor leak” to remove the two centimeter 

measurement distance to be consistent with EPA Method 21 and to meet RACT.

Action - Revise rule to implement RACT

• Rule 1107, Coating of Metal Parts and Products: AVAQMD’s RACT SIP states 

that the VOC limits in Rule 1107 is consistent with the 2008 Miscellaneous Metal 

and Plastic Parts Coatings CTG, but several VOC limits are less stringent than 

SCAQMD Rule 1107 Coating of Metal Parts and Products (1/6/2006). We 

reviewed Rule 1107 and concluded it implements RACT by meeting the 2008 

CTG and conclude the more stringent limits in SCAQMD Rule 1107 to be beyond 

RACT.8

However, we find that Rule 1107 does not contain VOC limits for can coating 

operations which are found in the1977 CTG for Surface Coating of Cans, Coils, 

Paper, Fabrics Automobiles, and Light-Duty Trucks; nor does it contain VOC limits 

for drum coating operations which are found in the 2008 CTG for Miscellaneous 

Metal and Plastic Parts Coatings. Specifically, page iv of the 1977 CTG lists VOC 

limits for can coating operations and Table 2 of the 2008 CTG lists recommended 

VOC limits for drum coatings but AVAQMD Rule 1107 states it does not apply to 

metal containers (e.g., drums). We therefore conclude that AVAQMD does not 

currently regulate can or drum coating operations and does not have a negative 

declaration for the 2008 8-hour ozone standard for these coating categories.

We note that can and drum coatings were previously covered under AVAQMD 

Rule 1125 Metal Container, Closure, and Coil Coating Operations. On February 

17, 2004, AVAQMD rescinded Rule 1125 and at the same Board Action, adopted 

a negative declaration certifying it had no sources regulated by Rule 1125. The 

EPA approved AVAQMD’s rescission and negative declaration for can and drum 

coatings in 2004.9 AVAQMD should adopt a negative declaration for can coating 

operations for the 1977 CTG under the 2008 8-hour ozone standard.10

 

8 SCAQMD Rule 1107’s VOC limits for three categories (general, extreme high-gloss, and pre-fabricated 

architectural - for air dried coatings) are more stringent than the identical categories in EPA’s 2008 CTG for 

Miscellaneous Metal and Plastic Parts Coatings. We reviewed the metal coating rules from 11 California air 

districts and found that where the air district regulated the general, extreme high-gloss, or pre-fabricated 

architectural coating categories, its limits were identical to the limits in the 2008 CTG and none of the 11 air 

districts had adopted SCAQMD’s more stringent VOC limits. EPA generally considers controls that have been 

achieved in practice by a significant number of sources to be technologically and economically feasible, and 

therefore concludes SCAQMD Rule 1107’s more stringent limits for these three categories to be beyond RACT.

9 See 69 FR 56355 (September 21, 2004).

10 Our TSD for the 1997 ozone standard also recommends AVAQMD adopt a negative declaration for the 1997 8-

hour ozone standard for can coating operations subject to EPA-450/2-77-008, Control of Volatile Organic Emissions 

from Existing Stationary Sources – Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and 

Light-Duty Trucks.
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Action - AVAQMD should evaluate adopting, for the 2008 8-hour ozone standard,

a negative declaration for the can coating portion of the 1977 CTG: EPA-450/2-

77-008, Control of Volatile Organic Emissions from Existing Stationary Sources –

Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and 

Light-Duty Trucks.

AVAQMD should also evaluate adopting a negative declaration for the drum 

coating portion of the 2008 CTG: EPA 453/R-08-003, Control Techniques 

Guidelines for Miscellaneous Metal and Plastic Parts Coatings, or incorporate the 

applicable can/drum VOC limits into a SIP rule.

• Rule 1145, Plastic, Rubber and Glass Coatings: We find that the VOC limits for 

plastic parts coatings in Rule 1145 is consistent with Table 3 of the 2008 CTG for

Miscellaneous Metal and Plastic Parts Coatings with the exception that Rule 1145 

does not have a category for “Extreme Performance – 2 pack coatings”. We 

interpret the Extreme Performance category would therefore fall under Rule 

1145’s General Coatings category for two component coatings, which is 

consistent with the CTG’s limit of 420 g/L. EPA does not have a CTG for rubber or 

glass coatings. No further action is required for RACT.

• Rule 1151, Motor Vehicle and Mobile Equipment Coating Operations: the EPA 

concurs that BYD Coach and Bus is not currently a major source of VOC or NOx.

BYD Coach and Bus started operations in Antelope Valley in 2013. A review of

CARB’s emissions inventory for 2014 does not show this facility.11

Rule 1151 applies to the refinishing of automobiles and not to coating of new 

vehicles. Based on the District’s statement that BYD Coach’s permit allows it to 

exceed the applicability threshold of the 2008 CTG for Automobile and Light-Duty 

Truck Assembly Line Coatings, Rule 1151 will either need to be amended or a 

new rule adopted to implement RACT for this category.

Action - AVAQMD should amend Rule 1151 or adopt a new rule to incorporate 

VOC RACT coating limits for new heavier duty vehicles and, as applicable, VOC 

content limits from the 2008 CTG for Miscellaneous Metal and Plastic Parts 

Coatings, Table 6 Motor Vehicle Materials.

• Rule 1171, Solvent Cleaning Operations: we concur that this rule does not 

completely implement the 2006 CTG for Industrial Cleaning Solvents and should 

be revised to include work practices, VOC limits, and other items to implement

RACT.

 

11 BYD Motors Inc. appears to have started production in Lancaster, CA in the Spring of 2013. See 

http://sfvbj.com/news/2015/sep/08/byd-contract-brings-more-bus-building-lancaster/. AVAQMD states that BYD 

had total VOC emissions of 1.789 tons in 2015, which is below the CTG. See S. Detwiler (CARB) email to S. 

Tong (EPA), November 8, 2016, RE: VOC / NOx emissions for BYD Motors, Lancaster, CA?
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Action - AVAQMD should amend Rule 1171 to implement RACT.

We reviewed the two rules listed above that AVAQMD concluded do not need to be updated

at this time to implement RACT. Our evaluation follows:

• Rule 1106.1, Pleasure Craft Coating Operations: we concur that this rule 

implements RACT, but recommend the next time the rule is opened, that the 

compliance test methods be updated to reflect the latest methods as shown in 

SCAQMD Rule 1106.1, section (e)(1) (64 FR 47392, August 31, 1999).

• Rule 1141.1, Coatings and Ink Manufacturing: this is not a CTG category and 

based on reviewing CARB’s emissions inventory, AVAQMD does not have a 

coatings and ink manufacturing facility that is a major source of VOC. Rule 1141.1 

contains work practices to minimize VOC emissions.

2. Efforts to Identify Major non-CTG sources of VOC or NOx within the District

AVAQMD action:

AVAQMD’s 2015 RACT SIP, Table 1, lists five facilities that are major sources that emit or 

have the potential to emit (PTE) at least 25 tons/year of VOC or NOx. The 2015 RACT SIP 

states that two of these facilities, Antelope Valley Public Landfill and Lancaster Landfill and 

Recycling Center, do not emit a large amount of reactive VOCs, and therefore are not major 

sources of ozone precursors. Northrup-Grumman and Lockheed Martin Skunk Works are 

major VOC sources, and Wm. Bolthouse Farms is a major source of NOx. 

EPA evaluation:

We reviewed CARB’s 2010 - 2014 emissions inventory for Antelope Valley Public Landfill 

and Lancaster Landfill and Recycling Center and agree that actual VOCs are significantly 

less than 25 tons/year. Maximum actual VOC emissions from the Antelope Valley Public 

Landfill for 2010 - 2014 was 7.2 tpy and for the Lancaster Landfill and Recycling Center it 

was 2.6 tpy. 

As indicated by AVAQMD12, approximately 95% of the VOC PTE emissions at NorthrupGrumman and Lockheed Martin Skunk Works are controlled by Rule 1124, Aerospace and 

 

12 T. Walters (AVAQMD) email to J. Shears (EPA), April 19, 2016, FW: AV RACT SIP more questions. NorthrupGrumman’s 2014 emissions was 20.6 tpy and Lockheed Martin was 16.8 tpy VOC. AVAQMD stated 

approximately 95% of the VOC PTE emissions are controlled by Rule 1124. The remaining 5% represents 

approximately 1 tpy. Since EPA’s CTGs generally have an applicability threshold of 2.7 or 3 tpy, we conclude the 

remaining approximately 1 tpy is not likely to be subject to RACT controls and therefore did not further investigate 

these emissions. We also note that several VOC limits in Rule 1124 are more stringent than the recommended 

CTG limits and will help to achieve greater VOC reductions than required by the CTG (e.g., Adhesive Bonding 
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Component Manufacturing Operations (80 FR 60040, October 5, 2015). This rule meets 

RACT. 

Wm Bolthouse Farms’ NOx emissions13 come from diesel engine well pumps and is 

considered a major source of NOx. AVAQMD indicates the facility has electrified many of its 

engines and may, in the near future, be below the threshold for a title V permit.

14 A review of 

the title V permit indicates the applicable requirement to be CARB’s Airborne Toxic Control 

Measure (ATCM) for Diesel Particulate Matter from Portable Engines Rated at 50 

Horsepower and Greater15. There does not however, appear to be a NOx SIP rule which 

covers internal combustion engines used for agricultural operations. Specifically, CARB’s 

ATCM limits particulate matter and does not regulate NOx emissions and Rule 1110.2 

Emissions from Stationary, Non-road and Portable Internal Combustion Engines (January 

21, 2003) exempts engines used for agricultural operations.

Action: Amend Rule 1110.2 to remove agricultural exemption or adopt a new rule - see the 

next section for additional details.

The District’s efforts to identify all major sources appear to be thorough.

3. Other NOx Rules

AVAQMD action:

AVAQMD’s 2015 RACT SIP also examined the following 3 NOx rules:

• Rule 1110.2, Emissions from Stationary, Non-road and Portable Internal 

Combustion Engines: The 2015 RACT SIP indicates Rule 1110.2 does not 

implement RACT and will be updated to meet other federal requirements. Rule 

1110.2 must be updated to remove the agricultural exemption and address other 

EPA comments identified in the proposed limited approval / limited disapproval

(69 FR 21482, April 21, 2004).

• Rule 1146, Emissions of Oxides of Nitrogen from Industrial, Institutional and 

Commercial Boilers, Steam Generators, and Process Heaters: the District 

compared its rule to SCAQMD Rule 1146 and San Joaquin Valley Unified air 

Pollution Control District (SJVUAPCD) Rule 4306, and found AVAQMD Rule 1146 

was less stringent for certain NOx limits. The 2015 RACT SIP states it will survey 

 

Primers - Commercial and Military Aircraft, Fire-Resistant interior coating - civilian, and fuel tank coating-general 

limit).

13 CARB’s emissions inventory shows 46 tpy NOx in 2012, 39.7 tpy in 2013 and 39.5 tpy in 2014.

14 T. Walters (AVAQMD) email to J. Shears (EPA), April 21, 2016, FW: Wm. Bolthouse farms.

15 CARB ATCM available at http://www.arb.ca.gov/diesel/peatcm/peatcm.htm.
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affected units for applicability to this rule and determine if it is feasible to update 

the limits as RACT.

• Rule 1146.1, Emissions of Oxides of Nitrogen from Small Industrial, Institutional, 

and Commercial Boilers, Steam Generators, and Process Heaters: the District 

found the NOx limits in this rule to be consistent with the then current SIPapproved RACT limits in SJVUAPCD Rule 4307 (10/16/08) and SCAQMD Rule 

1146.1 (9/5/08). The 2015 RACT SIP states these rules as well as the TSD for the 

SCAQMD Rule 1146.1 (9/5/08), will be used for updating requirements during the 

next rule update.16

 

 EPA evaluation:

Rule 1110.2, Emissions from Stationary, Non-road and Portable Internal Combustion Engines: 

the EPA concurs that this rule needs to be updated to implement RACT. Our April 21, 2004 

proposed limited approval/limited disapproval was based on exempting agricultural internal 

combustion engines from the rule and this exemption should be removed. The limited 

approval/limited disapproval17 also included a request for justification of the seasonal 

exemption for engines used for snow manufacturing and ski lift operation, a request to correct 

several citations, and a request to increase records retention from 2 years to 5 years. 

Action: Amend Rule 1110.2

Rule 1146, Emissions of Oxides of Nitrogen from Industrial, Institutional and Commercial 

Boilers, Steam Generators, and Process Heaters and Rule 1146.1, Emissions of Oxides of 

Nitrogen from Small Industrial, Institutional, and Commercial Boilers, Steam Generators, and 

Process Heaters: the EPA evaluated these two rules and found they do not appear to be 

associated with major NOx sources in the District. We therefore conclude these rules are not 

required to implement RACT at this time. 

4. Submit negative declarations where there are no facilities subject to a CTG18.

AVAQMD action:

In lieu of adopting RACT rules, Districts can adopt negative declarations for CTG source 

categories if there are no sources in the District covered by the CTG. 

 

16 SJVUAPCD and SCAQMD subsequently amended its rules on April 21, 2016 and November 1, 2013 

respectively. 

17 See 69 FR 21482 (April 21, 2004).

18 Although AVAQMD’s July 21, 2015 Final Staff Report - Executive Summary (pg. 1) incorrectly describes the 

CAA RACT requirements to apply to CTG documents for “major sources” of VOCs and NOx, AVAQMD did use 

the correct criteria to identify all sources and source categories that are subject to the RACT Analysis (see p.9 of 

the July 2015 RACT SIP Analysis).
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Table 1 of AVAQMD’s “Final Staff Report – Adoption of the Federal Negative Declarations 

for Twenty Control Techniques Guidelines Source Categories”, dated July 21, 2015, 

identifies the CTG source categories for which the District indicates it has no applicable 

stationary sources. AVAQMD compiled this list by comparing its rules against EPA’s list of 

CTGs and ACTs and reviewing its permits, emissions inventory, and consulting with 

knowledgeable staff of the District’s permit and enforcement divisions.

The AVAQMD identified the following CTG source categories where it has an existing rule, 

but does not have sources exceeding the CTG’s applicability threshold: Rule 463, Storage 

of Organic Liquids, Rule 1102, Petroleum Solvent Dry Cleaners, and Rule 1104, Wood Flat 

Stock Coating Operations. The District states that adoption of negative declarations for 

these categories does not affect the SIP status of the existing rules nor does it preclude the 

District from amending such rules in the future and submitting them as SIP revisions.

EPA Evaluation:

EPA’s proposed rule to implement the 2008 8-hour ozone standard states: “RACT SIPs 

must contain adopted RACT regulations, certifications where appropriate that existing 

provisions are RACT and/or negative declarations that there are no sources in the

nonattainment area covered by a specific CTG source category.”19 We compared 

AVAQMD’s adopted rules and list of negative declarations to verify all the CTG categories

were either addressed by a District rule or were covered by a negative declaration. Table 2 

below lists three negative declarations that were missing from the District’s analysis, and a 

recommendation for the District to adopt a negative declaration for these categories as 

appropriate. A negative declaration for the RACT SIP does not impact the SIP approval 

status of a rule previously approved into the SIP by the EPA. 

Table 1 below lists the CTG source categories included in AVAQMD’s 2015 Federal 

Negative Declarations Table 1. We searched CARB’s emissions inventory database and 

verified there do not appear to be facilities in AVAQMD that might be subject to these 

CTGs. 

Table 1 – AVAQMD Negative Declarations

CTG Source Category CTG Reference Document

Bulk Gasoline Plants EPA-450/2-77-035, Control of Volatile Organic Emissions from Bulk 

Gasoline Plants

Coils EPA-450/2-77-008, Control of Volatile Organic Emissions from Existing 

Stationary Sources – Volume II: Surface Coating of Cans, Coils, Paper, 

Fabrics, Automobiles, and Light-Duty Trucks

Fiberglass Boat Manufacturing

Materials

EPA-453/R-08-004, Control Techniques Guidelines for Fiberglass Boat 

Manufacturing Materials

Flat Wood Paneling EPA-453/R-06-004, Control Techniques Guidelines for Flat Wood 

Paneling Coatings

 

19 80 FR 12264 at 12278, March 6, 2015.
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CTG Source Category CTG Reference Document

Fixed Roof Tanks EPA-450/2-77-036, Control of Volatile Organic Emissions from Storage 

of Petroleum Liquids in Fixed Roof Tanks

Floating Roof Tanks EPA-450/2-78-047, Control of Volatile Organic Emissions from 

Petroleum Liquid Storage in External Floating Roof Tanks

Insulation of Magnet Wire EPA-450/2-77-033, Control of Volatile Organic Emissions from Existing 

Stationary Sources – Volume IV: Surface Coating of Insulation of 

Magnet Wire

Large Appliances Coatings EPA-450/2-77-034, Control of Volatile Organic Emissions from Existing 

Stationary Sources – Volume V: Surface Coating of Large Appliances

EPA-453/R-07-004, Control Techniques Guidelines for Large Appliance 

Coatings

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

from Large Petroleum Dry Cleaners 

Manufacture of High-Density 

Polyethylene, Polypropylene, 

and Polystyrene Resins

EPA-450/3-83-008, Control of Volatile Organic Compound Emissions 

from Manufacture of High-Density Polyethylene, Polypropylene, and 

Polystyrene Resins

Metal Furniture Coating EPA-453/R-07-005, Control Techniques Guidelines for Metal Furniture 

Coatings

Natural Gas/Gasoline 

Processing Plants 

EPA-450/2-83-007, Control of Volatile Organic Compound Equipment 

Leaks from Natural Gas/Gasoline Processing Plants

Petroleum Refinery Equipment EPA-450/2-78-036, Control of Volatile Organic Compound Leaks from 

Petroleum Refinery Equipment

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

Manufacture of Pneumatic Rubber Tires

Refinery Vacuum Producing 

Systems, Wastewater 

Separators, and Process Unit 

Turnarounds

EPA-450/2-77-025, Control of Refinery Vacuum Producing Systems, 

Wastewater Separators, and Process Unit Turnarounds

Shipbuilding and Ship Repair 

Operations Surface Coating

61 FR 44050 and EPA-453/R-94-032,

Control Techniques Guidelines for Shipbuilding and Ship Repair 

Operations (Surface Coating)

Synthetic Organic Chemical 

Polymer and Resin 

Manufacturing Equipment

EPA-450/3-83-006, Control of Volatile Organic Compound Leaks from 

Synthetic Organic Chemical Polymer and Resin Manufacturing 

Equipment

Synthesized Pharmaceutical 

Products

EPA-450/2-78-029, Control of Volatile Organic Emissions from 

Manufacture of Synthesized Pharmaceutical Products

Synthetic Organic Chemical EPA-450/3-84-015, Control of Volatile Organic Compound Emissions 

from Air Oxidation Processes in Synthetic Organic Chemical 

Manufacturing Industry

EPA-450/4-91-031, Control of Volatile Organic Compound Emissions 

from Reactor Processes and Distillation Operations in Synthetic 

Organic Chemical Manufacturing Industry

Wood Furniture Manufacturing EPA-453/R-96-007, Control of Volatile Organic Compound Emissions 

from Wood Furniture Manufacturing Operations

We also compared the District’s earlier negative declarations for the 1997 ozone standard 

and found the Tank Truck Loading Terminal category was missing in the current list of 

negative declarations. We also note the 1978 Flat Wood Paneling and 1977 Metal Furniture 
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CTGs were not listed as negative declarations while the newer versions of these CTGs 

were adopted as negative declarations for the 2008 8-hour ozone standard. 

AVAQMD should determine if the following are negative declarations for the 2008 ozone 

standard and adopt negative declarations as appropriate.

Table 2 – Suggested Additional Negative Declarations

CTG Source Category CTG Reference Document

Tank Truck Terminal >76,000 L EPA-450/2-77-026, Control of Hydrocarbons from Tank Truck Gasoline 

Loading Terminals

Negative declaration was adopted for the 1997 8-hour ozone standard

but not for the 2008 8-hour ozone standard

Flat Wood Paneling EPA-450/2-78-032, Control of Volatile Organic Emissions from Existing 

Stationary Sources – Volume VII: Factory Surface Coating of Flat Wood 

Paneling

Negative declaration was adopted for the 2008 CTG for Flat Wood 

Paneling, but not for the 1978 CTG for Flat Wood Paneling

Metal Furniture EPA-450/2-77-032, Control of Volatile Organic Emissions from Existing 

Stationary Sources – Volume III: Surface Coating of Metal Furniture

Negative declaration was adopted for the 2007 CTG for Metal Furniture 

Coatings, but not for the 1977 CTG for Metal Furniture Coatings

5. Summary

With the exception of the following rules, we conclude that AVAQMD’s 2015 RACT SIP in 

combination with its 2006 RACT SIP Analysis for the 1997 8-hour ozone standard and its 2014 

Supplemental Analysis largely satisfies the District’s RACT obligation for the 1997 and 2008 8-

hour ozone standards. The rules that need to be amended to implement RACT are:

Rule 462 Organic Liquid Loading - Amend rule to address deficiencies in the proposed Limited

Approval/Limited Disapproval in 62 FR 26460, 05/14/1997.

Rule 1110.2 Emissions from Stationary, Non-road and Portable Internal Combustion Engines -

Amend rule to remove agricultural exemption.

Rule 1151 - Motor Vehicle and Mobile Equipment Coating Operations - Amend or adopt 

separate rule to cover coating of new heavier duty vehicles and, as applicable, VOC content 

limits from the 2008 CTG for Miscellaneous Metal and Plastic Parts Coatings, Table 6 Motor 

Vehicle Materials.

Rule 1171 - Solvent Cleaning Operations - Amend rule to incorporate work practices from 

2006 Industrial Solvent Cleaning CTG.

Evaluate adopting negative declarations for the following CTGs for the 2008 8-hour ozone 

standard:

EPA-450/2-77-008 Can coating portion 
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EPA-453/R-08-003 Drum coating portion and Pleasure craft portion

EPA-450/2-77-026 Tank Truck Gasoline Loading Terminals

EPA-450/2-78-032 Flat Wood Paneling coating

EPA-450/2-77-032 Metal Furniture coating

Final disapproval will result in offset and highway sanctions unless EPA approves a SIP 

revision amending the above rules as fulfilling RACT within 18 months of the effective date of 

the disapproval. See CAA section 179 and 40 CFR 52.31. We will not finalize this partial 

disapproval, however, if we receive and fully approve these rules fulfilling RACT before 

finalizing action on the 2015 RACT SIP. EPA is committed to working with CARB and the 

District to resolve these RACT deficiencies, and we encourage the State and District to submit 

a SIP revision correcting the identified deficiencies as expeditiously as practicable. A revised 

2015 RACT SIP demonstration will not be necessary if the submitted amended rules correct 

the identified deficiencies. 

In addition, CAA section 110(c)(1) provides that EPA must promulgate a Federal 

Implementation Plan (FIP) within two years after finding that a State has failed to make a 

required submission or disapproving a SIP submission in whole or in part, unless EPA 

approves a SIP revision correcting the deficiencies within that two-year period. 

6. Suggestions for Additional VOC / NOx Reductions

If additional emission reductions are needed beyond RACT, the District may want to 

investigate:

1) Controlling emissions from chain driven charbroilers. See SCAQMD Rule 1138, 

Control of Emissions from Restaurant Operations; SJVUAPCD Rule 4692, 

Commercial Charbroiling; or Bay Area AQMD Regulation 6 Rule 2 Commercial 

Cooking Equipment.

2) Warm mix asphalt as an option to hot mix asphalt – See San Joaquin 2015 DRAFT 

Warm Mix Asphalt Further Study Report 

http://www.valleyair.org/notices/Docs/2015/12-01-15_%28WMA%29/WMA.pdf

REFERENCES -

1. “Final Staff Report – Adoption of the 2015 Reasonably Available Control Technology –

State Implementation Plan Analysis (2015 RACT SIP Analysis)”, dated July 21, 2015.

2. “8-Hour Reasonably Available Control Technology – State Implementation Plan Analysis 

(RACT SIP Analysis)”, dated July, 2015 [hereinafter “2015 RACT SIP”].

3. “Final Staff Report – Adoption of the Federal Negative Declarations for Twenty Control 

Techniques Guidelines Source Guidelines”, dated July 21, 2015.
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4. AVAQMD “8-Hour Reasonably Available Control Technology – State Implementation Plan 

Analysis (RACT SIP Analysis)”, dated August 2006.

5. AVAQMD “8-Hour Ozone Reasonably Available Control Technology (RACT) State 

Implementation Plan (SIP) Analysis – Supplemental Analysis”, dated March 13, 2014.

6. RACT SIPs, Letter dated March 9, 2006 from EPA Region IX (Andrew Steckel) to CARB 

(Kurt Karperos) describing Region IX’s understanding of what constituted a minimally 

acceptable RACT SIP.

7. RACT SIPs, Letter dated April 4, 2006 from EPA Region IX (Andrew Steckel) to CARB 

(Kurt Karperos) listing EPA’s current CTGs, ACTs, and other documents which may help 

to establish RACT.

8. RACT Qs & As – Reasonably Available Control Technology (RACT): Questions and 

Answers, May 18, 2006 Note from William T. Harnett, Director, Air Quality Policy Division, 

to Regional Air Division Directors. 

http://www3.epa.gov/ttn/caaa/t1/memoranda/ractqanda.pdf

9. “Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard – Phase 

2” (70 FR 71612; November 29, 2005).

10.“Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State 

Implementation Plan Requirements’’ (80 FR 12264; March 6, 2015).

11.“Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” (a.k.a.,

Bluebook) EPA OAQPS, May 25, 1988

http://archive.epa.gov/ttn/ozone/web/pdf/voc_bluebook.pdf

12.“Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” (a.k.a., 

Little Bluebook), EPA Region 9, August 21, 2001 http://www.arb.ca.gov/drdb/lbb2001.pdf

13.“State Implementation Plans, General Preamble for the Implementation of Title I of the 

Clean Air Act Amendments of 1990” (57 FR 13498; April 16, 1992).

14.“State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for the 

Implementation of Title I of the Clean Air Act Amendments of 1990” (57 FR 55620, 

November 25, 1992) (“the NOx Supplement”).

15. EPA’s CTGs and ACTs https://www.epa.gov/ozone-pollution/control-techniquesguidelines-and-alternative-control-techniques-documents-reducing

16. CARB’s emissions inventory database 

http://www.arb.ca.gov/app/emsinv/facinfo/facinfo.php

17. AVAQMD, CARB, and EPA Region IX databases of AVAQMD rules
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AVAQMD: http://avaqmd.ca.gov/rule-book 

CARB: http://www.arb.ca.gov/rldb/rldb.htm

EPA: http://www.epa.gov/approved-sips/approved-sips-region-9

18. “BYD Contract Brings More Bus Building to Lancaster”. See 

http://sfvbj.com/news/2015/sep/08/byd-contract-brings-more-bus-building-lancaster/

19. T. Walters (AVAQMD) email to J. Shears (EPA), April 19, 2016 FW: AV RACT SIP more 

questions.

20. CARB’s emissions inventory for AVAQMD showing 46 tpy NOx in 2012, 39.7 tpy in 2013 

and 39.5 tpy in 2014 for Wm Bolthouse Farms.

21. T. Walters (AVAQMD) email to J. Shears (EPA), April 21, 2016, FW: Wm. Bolthouse 

farms.

22. S. Detwiler (CARB) email to S. Tong (EPA), November 8, 2016, RE: VOC / NOx emissions 

for BYD Motors, Lancaster, CA?