Appendix VI

Air Quality Management Plan

South Coast Air Quality Management District

Cleaning the air that we breathe...

®

AQMD

December 2012

TRAN

S

P

O

RTATION

AIR QUALITY

ENERGY

CLIMATE

2012

Reasonably Available Control 

Measures (RACM) Demonstration
FINAL 2012 AQMP

APPENDIX VI

REASONABLY AVAILABLE CONTROL MEASURES

(RACM) DEMONSTRATION

DECEMBER 2012
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

GOVERNING BOARD

Chairman: DR. WILLIAM A. BURKE

Speaker of the Assembly Appointee

Vice Chairman: DENNIS YATES

Mayor, Chino, Cities of San Bernardino 

County

MEMBERS:

MICHAEL D. ANTONOVICH

Supervisor, Fifth District, County of Los Angeles

JOHN J. BENOIT

Supervisor, Fourth District, County of Riverside

MICHAEL A. CACCIOTTI

Mayor, South Pasadena, Cities of Los Angeles County/Eastern Region

JOSIE GONZALES

Supervisor, Fifth District, County of San Bernardino

RONALD O. LOVERIDGE

Mayor, Riverside, Cities of Riverside County

JOSEPH K. LYOU, Ph.D.

Governor’s Appointee

JUDITH MITCHELL

Councilmember, Rolling Hills Estates, 

Cities of Los Angeles County/Western Region

SHAWN NELSON

Supervisor, Fourth District, County of Orange

CLARK E. PARKER, Ph.D.

Senate Rules Appointee

JAN PERRY

Councilwoman, Ninth District, City of Los Angeles

MIGUEL A. PULIDO

Mayor, Santa Ana, Cities of Orange County

EXECUTIVE OFFICER:

BARRY R. WALLERSTEIN, D.Env.
CONTRIBUTORS

South Coast Air Quality Management District

Barry R. Wallerstein, D.Env.

Executive Officer

Elaine Chang, DrPH

Deputy Executive Officer

Planning, Rule Development, & Area Sources

Laki Tisopulos, Ph.D., P.E.

Assistant Deputy Executive Officer

Planning, Rule Development, & Area Sources

Joseph Cassmassi Philip Fine, Ph.D.

Planning and Rules Manager Planning and Rules Manager

Planning, Rule Development & Area Sources Planning, Rule Development & Area Sources

Author

Minh Pham, P.E., Air Quality Specialist

Planning, Rule Development & Area Sources

Contributors

SCAQMD, NOx/RECLAIM TEAM

Area Sources & Transportation

SCAQMD, VOC RULESTEAM

Gary Quinn, P.E., Program Supervisor Naveen Berry, Planning/Rules Manager

Michael Bigelow, Student Intern David Ono, Program Supervisor

Don Hopps, Air Quality Specialist

SCAQMD, PM STRATEGIES TEAM Michael Morris, Air Quality Specialist

Tracy Gross, P.E., Program Supervisor David DeBoer, Program Supervisor

Rizaldy Calungcagin, Air Quality Specialist

U.S. EPA, REGION IX SCAG 

Wienke Tax, Staff Member Jonathan Nadler, SCAG Department Manager

Stan Tong, Staff Member Rongsheng Luo, SCAG Program Manager

CARB

Ravi Ramalingam, Manager

Scott King, Staff Member

Reviewed By

Laki Tisopulos, Ph.D., P.E., Assistant Deputy Executive Officer
Table of Contents

INTRODUCTION .......................................................................................................... VI-1

IDENTIFYING AND EVALUATING REASONABLY AVAILABLE CONTROL 

MEASURES .............................................................................................................. VI-5

Step 1 - Air Quality Technology Symposium............................................................. VI-5

Step 2 - U.S. EPA Suggested List of Control Measures............................................. VI-6

Step 3 – Reasonably Available Control Technologies (RACT)................................. VI-7

Step 4 - Other Districts’ Current Rules and Regulations.......................................... VI-11

Step 5 - Other Districts’ Control Measures............................................................... VI-12

Step 6 - Additional Studies and Analyses................................................................. VI-17

CONCLUSION ............................................................................................................. VI-18

REFERENCES ............................................................................................................. VI-20
Final 2012 AQMP

VI - 1

INTRODUCTION

The South Coast Air Basin (Basin) is classified as “Nonattainment” with respect to the 

1997 PM2.5 National Ambient Air Quality Standards (NAAQS) of 15 μg/m3annual 

average, and 65 μg/m324-hour average, and the U.S. EPA has granted the Basin a onetime extension to April 5, 2015 to reach attainment.

1

In 2006, the U.S. EPA lowered the 

24-hour PM2.5 standard to 35 μg/m3, and designated the Basin and 30 other areas as 

nonattainment, effective December 14, 2009. The Basin is required to submit an Air 

Quality Management Plan (AQMP) to U.S. EPA no later than 3 years after designation 

date, by December 14, 2012, to address the attainment strategies for the 2006 24-hour 

PM2.5 standard. In addition, the Basin must reach attainment within 5 years of the 

designation date, or by December 14, 2014. Table VI-1 provides a list of several 

nonattainment areas in the nation and the important milestone dates that require actions 

from the nonattainment air districts. 

TABLE VI-1

PM2.5 NAAQS Designation and Implementation

1997 PM2.5 NAAQS 2006 PM2.5 NAAQS

Nonattainment Areas  Los Angeles, South Coast 

Air Basin, CA

 San Joaquin Valley, CA

 New York, New Jersey, 

Long Island, CT

 Los Angeles, South Coast 

Air Basin, CA

 San Joaquin Valley, CA

 Sacramento Metro, CA

 San Francisco, CA

 New York, New Jersey, 

Long Island, CT

Effective Date of Standards September 1997 December 2006

Effective Date of Designations April 2005 December 2009

SIPs Due Within 3 Years April 2008 December 2012

Attainment Date Within 5 Years April 2010 December 2014

Attainment Date With Extension Up To April 2015 Up To December 2019

Particulate Matter (PM 2.5) Nonattainment Areas, www.epa.gov/airquality/greenbook/rnc.html, posted on 

3/30/2012.

With regards to the ozone standards, on March 12, 2008, the U.S. EPA strengthened its 

ground-level 8-hour ozone standard from 0.08 parts per million (ppm) to a level of 

0.075 ppm. On May 21, 2012, the U.S. EPA classified two areas in the country, the 

South Coast and the San Joaquin Valley, as “Extreme” nonattainment areas with respect 
Appendix VI: Reasonably Available Control Measures

VI - 2

to the 2008 8-hour ozone standard.

2

 The attainment dates for the 1997 and 2008 ozone 

standards are June 15, 2024 and December 31, 2032, respectively. Table VI-2 shows 

the classifications and attainment dates for several nonattainment areas in the nation. 

While an extreme nonattainment area has a period of 20 years from the date of 

designation to reach attainment, other areas that are classified as severe, serious, 

moderate and marginal must reach attainment sooner in 15 years, 9 years, 6 years and 3 

years after the date of designation, respectively. 3

TABLE VI- 2

8-Hour Ozone NAAQS Designation and Implementation

NONATTAINMENT 

AREA

1997 OZONE STANDARD 2008 OZONE STANDARD

Classification Attainment Classification Attainment

Los Angeles South Coast Air 

Basin, CA Extreme June 2024 Extreme December 2032

San Joaquin Valley, CA Extreme June 2024 Extreme December 2032

Riverside County (Coachella 

Valley), CA Severe-15 June 2019 Severe-15 December 2027

Sacramento Metro, CA Severe-15 June 2019 Severe-15 December 2027

Houston-Galveston-Brazoria 

(HGB), TX Severe-15 June 2019 Marginal December 2015

Ventura County, CA Serious June 2013 Serious December 2021

Dallas-Fort Worth , TX Serious June 2013 Moderate December 2018

New York, New Jersey, 

Long Island, CT Moderate June 2010 Marginal December 2015

Washington (DC-MD-VA 

Area), District Columbia Moderate June 2010 Marginal December 2015

San Francisco, CA Marginal June 2007 Marginal December 2015

Note: Classifications of 8-Hour Ozone Nonattainment Areas, www.epa.gov/airquality/greenbook/gnc.html, posted on 

3/30/2012. The designation date is December 31, 2012. Attainment dates are within 20 years after the date of 

designation for extreme area, 15 years after the date of designation for severe area, 9 years after the date of designation 

for serious area, 6 years after the date of designation for moderate area, and 3 years after the date of designation for 

marginal area. 

To address multiple layers of attainment deadlines, the District is working in 

collaboration with CARB and the San Joaquin Valley to develop a joint “Vision of 

Clean Air” and formulate the attainment strategies for 24-hour PM2.5 standards in 

2014-2019, 8-hour ozone standards in 2024-2032, and the state is committed to reduce 

greenhouse gases emissions by 2050. The District’s goal is to develop and incorporate 
Final 2012 AQMP

VI - 3

all feasible control measures while balancing costs and socioeconomic impacts to meet 

the requirements of the Clean Air Act (CAA) on a timely basis.

The CAA, Section 172(c)(1), sets the overall framework for the Reasonably Available

Control Measures (RACM) analysis. The CAA requires the nonattainment air districts 

to:

“provide for the implementation of all reasonably available control measures as 

expeditiously as practicable (including such reductions in emissions from existing 

sources in the area as may be obtained through the adoption, at a minimum, of 

reasonably available control technology)and shall provide for attainment of the 

national primary ambient air quality standards.”

The U.S. EPA provided further guidance on the RACM in the preamble and the final 

“Clean Air Fine Particle Implementation Rule” to implement the 1997 PM2.5 NAAQS 

which were published in the Federal Register in November 1, 2005 and April 25, 2007, 

respectively.

4, 5 The U.S. EPA’s long-standing interpretation of the RACM provision 

stated in the 1997 PM2.5 Implementation Rule is that the nonattainment air districts 

should consider all candidate measures that are available and technologically and 

economically feasible to implement within the nonattainment areas, including any 

measures that have been suggested; however, the districts are not obligated to adopt all 

measures, but should demonstrate that there are no additional reasonable measures 

available that would advance the attainment date by at least one year or contribute to 

reasonable further progress (RFP) for the area. 

Regarding the approach of identifying emission reduction programs, the U.S. EPA

recommends the nonattainment air districts to first identify the emission reduction 

programs that have already been implemented at the federal, other states and local air 

districts. Next, the U.S. EPA recommends the air districts to examine additional 

RACM/RACTs adopted for other nonattainment areas to attain the ambient air quality 

standards as expeditiously as practicable. The U.S. EPA also recommends the air 

districts evaluate potential measures for sources of direct PM2.5, SOx and NOx first 

with a presumption that VOC and ammonia do not significantly contribute to the PM2.5

concentration in the nonattainment area. The PM2.5 Implementation Rule also requires 

the air districts establish RACM/RACT emission standards taking into consideration 

the condensable fraction of direct PM2.5 emissions after January 1, 2011. In addition, 

the U.S. EPA recognizes that each nonattainment area has its own profile of emitting 

sources, and thus neither requires specific RACM/RACT to be implemented in every 

nonattainment area, nor includes a specific source size threshold for the RACM/RACT 
Appendix VI: Reasonably Available Control Measures

VI - 4

analysis. The U.S. EPA however recommends severe nonattainment air districts to 

evaluate controls for smaller sources if needed for attainment.

A RACM/RACT demonstration must be provided within the State Implementation Plan 

(SIP). For areas projected to attain within five years of designation, a limited 

RACM/RACT analysis including the review of available reasonable measures, the 

estimation of potential emission reductions, and the evaluation of the time needed to 

implement these measures is sufficient. The areas that cannot reach attainment within 

five years must conduct a thorough RACM/RACT analysis to demonstrate that 

sufficient control measures could not be adopted and implemented cumulatively in a 

practical manner in order to reach attainment at least one year earlier. 

In regards to economically feasible, the U.S. EPA did not propose a fixed dollar per ton 

cost threshold and recommended the air districts to include health benefits in the cost 

analysis. As indicated in the preamble of the 1997 PM2.5 Implementation Rule:

“In regard to economic feasibility, U.S. EPA is not proposing a fixed dollar per ton 

cost threshold for RACM, just as it is not doing so for RACT...Where the severity of 

the nonattainment problem makes reductions more imperative or where essential 

reductions are more difficult to achieve, the acceptable cost of achieving those 

reductions could increase. In addition, we believe that in determining what are 

economically feasible emission reduction levels, the States should also consider the 

collective health benefits that can be realized in the area due to projected 

improvements.” 

Subsequently, on March 2, 2012, the U.S. EPA issued a memorandum to confirm that 

the overall framework and policy approach stated in the PM2.5 Implementation Rule 

for the 1997 PM2.5 standards continue to be relevant and appropriate for addressing the 

2006 24-hour PM2.5 standards.

6

The objective of this Appendix is to demonstrate that the District has conducted a 

thorough RACM/RACT analysis to meet the requirement of the CAA following closely 

the policy and guidance approach provided by the U.S. EPA in its PM2.5

Implementation Rule in identifying and selecting the control measures for the Final 

2012 AQMP.

For the scope of this RACM analysis, District staff will closely study the attainment 

strategies for stationary and area sources, the rules and regulations of the air districts 

responsible for the nonattainment areas listed in Table VI-1 and Table VI-2 while 

taking into account all available candidate measures proposed by the U.S. EPA, CARB, 
Final 2012 AQMP

VI - 5

the Advisory Committee members, the technical experts in air pollution control as well 

as the public and variety of stakeholders. Staff selected the air districts listed on Table 

VI-1 and Table VI-2 based on the severity of their nonattainment status and their nearterm attainment dates. The RACM analysis for Transportation Control Measures is 

conducted by SCAG as shown in Appendix IV-C and the RACM analysis for mobile 

sources conducted by the CARB is shown in the Attachment of this Appendix. 

IDENTIFYING AND EVALUATING REASONABLY AVAILABLE 

CONTROL MEASURES

To demonstrate that the District has considered all candidate measures that are available 

and technologically and economically feasible to implement within the Basin, the 

District staff has conducted 6-steps analysis described below.

Step 1 - Air Quality Technology Symposium

District staff conducted the 2012 Air Quality Technology Symposium in September 

2011with participation of technical experts from a variety of areas and the public to 

solicit new and innovative concepts to assist the Basin in attaining the NAAQS) for 

PM2.5 by 2014-2019 and ozone by 2024-2032. In addition, the District’s Planning, 

Rules Development and Area Sources Division conducted multiple internal meetings 

with the District’s Technology Advancement Office and the Engineering & Compliance 

Division from September through November of 2011 to brainstorm ideas for feasible 

control measures. In addition, the District also conducted an on-going extensive 

outreach to engage a wide range of stakeholders in the process. In general, the

following concepts were proposed:

 Promoting zero or near-zero emission measures and providing incentives for onroad and non-road mobile sources as well as goods movement;

 Further reducing VOC emissions from marine coatings, aerospace coatings, 

solvents and various consumer products, and focusing on reformulations or 

alternatives to VOC based-solvents;

 Conducting a mandatory technology review for NOx RECLAIM, and further 

reducing NOx emissions through the use of low NOx burners, fuel cells, biogas 

control, distributed power generation applications, and assessment for all feasible 

measures, as well as incentives;
Appendix VI: Reasonably Available Control Measures

VI - 6

 Addressing energy-climate change and co-benefits, the need for electricity storage 

and smart grid, or new fossil-fueled peaking plants, to compensate for fluctuations 

in renewable energy supply, and the use of outreach to promote energy efficiency 

measures; and

 Influencing consumer behavior, expanding carpool programs, incentivizing with 

outreach, increasing gas tax, and promoting public-private participation and multiagency collaboration.

Step 2 – U.S. EPA’s Suggested List of Control Measures

District staff reviewed for inclusion the control measure concepts suggested by the U.S. 

EPA for PM2.5 nonattainment areas described in the preamble of the PM2.5

Implementation Rule. As summarized in Table VI-3, the District either has an existing 

rule or developed a 2012 control measure for each control measure concept suggested 

by the U.S. EPA.

TABLE VI-3

Demonstration of Compliance with Control Measures Recommended by U.S. EPA

U.S. EPA’S CONTROL MEASURE CONCEPTS

2012 CONTROL 

MEASURES AND 

EXISTING RULES

STATIONARY SOURCE MEASURES

Diesel engine retrofit, rebuild, replacement, with catalyzed particle filter Rule 1470, Rule 1110.2

New or upgraded emission controls for direct PM2.5 (e.g., baghouse or 

electrostatic precipitator; improved monitoring methods)

Rule 1155, Rule 1156

New/upgraded emission controls for PM2.5 precursors (e.g., scrubbers) 2010 RECLAIM Amendment 

Energy efficiency measures to reduce fuel consumption Rule 1146, Rule 1146.1, Rule 

1146.2, Rule 1114, Rule 

1111, Control Measure EDU01, INC-01

MOBILE SOURCE MEASURES

On-road diesel engine retrofits for school buses and trucks using U.S. 

EPA-verified technologies

Refer to CARB’s Existing 

Rules and Control Measures

Non-road diesel engine retrofit, rebuild/replace with catalyzed particle 

filter

Refer to CARB’s Existing 

Rules and Control Measures
Final 2012 AQMP

VI - 7

TABLE VI-3 (concluded)

Demonstration of Compliance with Control Measures Recommended by U.S. EPA

U.S. EPA’S CONTROL MEASURE CONCEPTS

2012 CONTROL 

MEASURES AND 

EXISTING RULES

MOBILE SOURCE MEASURES (continued)

Diesel idling programs for trucks, locomotive, and other mobile sources Refer to CARB’s Existing 

Rules and Control Measures

Transportation control measures (including those listed in section 108(f) 

of the CAA as well as other TCMs), as well as other transportation 

demand management and transportation systems management strategies

Refer to SCAG’s Control 

Measures

Programs to reduce emissions and accelerate retirement of high emitting 

vehicles, boats, lawn and garden equipment

Refer to CARB’s Rules and 

Control Measures

Emissions testing and repair/maintenance programs for on-road vehicles Refer to CARB’s Rules and 

Control Measures

Emissions testing and repair/maintenance programs for non-road heavy 

duty vehicles and equipment

Refer to CARB’s Rules and 

Control Measures

Programs to expand use of clean burning fuels Refer to CARB’s Rules and 

Control Measures

Opacity/emissions standards for gross-emitting diesel equipment or 

vessels

Refer to CARB’s Rules and 

Control Measures

AREA SOURCE MEASURES

New open burning regulations and/or measures to minimize emissions 

from forest and agricultural burning activities

Rule 444

Reduce emissions from woodstoves and fireplaces Rule 445, Control Measure 

BCM-01

Regulate charbroiling/other commercial cooking operations Control Measure BCM-02

Reduce solvent usage or solvent substitution Control Measure CTS-02

Reduce dust from construction activities/vacant disturbed areas, paved 

and unpaved roads.

Rule 1157

Step 3 – Reasonably Available Control Technology (RACT)

As required by the CAA, Section 172(c)(1), the nonattainment areas must implement 

applicable RACTs. While RACM refers to measures which may be applicable to a wide 

range of sources, stationary as well as area and mobile sources, the U.S. EPA defines 

RACT as the lowest level of control specifically designed for stationary sources:
Appendix VI: Reasonably Available Control Measures

VI - 8

“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”.

The CAA, Section 172(c)(1) and Section 182, require nonattainment areas for ozone 

that are designated at moderate or above to adopt RACT for major sources. 

Nonattainment areas classified as serious, severe, or extreme must adopt control 

measures above and beyond the minimum RACT levels to fulfill attainment.

In addition, the CAA, Section 183, requires the U.S. EPA to provide guidance to the air 

districts on the “presumptive” RACT levels. As a result, the U.S. EPA developed 

several Control Techniques Guidelines (CTGs) for VOC sources, and Alternatives 

Control Techniques (ACT) documents for VOC and NOx sources. Most of the CTGs 

were issued prior to 1990, and most of the ACT documents were issued in the mid1990s. The CTGs contain mandated emission standards and work practices whereas the 

ACTs describe available control techniques and their cost effectiveness, but do not 

define “presumptive” RACT levels. The U.S. EPA is required to update existing 

CTG/ACTs, or develop new guidelines, on a frequent basis as new or updated control 

technologies become available.

The CAA, Section 182(b)(2), further requires the air districts to revise their SIPs to 

include the mandated RACT levels covered by the CTGs issued after November 15, 

1990 and prior to the area’s date of attainment. The U.S. EPA's final rule to implement 

the 8-hour ozone standard discusses RACT requirements which states that where a 

RACT SIP is required, the states must assure that RACT is met, either through a 

certification that previously required RACT controls represent RACT for 8-hour 

ozone standards, or through a new RACT determination.7To satisfy this 

requirement, the District developed and submitted to CARB and U.S. EPA a 

demonstration and certification that the District’s rules and regulations fulfill the 8-hour 

ozone RACT requirements developed between 1990 and the beginning of 2006.

8

 The 

U.S. EPA approved the District’s RACT demonstration in December 2008.

9

Subsequently, the U.S. EPA developed twelve new CTGs in 2006-2008 to update the 

requirements for several types of coatings, and staff again conducted an analysis 

comparing the current requirements in the District’s rules with those requirements in the 

new CTGs. The 12 new CTGs developed by the U.S. EPA are:

10

 Flat Wood Paneling Coatings (2006)
Final 2012 AQMP

VI - 9

 Flexible Packaging Printing Materials (2006)

 Industrial Cleaning Solvents (2006)

 Lithographic Materials and Letterpress Printing Materials (2006)

 Large Appliance Coatings (2007)

 Metal Furniture Coatings (2007)

 Paper, Film, and Foil Coatings (2007)

 Miscellaneous Metal Products Coatings (2008)

 Plastic Parts Coating (2008)

 Auto and Light-Duty Truck Assembly Coatings (2008)

 Fiberglass Boat Manufacturing Materials, and Miscellaneous (2008)

 Industrial Adhesives (2008)

District staff’s analysis is summarized in Table VI-4. As shown in Table VI-4, three 

District’s VOC rules, Rule 1130 – Graphic Arts, Rule 1115 – Motor Vehicle Assembly 

Line Coating Operations and Rule 1168 - Adhesives and Sealants have met or exceeded 

most, but not all, minimum requirements of the CTGs. Consequently, District staff has 

developed one or more control measures to address these issues. Staff estimates a 

potential reduction of 0.2 tons per day VOC associated with Rule 1130, and less than 

0.01 tons per day VOC associated with Rule 1115, and no emission reduction estimate 

for Rule 1168 is available at this time. District staff is aware that additional assessments 

may be required, such as a determination that major VOC sources subject to Rules 1130, 

1115, and 1168 met the minimum requirements in the CTGs, or a negative declaration 

that there are no sources in the area subject to the CTGs. These additional analyses will 

be provided during the rule development phase, or at the time of developing the 8-hour 

ozone AQMPs, whichever comes first. 
Appendix VI: Reasonably Available Control Measures

VI - 10

TABLE VI-4

Evaluation of 2006-2008 U.S. EPA’s VOC CTGs

CTG TITLE DISTRICT RULE EVALUATION

Flat Wood Paneling Coatings (2006) Rule 1104 - Wood 

Flat Stock Coating 

Operations

Overall equivalency to CTG emission standards. No further 

action is needed. 1

Flexible Packaging Printing Materials 

(2006); Lithographic Printing Materials 

and Letterpress Printing Materials (2006)

Rule 1130 -

Graphic Arts

Regarding flexible packaging printing, the rule is more 

stringent than CTG, and thus no further action is needed. 

Regarding lithographic and letterpress printing, the CTG 

standards for alcohol content in fountain solution and overall 

control efficiency are more stringent. Staff estimated a 

potential reduction of 0.2 tpd and may pursue rule update as 

part of Control Measure MCS-01 – Application of All 

Feasible Measure Assessment if needed for ozone attainment. 

1

Industrial Cleaning Solvents (2006) Rule 1171 -

Solvent Cleaning 

Operations

District rule is more stringent than CTG. No further action is 

needed. 2

Large Appliance Coatings (2007); Metal 

Furniture Coatings (2007); and 

Miscellaneous Metal Products Coatings 

(2008)

Rule 1107 -

Coating of Metal 

Parts and Products

District rule is equivalent or more stringent than CTGs, thus 

no further action is needed. 2

Paper, Film, and Foil Coatings (2007) Rule 1128 - Paper, 

Fabric, and Film 

Coatings

District rule is more stringent than CTG. No further action is 

needed.1

Plastic Parts Coatings (2008) Rule 1145 - Plastic, 

Rubber, Glass 

Coatings

District rule is equivalent or more stringent than CTG. No 

further action is needed. 1

Auto and Light-Duty Truck Assembly 

Coatings (2008)

Rule 1115 - Motor 

Vehicle Assembly 

Line Coating 

Operations

CTG has more stringent limits for electro-deposition primer at 

84 g/L (145 g/L in Rule 1115); sprayable primer, primersurfacer, and topcoat at 144 g/L (180 g/L in Rule 1115); and 

trunk coatings, interior coatings, sealers, and deadeners at 650 

g/L (Rule 1115 provides an exemption for these categories). 

However, Rule 1115 has a small inventory of about 0.01 tpd, 

thus no action is needed. 1

Fiberglass Boat Manufacturing Materials, 

and Miscellaneous (2008)

Rule 1162 -

Polyester Resin 

Operations

The rule has an overall equivalency to CTG based on more 

stringent transfer efficiency requirements. No further action is 

needed. 2

Industrial Adhesives (2008) Rule 1168 -

Adhesives and

Sealants

CTG has more stringent limits for reinforced plastic composite 

at 200 g/L (250 g/L in Rule 1168); single-ply roof membrane 

adhesive primer at 250 g/L (450 g/L in Rule 1168); other 

adhesive primers at 250 g/L (420 g/L in Rule 1168); the 

control efficiency is 85% (80% in Rule 1168); and the work 

practices is limited only for stripping cured adhesives or 

sealants for Rule 1148. Staff may further pursue rule update 

as part of Control Measure MCS-01 – Application of All 

Feasible Measures Assessment or CTS-02 – Further Emission 

Reductions from Miscellaneous Coatings, Adhesives, Solvents 

and Lubricants if needed for ozone attainment. 3

Note: 1) Evaluation conducted by Hopps and Ono; 2) Evaluation conducted by Morris and Ono; 3) Evaluation 

conducted by Calungcagin and De Boer.
Final 2012 AQMP

VI - 11

Step 4 - Other Districts’ Current Rules and Regulations

Because the District is classified as extreme nonattainment for both the 1997 and 2008 

ozone standards, and nonattainment for both the 1997 and 2006 PM2.5 standards, the 

District staff commits to search for innovative control technologies, make 

improvements, and update the District’s rules and regulations as expeditiously as 

possible to effectively help the Basin reach the PM2.5 attainment in 2014-2019, and 

ozone attainment in 2024-2032. District staff’s envisioned that the control technologies 

available and cost-effective to be implemented in other local areas in California, or any 

other areas in the nation, would be available and cost-effective for use in the Basin in a

timely manner. 

To catch all the improvements on innovative control technologies and identify the areas 

for improvements in its rules and regulations, the District staff re-evaluated all the 

District’s source-specific rules and regulations, and compared the requirements in these 

rules with more than 100 rules recently adopted or amended by four local air districts in 

California from 2007 to 2012. The four air districts selected are San Joaquin Valley, 

Sacramento Metropolitan, Ventura, and San Francisco Bay Area. Staff selected these 

districts based on the severity of their nonattainment status and their near-term 

attainment dates as shown in Table VI-1 and Table VI-2.

The summary of this analysis is presented in Table VI-5. In this table, staff only listed 

the areas where the requirements in other local air district’s rules are more stringent than 

those in the District’s rules and regulations. The analysis in Table VI-5 shows that in 

general the District’s current rules and regulations are equivalent to or more stringent 

than those developed by other air districts. However, where improvements are possible, 

District staff has developed several control measures to further study the situations.

Details of the control measures, emission reductions, cost effectiveness, prioritization 

and implementation schedule are discussed in Chapter 4 and Appendix IV. The 

modeling results discussed in Chapter 5 has shown that the attainment for PM2.5 can be 

achieved with a few episodic additional control measures. With regards to the ozone 

attainment, the District has identified several control measures with estimated early 

emission reductions. The control measures of which emission reductions cannot be 

quantified will not be considered RACMs since they cannot be used collectively to 

estimate the advancement of the attainment date. 
Appendix VI: Reasonably Available Control Measures

VI - 12

Staff commits to fine-tune the emission inventory, emission reduction, and costeffectiveness analysis, especially during the rule development process. In addition, staff 

commits to monitor the rule development in other air districts and conduct further 

analysis if necessary, and has developed a catch-all Control Measure MCS-01 –

Application of All Feasible Measures Assessment to facilitate this activity. 

Step 5 - Other Districts’ Control Measures

In an effort to ensure that all feasible candidate control measures are considered, 

District staff evaluated more than 100 control measures adopted within the period of 

2007-2012 by eight nonattainment air districts in the nation for both PM2.5 and 8-hour 

ozone listed on Table VI-1 and Table VI-2, specifically Ventura, San Francisco Bay 

Area, San Joaquin Valley, Sacramento Metro in California, Dallas-Fort Worth and 

Houston-Galveston-Brazoria in Texas, New York and New Jersey. A summary of this 

evaluation is provided below.

Ventura

Ventura is classified as serious nonattainment for the 2008 8-hour ozone standard. In 

the 2006-2008 Final Triennial Assessment and Plan Update,11the Ventura County Air 

Pollution Control District conducted an analysis of all feasible control measures, and 

identified 7 new control measures in addition to the 15 control measures in the 

Ventura’s 2007 AQMP. In this list, there is only one new Ventura’s control measure 

described below that is more stringent than the requirements in the existing District’s 

rules:

Ventura adopted a control measure to eliminate the current vapor pressure limit (45 

mmHg) of low VOC spray gun cleaning and establish a new limit of 25 g/L VOC 

content for cleaning solutions used in aerospace assembly and component 

manufacturing operations, adhesives and sealants, marine coating operations, and 

pleasure craft coatings and commercial boatyard operations. Currently, the cleaning

solutions used in marine coating operations, pleasure craft coatings, and adhesives and 

sealants in the Basin are subject to District’s Rule 1171 limit of 25 g/L, and there is no 

vapor pressure limit in Rule 1171. However, the limit for cleaning solutions and 

strippers in District’s Rule 1124 – Aerospace Assembly and Component Manufacturing 

Operations are currently at 200 g/L (or 45 mmHg) and 300 g/L (or 9.5 mmHg), 

respectively, and there is a potential to reduce these limits. Further assessment will be 
Final 2012 AQMP

VI - 13

conducted through the District’s Control Measure CTS-02 – Further Emission 

Reduction from Miscellaneous Coatings, Adhesives, Solvents and Lubricants.

San Francisco Bay Area

San Francisco Bay Area is a nonattainment area for PM2.5 standard and a marginal

nonattainment for 8-hour ozone standards. On September 15, 2010, the Bay Area 

adopted the final Bay Area 2010 Clean Air Plan (CAP) 12to provide an integrated, 

multi-pollutant strategy to address ozone, PM, air toxics and greenhouse gases. The 

plan established 55 feasible control measures to be implemented in the 2010-2012 

timeframe in which there are 18 measures for stationary and area sources and 4 energy 

and climate measures. The following 6 Bay Area’s control measures are currently 

above and beyond the requirements in the existing District’s rules:

 Bay Area’s Control Measure SSM1 – Metal Melting, and Control Measure SSM6 –

PM Limitation proposed to reduce particulate emission limits and encourage the use 

of high efficiency filtration at foundry operations and metal melting facilities, and 

other facilities whenever appropriate. The Bay area has developed and proposed 

amended rule for SSM1 and scheduled for a Public Hearing in 2012. District staff 

will conduct further analysis study on this concept through the District’s Control 

Measure MCS-01 – Application of All Feasible Measures Assessment.

 Bay Area’s Control Measure SSM2 – Digital Printing proposed to control VOC 

emissions from digital printing. The Bay Area is currently collected emissions 

information from this fairly new category of printing, including solvent-based inkjet

printing and laser printing. It is forecasted to have 21% market share by 2025, and 

thus there will be a potential to reduce VOC emissions from this category. District 

staff will conduct further study on this concept through the District’s Control 

Measure MCS-01 – Application of All Feasible Measures Assessment.

 Bay Area’s Control Measure SSM5 – Vacuum Trucks requires carbon or other 

control technology on vacuum trucks to reduce emissions of VOCs. District staff 

will conduct further study on this concept through the District’s Control Measure 

FUG-01 – Further VOC Reductions from Vacuum Trucks.

 Bay Area’s Control Measure SSM9 – Cement Kilns, SSM10 – Refinery Boilers and 

Heaters, SSM11 - Glass Furnaces proposed to further reduce NOx from these source 
Appendix VI: Reasonably Available Control Measures

VI - 14

category. District staff will conduct further study through the Control Measure 

CMB-01 – Further NOx Reductions from RECLAIM.

 Bay Area’s Control Measure ECM1 – Energy Efficiency proposed 1) to promote 

education and training to increase awareness on energy efficiency; 2) to provide 

technical assistance to local governments and encourage them to adopt and enforce 

energy efficient building codes; and 3) to provide incentives for improving energy 

efficiency at schools. These concepts are similar to those described in the District’s 

Control Measure EDU-01 – Further Criteria Pollutant Reductions from Education, 

Outreach and Incentives.

 Bay Area’s Control Measure ECM2 - Renewable Energy proposed to promote 

distributed renewable energy generation (solar, micro wind turbines, cogeneration, 

etc.) on commercial and residential buildings, and at industrial facilities. These 

concepts are covered under the District’s Control Measure EDU-01 – Further Criteria 

Pollutant Reductions from Education, Outreach and Incentives.

The District already spearheaded in implementing other concepts in the Bay Area’s 

AQMP that called for reducing SO2 emissions from coke calciner and cement kilns; 

further controlling VOC emissions from livestock waste and natural gas production 

facilities; and NOx emissions from residential fan type furnaces, space heating, dryers, 

and ovens. The District also has an on-going program that promotes tree planting. 

Other Bay Area’s control measures addressing New Source Review, Air Toxics “Hot 

Spots” program, and greenhouse gases in permitting, are either administrative in nature 

or not related to criteria pollutants. 

San Joaquin Valley

San Joaquin Valley is extreme nonattainment with respect to 2008 8-hour ozone 

standards and nonattainment with respect to PM2.5 standards. Up to date, the San 

Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) has developed two 

separate plans to address the 8-hour ozone standards in 2007 and the 1997 PM2.5

standards in 2008. Recently, the SJVUAPCD developed a 2010 mid-course review for 

the ozone plan, and continued the feasibility study for several other measures such as 

refinery wastewater separators, refinery turnaround units, refinery vacuum devices and 

municipal water treatment plans. In addition, the SJVUAPCD is in the process of 

developing a plan to address the 2006 PM2.5 standards in cooperation with CARB and 

the District. District staff reviewed the list of control measures completed and listed in 
Final 2012 AQMP

VI - 15

the San Joaquin Valley’s 2010 mid-course review in comparison with the 2012 control 

measures recommended by the District. Overall, the District has either already 

implemented or developed control measures with similar concepts proposed in the 

SJVUAPCD plans. 13-15

Dallas-Fort Worth (DFW) Texas

The entire state of Texas is in attainment of the PM2.5 standards, but the state has two 

nonattainment areas with respect to the 8-hour ozone standards: the Dallas-Fort Worth 

and the Houston-Galveston-Brazoria. The DFW area was reclassified from a moderate 

to a serious nonattainment area for the 1997 8-hour ozone standard, and is moderate 

nonattainment with respect to the 2008 8-hour ozone. The area must attain the 1997 and 

2008 8-hour ozone standards by June 2013 and December 2018, respectively. In their 

previous SIPs, the Texas Commission on Environmental Quality (TCQE) identified 8 

new RACMs for area sources and point sources, and 6 of these measures were already 

implemented at the District. The remaining 2 measures, one for the cement kilns and 

one for the voluntary energy efficiency and renewable energy will be implemented 

through the District’s Control Measure CMB-01 – Further NOx Reductions from 

RECLAIM and Control Measure EDU-01 – Further Criteria Pollutant Reductions from 

Education, Outreach and Incentives.

16

After being reclassified from a moderate to a serious nonattainment area, TCQE 

conducted additional RACM analysis in 2011 and made a determination not to adopt any 

additional measures since modeling demonstrated that the area would be able to meet the 

attainment date of 2013 for the 1997 ozone standard. 

Houston-Galveston-Brazoria (HGB) Texas

The Houston-Galveston-Brazoria area was reclassified from moderate to a severe 

nonattainment area for the 1997 8-hour ozone standard, and classified as marginal for 

the 2008 8-hour ozone standard. The HGB area must attain the 1997 8-hour ozone 

standards by June 2019. The TCQE identified 11 RACMs for area sources and point 

sources. After being reclassified to severe nonattainment area, the TCQE conducted 

additional RACM analysis, analyzed additional 100 potential control measures, and 

determined that there is only one control measure that would help advance the 

attainment date for the HGB by one year. 17
Appendix VI: Reasonably Available Control Measures

VI - 16

This specific control measure calls for a 25% additional reduction of the facility’s highly 

reactive VOC (HRVOC) caps from the facilities which are located in the Harris County 

and regulated under the HRVOC Emissions Cap and Trade program. The HRVOC cap 

includes the emissions from cooling towers, process vents, and flares. The District does 

not have a VOC cap and trade program, nevertheless plans to further control emissions 

from flares and from process vents at specific facilities through the District’s Control 

Measure CMB-02 – NOx Reductions from Biogas Flares, FUG-01 – Further VOC 

Reductions from Vacuum Trucks, FUG-02 – Emission Reduction from LPG Transfer 

and Dispensing , and FUG-03 – Further VOC Reductions from Fugitive VOC 

Emissions. The District has no plan to further regulate the emissions from cooling 

towers at this stage.

New York Metropolitan

The New York Metropolitan Area is classified as nonattainment area or the 1997 annual 

PM2.5 standard of 15 μg/m3. All of the New York State is in compliance with the 1997 

24-hour PM2.5 standard of 65 μg/m3. To satisfy the requirement of the CAA, the New 

York Department of Environmental Conservation (NYDEC) finalized the final annual 

PM2.5 SIP in July 2008. 18In this final PM2.5 SIP, it was determined that modeling will 

be used to demonstrate attainment in 2010 taking into effect the emission reduction 

programs already in place, the control measures already proposed, and the contingency 

measures, if needed. The three stationary source control measures that are more 

stringent than the District’s existing rules are: 

19

 Portland Cement Plants. The NYDEC has revised its regulations for cement plants on 

June 11, 2010 to require case-by-case RACT analysis for cement kilns. The District 

selects to reduce cement kiln emissions through the District’s Control Measure 

CMB-01 – Further Reductions from NOx RECLAIM.

 Glass Furnaces. The NYDEC has revised its regulation for glass manufacturing 

facilities on June 11, 2010 to require case-by-case RACT analysis to potentially 

include control technologies such as oxy-fuel firing, low NOx burners, SCR, SNCR. 

The District selects to reduce emissions from glass furnaces through Control 

Measure CMB-01 – Further Reductions from NOx RECLAIM.

 Stationary Combustion Installations. The NYDEC has revised its regulation on June 

8, 2010 to include stricter, case-by-case RACT determination for major stationary 

sources that contain natural gas and/or oil-fired Industrial/Commercial/Institutional 
Final 2012 AQMP

VI - 17

boilers, or combined cycle/cogeneration combustion turbines. The Districts will 

reduce emissions from this category of sources through the District’s Control 

Measure CMB-01 – Further Reductions from NOx RECLAIM.

In addition, many counties in the New York state are nonattainment areas with respect to 

the 8-hour ozone standards. The NYDEC developed a comprehensive plan to address 

multi-pollutant attainment for criteria pollutants, greenhouse gases and toxics in June 

2010.

20 In addition to the control measures for cement kilns, glass furnaces, boilers and 

turbines addressed above, the NYDEC includes several measures for VOC Clean Air 

Interstate Trading of NOx and SO2. Some of the VOC measures are more stringent than 

the District’s existing rules which will be further analyzed under District’s Control 

Measure MCS-01 – Application of All Feasible Measures Assessment. 

New Jersey and Sacramento Metro

District staff also reviewed the control measures developed by Sacramento Metro and 

New Jersey Department of Environmental Protection for their 8-hour ozone plans. 

There are no additional new measure concepts that the District has not yet considered 

for this Final 2012 AQMP. 

21-24

 

Step 6 - Additional Studies and Analyses

In addition to all of the above analyses, SCAG, CARB, and the District have completed 

the following analyses to meet the requirements of the CAA:

 RACM analyses and demonstration conducted by SCAG and CARB for 

transportation and mobile sources control measures are included in Appendix IV-C 

and in the Attachment of this Appendix.

25

 

 Costs and cost effectiveness analyses, planning and scheduling to implement for each 

District’s stationary source and mobile source control measures, if available, are 

provided in Chapter IV, Appendix IV-A and B.
Appendix VI: Reasonably Available Control Measures

VI - 18

CONCLUSION

Following are the District staff’s findings:

 As required by the CAA and the U.S. EPA’s PM2.5 Implementation Rule, District 

staff evaluated and analyzed all feasible control measure concepts that were currently 

available for inclusion in the Final 2012 AQMP. These concepts were either 

provided by the public and experts, or recommended by U.S. EPA, or implemented 

by other air districts. From these concepts, District staff selected and developed 8 

short-term stationary source control measures to address the 24-hour PM2.5

attainment, 16 early-action stationary source control measures and 17 on-road and 

off-road control measures to address the 8-hour ozone attainment. District staff also 

developed a catch-all Control Measure MSC-01 – Application of All Feasible 

Measures Assessment to facilitate the inclusion of any incoming innovative air 

pollution control technologies or ideas that can help the Basin achieve the NAAQS 

as expeditiously as possible.

 Following the approach recommended by the U.S. EPA in the PM2.5

Implementation Rule, District staff conducted a study of more than 100 rules and 

regulations and 100 control measures recently developed in the 2007-2012 timeframe 

by other nonattainment air districts in the nation. In general, the District’s existing 

rules and regulations are equivalent to, or more stringent than other districts’ rules 

and regulations and their proposed control measures in their respective SIPs. In the 

few areas where the District’s rules can be amended to promote cleaner technologies, 

add additional best management practices, and improve enforceability, District staff 

has developed one or more control measures to facilitate these activities.

 The control measures that do not have estimated emission reductions cannot be 

considered RACMs, and the District commits to further conduct analyses to refine 

the emission inventory, emission reductions, and cost-effectiveness for these 

measures. The District’s ambient air quality data and modeling analysis in Chapter 3 

and Chapter 5 demonstrates that the Basin would be able to meet the 24-hour PM2.5

attainment date by 2014 with the implementation of a few episodic control measures

discussed in Chapter 4.

 With regards to the early actions to achieve ozone attainment, District staff has 

developed an effective menu of controls to meet the attainment dates as expeditiously 

as possible. The available control measures that District staff did not include would 
Final 2012 AQMP

VI - 19

not collectively advance the attainment date or contribute to the RFP because of the 

uncertain non-quantifiable amount of emission reductions that they may potentially 

generate. 

 In conclusion, the District has conducted the RACM/RACT analysis for identifying 

and selecting the control measures for the Final 2012 AQMP is in compliance with 

the requirements of the CAA, the U.S. EPA’s PM2.5 Implementation Rule, as well 

as the U.S. EPA’s policy and guidelines. 
Appendix VI: Reasonably Available Control Measures

VI - 20

REFERENCES

1. Approval of Air Quality Implementation Plans for the South Coast AQMP -

Attainment Plan for 1997 PM2.5 Standards. 40 CFR Part 52, Federal Register, 

Volume 76, No. 217. November 9, 2011.

2. Air Quality Designations for the 2008 Ozone National Ambient Air Quality 

Standards, 40 CFR Part 81, Federal Register, Volume 77, No. 98, page 30088. 

May 21, 2012.

3. Implementation of the 2008 National Ambient Air Quality Standards for Ozone: 

Nonattainment Area Classification Approach, Attainment Deadlines and 

Revocation of the 1997 Ozone Standards for Transportation Conformity Purposes, 

40 CFR Part 50 and 51, Federal Register, Volume 77, No. 98, page 30160. May 

21, 2012.

4. Clean Air Fine Particle Implementation Rule. 40 CFR Part 51, Federal Register, 

Volume 72, No. 79, page 20586. April 25, 2007.

5. Proposed Rule to Implement the Fine Particle National Ambient Air Quality 

Standards. 40 CFR Part 51 and 52, Federal Register, Volume 70, No. 210, page 

65984. November 1, 2005.

6. Implementation Guidance for the 2006 24-Hour Fine Particle (PM2.5) National 

Ambient Air Quality Standard (NAAQS) Memorandum from Stephen Page, 

Director of Office of Air Quality Planning and Standards (OAQPS) to Regional Air 

Directors, March 2, 2012.

7. Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality 

Standard. 40 CFR Part 51, 52, and 80, Federal Register, Volume 70, No. 228, page 

71612. November 29, 2005

8. Adopt SCAQMD 8-Hour Reasonably Available Control Technology State 

Implementation Plan, Agenda #37, Governing Board Meeting, July 7, 2006.

9. Revisions to the California State Implementation Plan, SCAQMD, 40 CFR Part 52, 

Federal Register, Volume 73, Number 244, page 76947, December 18, 2008. (U.S. 

EPA’s Approval of RACT Analysis for the 8-Hour Ozone SIP)
Final 2012 AQMP

VI - 21

10. U.S. EPA’s RACTs, http://www.epa.gov/ttn/naaqs/ozone/ctg_act/index.htm, as of 

May 29, 2012.

11. Ventura County Triennial Assessment and Plan Update, 2006-2008, June 14, 2011.

12. Bay Area Clean Air Plan, Bay Area Air Quality Management District, Adopted 

September 15, 2010.

13. San Joaquin Valley APCD, Draft 2012 PM2.5 Attainment Plan for 2006 PM2.5

Federal Standards, April 30, 2012.

14. San Joaquin Valley APCD, 2010 Ozone Mid-Course Review, June 2010

15. San Joaquin Valley APCD, 2008 PM2.5 Attainment Plan for 1997 PM2.5 Federal 

Standards, April 30, 2008.

16. List of Control Measures for Affected Areas in Texas, 

http://www.tceq.texas.gov/airquality/sip/sipstrategies.html#point.

17. SIP Revision for Houston–Galveston-Brazoria of Texas, Chapter 4 - Control 

Strategies and Required Elements, March 10, 2010, 

http://www.tceq.state.tx.us/assets/public/implementation/air/sip/hgb/hgb_sip_2009/

09017SIP_Ch4_ado.pdf

18. New York Department of Environmental Conservation, Final Revision of State 

Implementation Plan for PM2.5 for New York Metropolitan Area, July 10, 2008. 

http://www.dec.ny.gov/chemical/60541.html

19. New York Department of Environmental Conservation, Reasonably Available 

Control Measures Analysis in the Final Revision of State Implementation Plan for 

PM2.5 for New York Metropolitan Area, July 10, 2008. 

http://www.dec.ny.gov/chemical/60567.html

20. New York Department of Environmental Conservation, Air Quality Management 

Plan – Multi-Component Approach, Final Draft June 2010. 

http://www.dec.ny.gov/chemical/72352.html
Appendix VI: Reasonably Available Control Measures

VI - 22

21. 2009 Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further 

Progress, March 26, 2009. 

http://www.airquality.org/plans/federal/ozone/8hr1997/2009AandRFP/

22. 2011 Sacramento Regional 8-Hour Ozone Attainment and Reasonable Progress 

Plan, 

http://www.airquality.org/plans/federal/ozone/8hr1997/2009AandRFP/PlanAndAp

pendicesAfterSIPRevis-Clean.pdf, November 10, 2011.

23. The State of New Jersey Department of Environmental Protection - State 

Implementation Plan (SIP) Revision for the Attainment and Maintenance of the 

Fine Particulate Matter (PM2.5) National Ambient Air Quality Standard – PM2.5 

Attainment Demonstration, 

http://www.nj.gov/dep/baqp/pm25sip/PM2.5%20SIP%20Document%20Final%202

009.pdf. March 24, 2009.

24. The State of New Jersey Department of Environmental Protection - State 

Implementation Plan (SIP) Revision for the Attainment and Maintenance of the 

Ozone National Ambient Air Quality Standard – Ozone Attainment Demonstration, 

October 29, 2007. http://www.nj.gov/dep/baqp/8hrsip/Final_CompleteSIP.pdf

25. RACM/RACT Analysis for Transportation & Mobile Source Control Measures, emails communication between Pham of SCAQMD, Nadler of SCAG, and 

Ramalingan and Lawrence of CARB, dated May 24, August 15, August 22, and 

September 4, 2012.
Final 2012 AQMP

VI - 23

TABLE VI-5

Evaluation of SCAQMD Rules and Regulations - NOx and SOx Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1109 NOx Emissions of Oxides of 

Nitrogen from Boilers and 

Process Heaters – Petroleum 

Refineries (Amended 8/5/88)

0.03 lbs/mmBTU of heat input 

(~25 ppmv). Subsumed by 

RECLAIM. 

RECLAIM (Amended 1/2005):

 5 ppmv for >110 mmbtu/hr 

units 

 25 ppmv for units 40-100 

mmbtu/hr

San Joaquin Rule 4306 (Amended 

10/18/08) has the following limits:

NOx limits for refinery gas:

 5 ppmv for units >110 

mmbtu/hr; 

 25 ppmv for units 65-110 

mmbtu/hr; and

 30 ppmv for 5-65 mmbtu/hr 

units

San Joaquin Rule 4320 (Amended 

9/5/08) has the following limits for 

refinery gas: 

 5 ppmv for >110 mmbtu/hr units

 5 - 6 ppmv for units between 20 

- 110 mmbtu/hr

Compliance may be mitigated with 

annual emissions fee.

Further study the feasibility of 

lowering the NOx limits through:

CMB-01 – Further NOx Reductions 

from RECLAIM 

1110.2 NOx, 

VOC, 

CO

Emissions from Gaseous and 

Liquid Fueled Engines 

(Amended 7/9/2010)

Rule 1110.2 has NOx, VOC, CO 

limits for all stationary and 

portable engines over 50 brake 

horse power (bhp). 

In general, the limits applicable 

to 1) stationary, non-emergency 

engines by 7/1/2011, and 2) 

biogas (landfill and digester gas) 

engines by 7/1/2012 are:

San Joaquin Valley Rule 4702 

(Amended 8/19/2011) has NOx, 

VOC, CO and SOx limits for 

engines rated over 25 bhp.

For engines over 50 bhp:

- By 1/1/2017, the limits for 

spark-ignited engines are:

 11 ppmv NOx

Further study the feasibility of 

lowering the NOx limits through:

CMB-01 – Further NOx Reductions 

from RECLAIM 
Appendix VI: Reasonably Available Control Measures

VI - 24

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - NOx and SOx Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 

2007-2012 RULES

EVALUATION 

 11 ppmv NOx

 30 ppmv VOC

 250 ppmv CO

Limits for new non-emergency 

engines driving electrical 

generators are:

 0.07 lbs NOx per MW-hr

 0.20 lbs CO per MW-hr

 0.10 lbs VOC per MW-hr 

NOx limits for low usage biogas 

engines:

 36 ppmv, engines ≥ 500 bhp

45 ppmv, engines < 500 bhp

VOC and CO limits for low 

usage biogas engines:

 40 ppmv VOC, landfill gas

 250 ppmv VOC, digester gas

 2000 ppmv CO.

Portable and agricultural engines 

are not subject to the general 

limits listed above.

Many of Rule 1110.2 engines are 

in RECLAIM, and RECLAIM 

will be amended to incorporate 

feasible BARCT.

 250 ppmv VOC (rich-burn) 

and 750 ppmv VOC (lean 

burn), and

 2000 ppmv CO 

- Engines used in agricultural 

operations (AO), or fueled with 

waste gas, or limited used, or 

cyclic loaded and field gas 

fueled are subject to higher 

limits than the above

- In general, all compression 

ignited engines must meet EPA 

Tier 4 standards.

Engines between 25 bhp - 50 bhp, 

non agricultural operations (AO), 

must meet federal standards 

40CFR Part 60 Subpart IIII and 

JJJJ.

The SOx limits are: 1) Natural gas, 

propane, butane, LPG, or 

combination, or 2) 5 grains/100 scf 

for gaseous fuel, or 3) 15 ppmv 

liquid fuel, or 4) CA reformulated 

gasoline for spark-ignited engines, 

or 5) CA reformulated diesel for 

compression ignited engines, or 6) 

95% control.
Final 2012 AQMP

VI - 25

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - NOx and SOx Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1111 NOx NOx Emissions from 

Natural-Gas-Fired, Fan-Type 

Central Furnaces (Amended 

11/6/09)

40 nanograms per joule heat 

output until 2014. A lower 

standard of 14 ng/J is required 

with staggering compliance dates 

from 2014-2018. 

1112 NOx Emissions of Oxides of 

Nitrogen from Cement Kilns 

(Amended 6/6/86)

Applicable to gray cement only. 

11.6 lbs/ton clinker averaged 

over 24 hours and 6.4 lbs/ton 

clinker averaged over 30 days. 

Subsumed by RECLAIM.

RECLAIM, amended 1/2005 

version, had no recommendation 

for cement kiln BARCT. 

However, RECLAIM BARCT 

analysis is an on-going process 

and will be evaluated every three 

years.

Further study the feasibility of 

lowering the NOx limits through:

CMB-01 – Further NOx Reductions 

from RECLAIM 

1117 NOx Emissions of Oxides of 

Nitrogen from Glass Melting 

Furnaces (Amended 1/6/84)

4 lb/NOx per ton of glass pulled. 

Flat glass and fiberglass melting 

furnaces are exempt.

Many of these R1117 units are in 

RECLAIM. RECLAIM 

(Amended 1/2005 version) had 

no BARCT recommendation for 

this class. However, BARCT 

analysis is an on-going process 

and will be reevaluated every 

three years.

San Joaquin Rule 4354 – Glass 

Melting Furnaces (Amended 

5/19/2011) have NOx, CO, VOC, 

SOx limits. 

There are several options for the 

NOx limits:

 Container Glass: 1.5 lbs/ton 

(rolling 30-day average)

 Fiberglass: 1.3-3 lbs/ton (24-

hour average)

Further study the feasibility of 

lowering NOx limit through: 

CMB-01 – Further NOx Reductions 

from RECLAIM
Appendix VI: Reasonably Available Control Measures

VI - 26

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - NOx and SOx Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1117

(Cont.)

 Flat Glass: 2.9 lbs/ton (30-day 

average) – 3.7 lbs/ton (24-hour 

average)

The SOx limits are:

 Container Glass: 0.9-1.1lbs/ton 

(rolling 30-day average)

 Fiberglass: 0.9 lbs/ton (rolling 

24-hour average)

 Flat Glass: 1.2 lbs/ton (30-day 

average) – 1.7 lbs/ton (24-hour 

average)

The VOC limits are: 

 Container or Fiberglass: 0.25 

lbs/ton or 20 ppmv

 Flat Glass: 0.10 lbs/ton or 20 

ppmv.

1121 NOx Control of Nitrogen Oxides 

from Residential Type, 

Natural-Gas-Fired Water 

Heaters (Amended 9/3/2009)

15 ppmv at 3% O2, dry input (or 

10 ng/j output) for all stationary 

water heaters; and 55 ppmv at 

3% O2, dry input (40 ng/j 

output) for mobile water heaters.

Other Districts’ plans propose to 

accelerate replacements of old water 

heaters with electric units or new 

highly-efficient lower-emitting 

water heaters with the use of 

incentives.

Further study the possibility of using 

incentives to promote electric heaters 

through:

INC-01 – Economic Incentive 

Programs to Adopt Zero and NearZero Technologies [NOx]

In addition, further consider the 

feasibility of technology transfer 

through:

CMB-03 – Reductions from 

Commercial Space Heating
Final 2012 AQMP

VI - 27

TABLE VI-5

Evaluation of SCAQMD Rules and Regulations - NOx and SOx Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1134 NOx Emissions of Oxides of 

Nitrogen from Stationary 

Gas Turbines (Amended 

8/8/97)

Standard = Reference Limit x

(Unit Efficiency/25%), where 

reference limit depends on size 

of units, varying from 9 ppmv 

for units rating at equal to or 

larger than 10MW to 25 ppmv 

for units rating from 0.3 MW to 

less than 2.9 MW.

RECLAIM, amended 1/2005 

version, indicated that 5 ppmv 

was achieved in practice but not 

cost effective, therefore did not 

propose BARCT. This analysis 

may need to be revised based on 

new information. RECLAIM 

BARCT is an on-going process 

that is planned to be reviewed 

every 3 years.

Bay Area, Regulation 9, Rule 9 

(Adopted 12/6/06) contains the 

following limits:

 9 ppmv for units between 250-

500 mmBTU/hr and

 5 ppmv for units more than 500 

mmBTU/hr

San Joaquin Valley Rule 4703, 

(Amended 8/17/06) requires 3 

ppmv for combined cycle >10 

MW, and standards from 5 – 50 

ppmv for other units. 

Sacramento Rule 413 (Amended 

03/24/05) requires 9 – 25 ppmv 

depending on size of units, but are 

independent on equipment 

efficiency.

Ventura Rule 74.9 (Amended 

11/08/05) requires 25 – 125 ppmv 

depending on fuel type but are 

independent from equipment size 

and efficiency. Control efficiency 

90% - 96%. In addition, all units 

have to meet 20 ppmv NH3. 

Further study the feasibility of 

lowering the NOx standard and 

establish ammonia standard through:

CMB-01 – Further NOx Reductions 

from RECLAIM 

MCS-01 – Application of All 

Feasible Measures Assessment (for 

non-RECLAIM facilities)
Appendix VI: Reasonably Available Control Measures

VI - 28

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - NOx and SOx Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1135 NOx Emissions of Oxides of 

Nitrogen From Electric 

Power Generating Systems 

(Amended 7/19/91)

Mass emission limits and 

emission reduction goals for 

utility boilers. Only City of 

Glendale is subject to Rule 1135, 

which is allowed to meet 0.2 

lb/MW-hr (or a daily mass limit 

of 390 lb NOx per day, or an 

annual limit of 35 tons per year).

Other utility boilers are in 

RECLAIM subject to declining 

NOx allocations which were 

determined based on a level of 7 

ppmv = 0.07 lb/MW-hr = 0.008 

lb/mmbtu, assuming a heat rate 

of 8130 Btu/kw-hr. The utility 

boilers are operated at various 

BARCT levels from 5 - 30

ppmv. (Note)

Ventura Rule 59 (amended 

7/15/97) requires:

 0.1 lb NOx/MW-Hr for utility 

boilers and

 0.04 lb/MW-hr for auxiliary 

boilers.

San Joaquin Rule 4306 – Phase 3

(amended 3/17/2005) requires 

boilers more than 20 mmbtu/hr to 

comply with the following options:

 Standard option of 9 ppmv (or 

0.011 lb/mmbtu) complied by 

2005-2007, or 

 Enhanced option of 6 ppmv (or 

0.007 lb/mmbtu) complied by 

2006-2008. (Assuming a heat 

rate of 8130 Btu/kw-hr, 6 

ppmv is about 0.06 lb/MW-hr.)

Further study the feasibility of 

lowering the emission targets 

through:

CMB-01 – Further NOx Reductions 

from RECLAIM facilities

MCS-01 – Application of All 

Feasible Measures Assessment

Note: RECLAIM facilities have flexibility to operate their utility boilers provided that the total facility emissions must be at or below their allocations determined 

based on a level of 7 ppmv. Regarding BARCT levels, according to Marty Kay and John Yee, the utility boilers at Southern California Edison, Department of Water 

and Power, and City of Burbank are operated at a level from 5 – 7 ppmv (1-hr to 1-month average time) whereas City of Pasadena boilers are operated at a level of 30 

ppmv. In addition, since heat rate (mmbtu per kw-hr) varies with each utility boiler, District staff used 8130 BTU/kw-hr to convert the ppmv to lb/MW-hr for the unit 

operated by City of Glendale.
Final 2012 AQMP

VI - 29

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - NOx and SOx Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1146 NOx Emissions of Oxides of 

Nitrogen from Industrial, 

Institutional and Commercial 

Boilers, Steam Generators, 

and Process Heaters 

(Amended 9/5/2008)

Applicable to units rating of 

more than 5 mmbtu/hr.

Current NOx limits:

 For digester gas: 15 ppmv 

 For landfill gas: 25 ppmv

 For refinery gas: 30 ppmv 

(the 2008 amendment did not 

revise limits for refinery gas)

 For other types of fuels:

5 ppmv for ≥75 mmbtu/hr, 

natural gas; 30 ppmv for ≥75 

mmbtu/hr, other fuels; and 5 

or 9 ppmv for 20–75 

mmbtu/hr units

CO limit: 400ppmv

Many Rule 1146 units are in 

RECLAIM. RECLAIM 

(Amended 1/2005 version) 

contains the following NOx 

limits:

 For refinery gas:

5 ppmv for units > 110 

mmbtu/hr; and 25 ppmv for 

units < 110 mmbtu/hr units

 For other units: 

9 ppmv for units > 20 

mmbtu/hr; and 12 ppmv for 

units >2 mmBTU/hr

Sacramento Rule 411 (Amended 

10/27/05) limits for gaseous fuel 

are 9 ppmv for units greater than 

20 mmbtu/hr, and 15 ppmv for 

units from 5 to 20 mmbtu/hr.

San Joaquin Rule 4306 (Amended 

10/18/08) has the following limits:

NOx limits:

 30 ppmv for 5-65 mmbtu/hr 

units using refinery gas. For 

units from 40 – 100 mmbtu/hr, 

refer to the comparison under 

Rule 1109.

 For other types of fuels:

9 ppmv for >20 mmbtu/hr units; 

15 ppmv for ≤20 mmbtu/hr units

(6 – 9 ppmv for enhanced 

options)

 Other units: 15 – 30 ppmv

CO limit: 400 ppmmv.

San Joaquin Valley further reduces 

NOx, CO, SO2 and PM10 

emissions by adopting Rule 4320 

on 10/16/08. The limits in Rule 

4320 are:

Further explore the feasibility of 

lowering the NOx standards for Rule 

1146 (e.g. refinery fuels, digester and 

landfill gases) and RECLAIM 

through:

CMB-01 – Further NOx Reductions 

from RECLAIM 
Appendix VI: Reasonably Available Control Measures

VI - 30

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - NOx and SOx Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1146

(Cont.)

NOx NOx limits:

 For refinery gas:

5 – 6 ppmv for units between 

20-110 mmbtu/hr; 6 – 9 ppmv 

for units between 5 - 20 

mmbtu/hr; and 9 ppmv for units 

firing of less than 50% by vol

PUC quality gas. Refer to the 

comparison under Rule 1109 for 

40 mmbtu/hr units and above 

using refinery gas.

 For oil field generators:

5 - 7 ppmv for units greater than 

20 mmbtu/hr; 6 – 9 ppmv for

units larger than 5 but less than 

20 mmtu/hr; and 9 ppmv for 

units firing of less than 50% by 

vol PUC quality gas

 For low usage units: 9 ppmv

 For units at a wastewater 

treatment facilities firing on less 

than 50% by vol PUC quality 

gas: 9 ppmv

 For other units: 5 – 7 ppmv for 

units larger than 20 mmbtu/hr; 

and 6 – 9 ppmv for units 

between 5 mmbtu/hr and 20 

mmbtu/hr

Compliance may be mitigated with 

annual emission fees.
Final 2012 AQMP

VI - 31

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - NOx and SOx Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 2007-2012 

RULES

EVALUATION 

1146.1 NOx Emissions of Oxides of 

Nitrogen from Small 

Industrial, Institutional, and 

Commercial Boilers, Steam 

Generators, and Process 

Heaters (Amended 9/5/2008)

Applicable to units rating from 

2 mmbtu/hr to 5 mmbtu/hr. 

NOx limits:

 Atmospheric Units: 12 ppmv

 Digester gas: 15 ppmv

 Landfill gas: 25 ppmv 

 All others: 9 ppmv 

CO limit: 400 ppmv.

Many Rule 1146.1 units are in 

RECLAIM, and RECLAIM 

(Amended 1/2005 version) 

BARCT analysis recommended 

12 ppmv for less than 20 

mmbtu/hr units based on ultra 

low NOx technology that is 

achieved in practice. 

RECLAIM (Amended in 2005) 

has a limit of 12 ppmv NOx for 

boilers in this size range.

Bay Area Rule 9-11 (Amended 

5/17/00) has following limits for 

boilers using gaseous fuel 1) 10 

ppmv for boilers with rated input 

greater than 1.75 mmbtu/hr, 2) 25 

ppmv for boilers from 1.5-1.75 

mmbtu/hr, 3) 30 ppmv for boilers 

less than 1.5 million btu/hr. Nongaseous fuel combustion devices 

have higher limits than gaseous 

fuel devices.

San Joaquin Rule 4307 (Amended 

5/19/2011) has the following 

limits:

NOx limits:

- For New or Replacement Units:

Atmospheric Units: 12 ppmv, and 

Non-Atmospheric Units: 9 ppmv

-For Retrofit Units: 30 ppmv 

burning gaseous fuels; and 40 

ppmv burning liquid fuels

Sulfur limits for SO2: 

-For natural gas, propane, butane, 

or LPG: 5 grains of total sulfur 

per 100 scf, or 9 ppmv SO2, or

95% control

-For liquid fuels: 15 ppmv sulfur

Further study the feasibility of 

promoting the use of cleaner units 

through incentives through one of the 

following:

INC-01 – Economic Incentive 

Programs to Adopt Zero and NearZero Technologies [NOx]
Appendix VI: Reasonably Available Control Measures

VI - 32

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - NOx and SOx Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 

2007-2012 RULES

EVALUATION 

1146.2 NOx Emissions of Oxides of 

Nitrogen from Large Water 

Heaters and Small Boilers

(Amended 5/5/06)

Applicable to units less than 

2 mmbtu/hr. 

Current limits are:

 20 ppmv for units from 

400,000 btu/hr – 2 mmbtu/hr

 55 ppmv for units rating less 

than 400,000 btu/hr

San Joaquin Valley Rule 4308, 

(Amended 12/17/09) requires:

 20 ppmv for units used PUC 

gas from 75,000 btu/hr – 2 

mmbtu/hr

 30 ppmv for units from 400,000 

btu/hr - 2 mmbtu/hr used other 

types of fuels

 77 ppmv for units rating from 

75,000 btu/hr – 400,000 btu/hr 

used other types of fuels

Further study the feasibility of 

promoting the use of cleaner units 

through:

INC-01 – Economic Incentive 

Programs to Adopt Zero and NearZero Technologies [NOx]

2000 -

2015

NOx, 

SOx

RECLAIM (Amended 

5/6/05)

Include facility allocations for 

NOx and SOx for RECLAIM 

facilities. 

Since other Districts do not have 

RECLAIM, refer to comparison 

for individual rules such as Rule 

1146, 1146.1, 1110.2 etc.

Further review BARCT through:

CMB-01 – Further NOx Reductions 

from RECLAIM .

District has set most stringent 

BARCT for SOx sources in the 2010 

RECLAIM Amendments.
Final 2012 AQMP

VI - 33

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - VOC Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1106 VOC Marine Coating Operations

(Amended 1/13/95)

Coating-specific emission limits 

from 275 – 780 g/L. In lieu of 

complying with specific 

emission limits, operator can use 

air pollution control system with 

at least 85% efficiency. Solvent 

cleaning operations must comply 

with Rule 1171.

Ventura Rule 74.24 (Amended 

11/11/03) generally has the same 

limits as South Coast Rule 1106, 

except the limit for special 

marking of items such as flight 

decks, ship numbers is 420 g/L 

(490 g/L in Rule 1106)

Bay Area Rule 8-43 (Amended 

10/16/02) generally has the same 

limits as South Coast Rule 1106, 

except it has lower limit for 

pretreatment wash primer at 420 

g/L (780 g/L in Rule 1106)

Further study the potential of 

lowering the emission standards for 

this source category through:

CTS-02 – Further Emission 

Reductions from Miscellaneous 

Coatings, Adhesives, Solvents and 

Lubricants

1106.1 VOC Pleasure Craft Coating 

Operations (Amended 

2/12/99)

Coating-specific emission limits 

from 340 – 780 g/L. Solvent 

cleaning operations must comply 

with Rule 1171.

San Joaquin Valley’s Rule 4603 

(Amended 9/17/09) limit for teak 

primer, wood sealer, and clear 

wood varnish is 420 g/L, which is 

more stringent than the limits in 

Rule 1106.1 (i.e. 775 g/L for teak 

primer, 550 g/L for clear wood 

sealers, and 490 g/L for clear wood 

varnishes.) 

Further study the potential of 

lowering the emission standards for 

this source category through:

CTS-02 – Further Emission 

Reductions from Miscellaneous 

Coatings, Adhesives, Solvents and 

Lubricants 

1113 VOC Architectural Coatings 

(Amended 6/3/2011)

Coating-specific emission limits 

from 50 g/L – 730 g/L. Allow 

averaging, scheduled to be 

phased out on January 1, 2015.

Further study the potential of 

lowering the emission standards for 

this source category through:

CTS-01 – Further VOC Reductions 

from Architectural Coatings (R1113)
Appendix VI: Reasonably Available Control Measures

VI - 34

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - VOC Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1107 VOC Coating of Metal Parts and 

Products (Amended 1/6/06)

Coating-specific emission limits 

from 2.3 lbs/gal – 3.5 lbs/gal. In 

lieu of complying with specific 

emission limits, operator can use 

air pollution control system with 

at least 95% control efficiency

(or 5 ppmv outlet) and 90% 

capture efficiency. Solvent 

cleaning operations must comply 

with Rule 1171.

Ventura Rule 74.12 (Amended 

1/6/06) generally has the same 

coating-specific limits as South 

Coast Rule 1107, except in the 

following categories: 

 Limit for metallic coating is 3 

lbs/gal (3.5 lbs/gal in Rule 

1107);

 Limit for camouflage is 3 lbs/gal 

(3.5 lbs/gal in Rule 1107);

 Limit of pretreatment coatings is 

2.3 lbs/gal (3.5 lbs/gal in Rule 

1107)

 Overall minimum control 

efficiency is 90%, higher than 

Rule 1107 requirement at 85%

San Joaquin Valley Rule 4603 

(Amended 9/17/09) have more 

stringent limits than Rule 1107 for 

baked camouflage and baked 

metallic coating at 360 g/L (420 

g/L in Rule 1107)

Explore the feasibility of lowering 

the VOC limits considering the 

diversity of applications, and if 

feasible, implement through the 

following control measure:

CTS-02 – Further Emission 

Reduction from Miscellaneous 

Coatings. Adhesives, Solvents, and 

Lubricants, or

MSC-01 – Application of All 

Feasible Measures Assessment
Final 2012 AQMP

VI - 35

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - VOC Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1115 VOC Motor Vehicle Assembly 

Line Coating Operations

(Amended 5/12/95)

Limits from 1.2 lbs VOC/gal 

coating for electrophoretic 

primer to 15 lbs/gal of applied 

solids for primer, primer surfacer 

and topcoat. Cleaning operations 

must comply with Rule 1171.

San Joaquin Valley Rule 4602, 

(Amended 9/17/09) has more 

stringent limits for: 1) Primer at 

0.7 lbs/gal and 2) Primer surface 

and topcoat at 12 lbs/gal 

Further lowering the VOC limits

1118 All Refinery Flares (Amended 

11/4/05)

 Minimize flare emissions & 

require smokeless operations

 Specify SO2 gradually 

decreasing performance 

target to less than 0.5 tons 

per million barrels of crude 

by 2012.

 If the performance target is 

exceeded, the operator must 

1) pay mitigation fee; or 2) 

submit a Flare Mitigation 

Plan to reduce emissions.

 Require Cause Analysis for 

event exceeding 100 lbs 

VOC, 500 lbs of SO2, or 

500,000 scfm of vent gas, 

excluding planned shutdown, 

startup and turnarounds

 Require 160 ppmv H2S, 3 

hour average by 1/1/2009, 

and no limits for NOx, VOC, 

PM and CO.

U.S. EPA suggested the District to 

further re-evaluate Rule 1118 (FR 

Vol 76 No 217, Nov 9, 2011, CBE 

comments).

San Joaquin Valley Rule 4311 

(Amended 6/18/09) has VOC/NOx 

limits for ground-level enclosed 

flares; SO2 Targets (1.50 

tons/million barrels of crude by 

2011, and 0.5 tons/million barrels 

by 2012); Flare Minimization Plan 

for refinery flares more than 5 

mmbtu/hr; and operational 

requirements for all flares that 

have potential to emit more than 10 

tons/yr VOC and more than 10 

tons/yr of NOx. 

Bay Area Rule 12-12 (Adopted 

4/5/06) does not specify a 

declining SO2 target and does not 

contain a mitigation fee option.

Explore the possibility of further 

minimizing flare related events, 

through:

MSC-03 – Improved Start-Up, 

Shutdown and Turnaround 

Procedures

In addition, further study the 

feasibility of reducing emissions of 

landfill flares through:

CMB-02 – NOx Reductions from 

Biogas Flares
Appendix VI: Reasonably Available Control Measures

VI - 36

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - VOC Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1122 VOC Solvent Degreasers 

(Amended 5/1/09)

Contain various work practice 

and design requirements.

Further study to assess the feasibility 

of reducing emissions through:

CTS-02 - Further Emission 

Reductions from Miscellaneous 

Coatings, Adhesives, Solvents and 

Lubricants 

1124 VOC Aerospace Assembly and 

Component Manufacturing 

Operations (Amended 

9/21/01)

Coating-specific emission limits 

from 160 – 1000 g/L. Specific 

high transfer coating applications 

(e.g. HVLP spray). In lieu of 

complying with specific 

emission limits, operator can use 

air pollution control system with 

at least 95% control efficiency 

(or 50 ppmv outlet) and 90% 

capture efficiency. Solvent 

cleaning operations must comply 

with Rule 1171.

San Joaquin Valley Rule 4605 

(Amended 6/16/2011) has the 

following limits that are more 

stringent than those in Rule 1124: 

 Flight Test Coatings = 600 g/L 

(840 g/L in Rule 1124)

 Fastener Sealant = 600 g/L (675 

g/L in Rule 1124)

Sacramento Rule 456 (Amended 

10/23/08) has the following limits 

that are more stringent than those 

in Rule 1124: 

 Conformal Coating = 600 g/L 

(Rule 1124 limit is 750 g/L)

Explore the feasibility of lowering 

the VOC limits through:

CTS-02 - Further Emission 

Reductions from Miscellaneous 

Coatings, Adhesives, Solvents and 

Lubricants 
Final 2012 AQMP

VI - 37

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - VOC Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1124 

(Cont.)

 Fire Resistant Coatings = 600 

g/L. (Rule 1124 limits are 650 

g/L for Commercial; 800 g/L for 

Military)

 High-Temperature Coating = 

420 g/L. (Rule 1124 limit is 850 

g/L)

 Mold Release Coatings = 762 

g/L. (Rule 1124 limit is 780 

g/L)

 Radiation Effect = 600 g/L. 

(Rule 1124 limit is 800 g/L)

 Rain Erosion Resistant Coating 

= 600 g/L in All Other Category. 

(Rule 1124 limit is 800 g/L)

Ventura 2006-2008 Triennial 

Assessment and Plan Update has a 

control measure to require 25 g/L 

VOC limit for cleaning solutions 

and remove the 45 mmHg vapor 

pressure allowance. (Rule 1124 

limits for cleaning solutions and 

strippers are 200 g/L (or 45 mmHg 

vapor pressure) and 300 g/L (or 

9.5 mmHg vapor pressure)
Appendix VI: Reasonably Available Control Measures

VI - 38

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - VOC Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1125 VOC Metal Container, Closure, 

and Coil Coating Operations

(Amended 3/7/2008)

Coating-specific emission limits 

from 0 g/L (for non food cans) –

660 g/L. Specific high transfer 

coating applications (e.g. HVLP 

spray). In lieu of complying 

with specific emission limits, 

operator can use air pollution 

control system with at least 95% 

control efficiency (or 50 ppmv 

outlet) and 90% capture 

efficiency, which is equivalent to 

an overall control efficiency of 

85%. Solvent cleaning 

operations must comply with 

Rule 1171.

The following limit in San Joaquin 

Rule 4604 (Amended 9/20/07) are 

more stringent than those in Rule 

1125: 

 Two-Piece Interior Body Spray

= 420 g/L (440 g/L in Rule 

1125)

 Three-Piece Interior Body Spray

= 360 g/L (510g/L in Rule 

1125)

In addition, SJV Rule 4604 have 

many limits that are not listed in 

Rule 1125 such as 20 g/L for end 

seal compounds and 225 g/L for 

two-piece interior sheet base 

coating and over-vanish.

Sacramento Rule 452 (Amended 

9/25/2008) has the following more 

stringent limits than Rule 1125:

 Two-Piece Interior Body Spray

= 420 g/L (440 g/L in Rule 

1125)

 Three-Piece Interior Body Spray 

= 360 g/L (510g/L in Rule 1125)

Explore the feasibility of lowering 

the VOC limits through:

CTS-02 - Further Emission 

Reductions from Miscellaneous 

Coatings, Adhesives, Solvents and 

Lubricants, or

MSC-01 – Application of All 

Feasible Measures Assessment
Final 2012 AQMP

VI - 39

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - VOC Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1130 VOC Graphic Arts (Amended 

10/8/99)

VOC content limits: 80 g/l – 100 

g/l for fountain solution, 150 g/l 

for adhesives, 225 g/l - 300 g/l 

for inks and coatings. In lieu of 

meeting specific emission limits, 

control device with overall 

control efficiency from 75% -

85% can be used to achieve 

equal or better emission 

reductions.

VOC limits for cleaning 

solutions for printing presses are 

in Rule 1171 ranging from 25 g/l 

(0.21 lb/gal) for flexographic 

printing to 100 g/l (0.83 lb/gal) 

for lithographic printing (even 

though 500 g/l is allowed up to 

end of year 2007.)

The following limits in San 

Joaquin Valley Rule 4607 

(Amended 12/18/08) are more 

stringent: 1) 95% control 

efficiency for heat-set web offset 

lithographic or letterpress printers 

that emit greater than 25 tons per 

year VOC; 2) 1.6% VOC content 

for fountain solution used in heatset lithographic printers, 5% for 

fountain solution used in cold-set 

and sheet-fed lithographic printers, 

and 8% for fountain solution used 

in other presses. 

Sacramento Rule 450 is more 

stringent in the following: 1) 

overall control efficiency of 95% 

for heat-set web offset lithographic 

and letterpress printing and 80% 

for flexible package printing (Rule 

1130 requires only 75% control 

efficiency) ; 2) VOC in fountain 

solution is lower, generally from 

1.6% to 5%; 3) electronic circuit 

limit is 800 g/l (850 g/l in Rule 

1130.1)

Further study to assess the feasibility 

of increasing the overall control 

efficiency and reducing the alcohol 

usage in fountain solution through 

the implementation of:

MSC-01 – Application of All 

Feasible Measures Assessment
Appendix VI: Reasonably Available Control Measures

VI - 40

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - VOC Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1130 

(Cont.)

Bay Area, Regulation 8, Rule 20 

(Amended 11/19/08) requires 8% 

VOC content in fountain solution. 

In addition, the rule requires 

recordkeeping for digital printing, 

cleaning and stripping of UV or 

electron beam-cured inks for 

further study potential emission 

reductions in a near future.

Ventura Rule 74.19 (Amended 

6/14/11) requires low VOC content 

in fountain solution used in 

lithographic presses.

In addition, the U.S. EPA CTG for 

lithographic and letterpress, 

September 2006, recommends:

 Destruction efficiency of 90% 

to 95% depending on date of 

installation (or 20 ppmv outlet 

concentration) for heat-set web 

with potential to emit, prior to 

controls, of at least 25 tpy. 

 For operations emitting 15 

lb/day, fountain solution must 

be 1) 1.6% alcohol or less, or 
Final 2012 AQMP

VI - 41

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - VOC Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1130 

(Cont.)

2) 3% with refrigerated chiller 

or 3) 5% alcohol substitute for 

heat-set web presses; 4) 5% 

alcohol for sheet-fed presses; 5) 

5% alcohol substitute and no 

alcohol in fountain solution for 

cold-set web presses.

The EPA CTG for rotogravure and 

flexographic, adopted in 

September 2006, recommends 

control efficiency of 80% for 

presses installed after March 1995, 

and 65% - 75% for older presses.

1130.1 VOC Screen Printing Operations

(Amended 12/13/96)

VOC content limits ranges from 

400 g/l – 800 g/l for materials 

used in screen printing. In lieu 

of specific emission limits, 

control device can be used to 

achieve equal or better 

reductions, at least 95%.

Bay Area, Regulation 8, Rule 20 

(Amended 11/19/08) has more 

stringent limit for adhesives at 150 

g/L (400 g/L in Rule 1130.1).

Sacramento Rule 450 (Amended 

10/23/08) has more stringent limits 

than Rule 1130.1 in the following 

areas: 1) limit for electronic circuit 

ink is 800 g/L (850 g/L in Rule 

1130.1); 2) limit for adhesives is 

150 g/L (400 g/L in Rule 1130.1)

Further study to assess the feasibility 

of reducing the VOC limits for 

adhesives through:

MSC-01 – Application of All 

Feasible Measures Assessment
Appendix VI: Reasonably Available Control Measures

VI - 42

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - VOC Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1132 VOC Further Control of VOC 

from High Emitting Spray 

Booths (Amended 5/7/04)

Further reduce emissions by 65% 

from the baseline primarily 

through the installation of 

control devices, beyond and 

above the use of coatings that 

comply with existing coating 

rules.

1136 VOC Wood Products Coatings

(Amended 6/14/96)

VOC content limits range from 

2.3 – 6.3 lbs/gal VOC. 

Averaging provisions and add-on 

control are allowed. Transfer 

efficiency is at least 65%, or 

operator must use certain type of 

equipment (e.g. HVLP). Solvent 

cleaning operations must comply 

with Rule 1171.

Ventura Rule 74.30 (Amended 

6/27/06) has more stringent limit 

for high-solid stains on new wood 

products at 2 lbs/gal (2.9 lbs/gal in 

Rule 1136). In lieu of coating 

specific limits, control equipment 

achieving 90% efficiency is 

required. No averaging provisions 

in Ventura.

San Joaquin Valley Rule 4606 

(Amended 10/16/08) is more 

stringent in the following areas:

 Rule 1136 allows the use of a 

stripper with limits higher than 

350 g/L if the stripper has low 

vapor pressure of 2 mmHg. SJV 

does not have this allowance;

 SJV Rule 4606 requires a min

overall control efficiency of 

85% - 90% for flat wood 

paneling products, whereas Rule 

1136 does not have control 

efficiency requirement.

Explore the feasibility of lowering 

the VOC limits for wood products 

coatings through:

CTS-02 - Further Emission 

Reductions from Miscellaneous 

Coatings, Adhesives, Solvents and 

Lubricants, or

MSC-01 – Application of All 

Feasible Measures Assessment
Final 2012 AQMP

VI - 43

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - VOC Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1136

(Cont.)

Bay Area, Regulation 8, Rule 32, 

(Amended 8/5/09) has lower limits 

for surface preparation and 

cleanup, including stripping, at 

0.21 lbs/gal.

1144 VOC Metalworking Fluids and 

Direct-contact Lubricants 

(Amended 7/9/2010)

Various limits from 50 g/L – 340 

g/L. Add-on control at 90% 

capture efficiency, 95% control 

efficiency (or 5 ppmv outlet)

Further study the potential of 

lowering the VOC limits through:

CTS-02 - Further Emission 

Reductions from Miscellaneous 

Coatings, Adhesives, Solvents and 

Lubricants
Appendix VI: Reasonably Available Control Measures

VI - 44

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - VOC Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1151 VOC Motor Vehicle and Mobile

Equipment Non-Assembly 

Line Coating Operations 

(Amended 12/2/05)

VOC content limits range from 

250 – 840 grams VOC per liter. 

Averaging provisions are 

allowed. High transfer coating 

equipment (e.g. HVLP) is 

required. Solvent cleaning 

operations must comply with 

Rule 1171.

San Joaquin Valley Rule 4602 

(Amended 9/17/09) is more 

stringent in the following areas: 1) 

adhesive at 250 g/L (540 g/L in 

Rule 1151), 2) gasket/gasket 

sealing at 200 g/L (400 g/L in Rule 

1151), and 3) truck bed liner 

coating at 200 g/L (310 g/L in Rule 

1151)

Sacramento Rule 459 (Amended 

8/25/11) is more stringent in the 

following areas: 1) multi-color 

coating at 520 g/L for mobile 

equipment driven on rails (680 g/L 

in Rule 1151), 2) truck bed liner 

coating at 200 g/L (310 g/L in Rule 

1151)

Bay Area, Regulation 8, Rule 45 

(Amended 12/3/08) is more 

stringent in the following areas: 1) 

VOC limit for surface preparation 

and cleanup, including stripping, of 

0.2 lbs/gal or 2) a minimum 85% 

overall control efficiency.

Further study the feasibility of 

lowering the VOC limits for coatings 

through:

CTS-02 - Further Emission 

Reductions from Miscellaneous 

Coatings, Adhesives, Solvents and 

Lubricants, or

MSC-01 – Application of All 

Feasible Measures Assessment 

1162 VOC Polyester Resin Operations

(Amended 7/8/05)

VOC limits (monomer content) 

from 10-48% by weight or 

alternatively 90% control 

efficiency for add-on control

Regulation 8, Rule 50 (Amended 

12/2/09) is similar to Rule 1162, 

except the limit for corrosion 

resistant resin is more stringent at 

40% - 46% (48% in Rule 1162). 

The rule allows some usage of 

acetone

Further study the feasibility of 

lowering the VOC limits through:

MSC-01 – Application of All 

Feasible Measures Assessment
Final 2012 AQMP

VI - 45

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - VOC Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1168 VOC Adhesive and Sealant 

Applications (Amended 

1/7/05)

VOC limits for solvents range 

from 30 – 775 lbs VOC per 

gallon. Require the use of high 

transfer efficiency equipment 

(e.g. HVLP spray). In lieu of 

meeting the VOC limits, using 

add-on control with 80% control 

efficiency is allowed.

San Joaquin Valley Rule 4653 

(Amended 9/16/2010) has more 

stringent limits in the following 

areas:

 100 g/L for Cellulosic Plastic 

Welding Adhesive, 100 g/L for 

Styrene Acrylonitrile Welding 

Adhesive, and 200 g/L for 

Reinforced Plastic Composite 

Adhesive (Rule 1168 limit is 

250 g/L limits for all three 

categories)

 Minimum overall control 

efficiency is 85% (80% in Rule 

1168)

Further study the feasibility of 

lowering the VOC limits through:

CTS-02 - Further Emission 

Reductions from Miscellaneous 

Coatings, Adhesives, Solvents and 

Lubricants
Appendix VI: Reasonably Available Control Measures

VI - 46

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - VOC Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1171 VOC Solvent Cleaning Operations

(Amended 5/1/2009)

VOC limits for solvents are 25 

g/l in general, and have a 100-

800 g/l VOC for specific 

cleaning operations. In lieu of 

meeting the VOC limits, add-on 

control having 90% collection 

efficiency and 95% destruction 

efficiency or meeting 50 ppmv 

outlet concentration can be used. 

The rule however only requires 

(70%)(95%) = 66.5% overall 

control efficiency for graphic 

arts and screen printing 

applications

The U.S. EPA RACT published in 

September 2006 limit is 50 g/l or 

an overall control efficiency of 

85%. The U.S. EPA is not 

recommending limits beyond 50 

g/l; but also recommends states to 

adopt higher limits based on 

individual performance 

requirements of specific 

applications. Rule 1171 meets the 

U.S. EPA RACT.

Further study the feasibility of 

lowering the VOC limits and 

increasing the overall control 

efficiency requirement for control 

devices located at graphic arts 

facilities through:

CTS-02 - Further Emission 

Reductions from Miscellaneous 

Coatings, Adhesives, Solvents and 

Lubricants,

462 VOC Organic Liquid Loading 

(Amended 5/14/99)

Limit in Rule 462 is 0.08 lbs per 

1000 gallons of liquid loaded for 

Class A facility loading of 

20,000 gallons or more. This 

limit is not applicable to small 

facilities (Class B and C).

Bay Area, Regulation 8, Rule 33 

(Amended 4/15/09) has a limit of 

0.04 lbs/1000 gallons of liquid 

loaded and requires stringent 

monitoring requirements

Further study to assess the feasibility 

of reducing the VOC limits through:

MSC-01 – Application of All 

Feasible Measures Assessment
Final 2012 AQMP

VI - 47

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations – VOC, PM Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’ 

2007-2012 RULES

EVALUATION 

1133, 

1133.1, 

1133.2

PM, 

VOC, 

NH3

Composting, CoComposting, and Related 

Operations

(Rule 1133, Adopted 

1/10/2003; Rule 1133.1, 

Amended 7/8/2011; and 

Rule 1133.2, Adopted 

1/10/2003)

Various performance standards. 

Air pollution control must have 

80% control efficiency or 

greater. Existing operations 

must reduce up to 70% baseline 

VOC and ammonia emissions. 

Baseline emission factors are 

1.78 lbs VOC/ton throughput and 

2.93 lbs NH3/ton throughput.

San Joaquin Rule 4565 –

Biosolids, Animal Manure, and 

Poultry Litter Operations (Adopted 

3/15/07) and Rule 4566 – Organic 

Material Composting Operations 

(Adopted 8/18/11) have various 

operational requirements for these 

operations as well as the operators 

who landfills, composts, or cocomposts these materials. The 

applicability of Rules 4565/4566 is 

broader than the applicability of 

Rule 1133.3. In addition, Rules 

4565/4566 include additional 

mitigation measures to control 

VOC from composting active piles 

(e.g. maintain minimum oxygen 

concentration of 5%, moisture 

content of 40%-70%, carbon to 

nitrogen ratio of 20-1). San 

Joaquin’s rule does not address 

chipping & grinding as in Rule 

1133.1. 

Further study the feasibility of 

further control through:

MCS-02 – Further Emission 

Reductions from Green Waste 

Processing 

1133.3 VOC

NH3

Emission Reductions from 

Greenwaste Composting 

Operations (Adopted 

7/8/2011)

Include requirements for 

composting greenwaste, or 

greenwaste in combination of 

manure or foodwaste. Include 

various performance standards. 

Require air pollution control 

with efficiency of 80% or greater

for operations greater than 5000 

tons/year of foodwaste. For 

operations less than 5000 

tons/year, require the composting 

piles to be covered, watered, and 

turned, or operated with 

measures that reduce at least 

40% VOC emission and 20% 

NH3 emissions.
Appendix VI: Reasonably Available Control Measures

VI - 48

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - PM Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1138 PM Control Of Emissions From 

Restaurant Operations

(Amended 11/14/97)

Require catalytic oxidizer for 

chain-driven charbroilers. 

Exemption provided for underfired charbroilers and units 

cooking less than 875 lbs/week, 

but does not contain any specific 

limits.

San Joaquin Valley Rule 4962 

(Amended 9/17/09) requires the 

emissions from the restaurant 

charbroilers be controlled by 

catalytic oxidizer with minimum 

control efficiencies of 86% for 

VOC and 83% for PM10. 

Bay Area Regulation 6, Rule 2 

(Adopted 12/5/07) sets limit for 

both chain-driven charbroilers at 

1.3 lbs PM10 and 0.32 lbs ROG 

per 1000 lbs beef cooked) and 

under-fired charbroilers at 1 lbs 

PM10 per 1000 lbs beef cooked) 

Ventura Rule 74.25 (Adopted 

10/12/04) which has equivalent 

requirements as in Rule 1138.

Further study the feasibility of 

regulating under-fired charbroilers 

through:

BCM-03 – Emission Reductions 

from Under-Fired Charbroilers 

Note that the District has currently 

funded UCR - CE-CERT to 

investigate on the control 

technologies for under-fired 

charbroilers.
Final 2012 AQMP

VI - 49

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - PM Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

1155 PM Particulate Matter Control 

Devices (Adopted 

12/4/2009)

PM standards for PM control 

devices at 0.01 gr/dcsf for 

existing large baghouses >7500 

square feet. Good operational 

practices to reduce PM emissions 

Bay Area, Draft Regulation 12, 

Rule 13 is scheduled for a Public 

Hearing in summer of 2012. This 

rule is to implement Bay Area 

Control Measure SSM1 in the 

2010 Clean Air Plan. The rule is 

applicable to facilities that melt or 

process metals (foundries, forges, 

heat treatment of metals, and metal 

recycling operations). The focus is 

to promote the use of high 

efficiency filters (e.g. Gore-Tex 

bags). Proposed limits are:

 0.002 gr/dscf for flow rate of 

25,000 dscf per min or higher; 

and 

 0.004 gr/dscf for flow rates less 

than 25,000 dscf per min.

Further study the feasibility of 

lowering the PM limits through:

MCS-01 – Application of All 

Feasible Measures Assessment

444 All Open Burning (Amended 

11/7/2008)

Contains requirements and 

prohibitions for open burning to 

minimize emissions and smoke 

impacts to the public.

San Joaquin Valley Rule 4103 

(Amended 4/15/2010) contains 

additional best management 

practices compared to Rule 444 

such as best management practices 

to control open burning of weeds.

Bay Area, Reg 5, sets requirements 

for open burning, and was to forbid 

recreational burning during 

curtailment periods.

Further study to include additional 

good management practices and a 

possibility of restricting burning 

during episodic curtailment periods 

through:

BCM-02 – Further Reductions from 

Open Burning
Appendix VI: Reasonably Available Control Measures

VI - 50

TABLE VI-5 (continued)

Evaluation of SCAQMD Rules and Regulations - PM Rules

RULE TYPE RULE TITLE CURRENT RULE 

REQUIREMENTS

OTHER DISTRICTS’

2007-2012 RULES

EVALUATION 

404, 

468, 

and 

469

PM Rule 404 – Particulate 

Concentration (Amended 

2/7/86)

Rule 468 – Sulfur Recovery 

Units (Amended 10/8/76)

Rule 469 – Sulfuric Acid 

Units (Amended 2/13/81)

PM limits vary from 0.01gr/dscf 

to 0.19 gr/dscf in Rule 404

depending on exhaust flow rates.

Sulfuric acid mist limit in Rule 

469 is 0.3 lbs per ton of acid 

produced (approximately 0.1 

gr/dscf)

Rule 468 for sulfur recovery 

units does not contain any PM 

standard.

Bay Area, Regulation 6, Rule 1 

(Adopted 12/5/07) contains the 

following limits:

 Generally, PM limit is 0.15 

gr/dscf

 Sulfuric Acid Manufacturing 

Plants: limit sulfur trioxide or 

sulfuric acid mist, or both, 

expressed as 100% sulfuric acid, 

to 0.04 gr/dscf

 Sulfur Recovery Units: limit 

sulfur trioxide or sulfuric acid 

mist, or both, expressed as 100% 

sulfuric acid, to 0.08 gr/dscf

Further study the feasibility of 

reducing the emission limits through:

MCS-01 – Application of All 

Feasible Measures Assessment

445 PM Wood Burning Devices 

(Adopted 3/7/08)

Contains requirements for wood 

burning devices to minimize 

emissions and smoke impacts to 

the public. 

San Joaquin Valley Rule 4901 

(Amended 10/16/2008) contains 

additional best management 

practices compared to Rule 445.

Further study to include additional 

good management practices and the 

possibility of restricting burning 

during the episodic curtailment 

periods through:

BCM-01 – Further Reductions from 

Residential Wood Burning Devices
Final 2012 AQMP

VI - 51

ATTACHMENT

CALIFORNIA AIR RESOURCES BOARD

Mobile Source RACM Analysis for the South Coast 2012 Final AQMP

Given the significant emission reductions needed for attainment in California, ARB has adopted 

some of the most stringent control measures nationwide for on-road and off-road mobile sources 

and the fuels that power them. These measures target both new and in-use equipment. And 

while California first focused on cleaning up cars – new car emissions have been reduced by 99 

percent – the scope of California’s program is vast. The State has implemented regulations and 

programs to reduce emissions from freight transport equipment, including heavy-duty trucks, 

ocean going vessels, locomotives, harbor craft, and cargo handling equipment. In addition, the 

State has standards for lawn and garden equipment, recreational vehicles and boats, and other 

newly manufactured off-road equipment. California has also adopted many measures that focus 

on achieving reductions from in-use mobile sources that include accelerated replacement of older 

equipment with newer, less polluting equipment; more stringent inspection and maintenance 

requirements; and operational requirements such as truck and bus idling restrictions and speed 

reduction requirements for ocean going vessels.

California has unique authority under Clean Air Act section 209 to adopt and implement new 

emission standards for many categories of on-road vehicles and engines, and new and in-use offroad vehicles and engines. Use of this authority is subject to U.S. EPA waiving the applicable 

federal standard upon their finding that the standards adopted by California are, in the aggregate, 

at least as stringent as the comparable federal standard. 

To support the attainment plans submitted to U.S. EPA in 2007 for 8-hour ozone and PM2.5, 

ARB undertook an extensive public consultation process to identify potential SIP measures. 

New measures developed by ARB as part of this 2007 State Strategy focused on cleaning up the 

in-use fleet, and increasing the stringency of emissions standards for a number of engine 

categories, fuels, and consumer products. These measures build on ARB’s already 

comprehensive program that addresses emissions from all types of mobile sources.

In 2011, U.S. EPA approved the State mobile source control program as being RACM in the 

context of the 2007 and 2008 South Coast and San Joaquin Valley PM2.5 plans (76 FR 69928 at 

69933). In its proposed approval of the 2007 South Coast PM2.5 Attainment Plan, U.S. EPA 

recognized that the “State of California has been a leader in the development of some of the most 

stringent control measures nationwide for on-road and off-road mobile sources and the fuels that 

power them” (76 FR 41562 at 41570). In the 2007 State Strategy, ARB identified and committed 
Appendix VI: Reasonably Available Control Measures

VI - 52

to propose new defined measures for the sources under its jurisdiction. Of these new measures, 

U.S. EPA noted that “many, if not most, of these measures are being proposed for adoption for 

the first time anywhere in the nation” (76 FR 41562 at 41570).

California’s comprehensive mobile source program continues to be RACM as it expands and 

further reduces emissions. The 2012 PM2.5 SIPs rely on additional regulations adopted since the 

State’s last major SIP revision in 2007. In January 2012, ARB adopted the Advanced Clean Cars 

program, which combines the control of smog-causing pollutants and greenhouse gas emissions 

into a single coordinated package of requirements for model years 2017 through 2025. The 

program was developed in tandem with the federal government over several years, including a 

joint fact-finding process with shared engineering and technical studies. Benefits from this new 

program are reflected in emission inventories used in the 2012 PM2.5 attainment plans.