1

Tong, Stanley

From: Joe Cassmassi <jcassmassi@aqmd.gov>

Sent: Tuesday, November 25, 2014 1:13 PM

To: Tong, Stanley

Subject: SCAQMD RACT Analysis Draft 20141119 (2)

Attachments: SCAQMD RACT Analysis Draft 20141119 (2).doc
1 

Updates on November 18, 2014 

Based on the 2012 Annual Emission Report (AER), 211 facilities emitted more than 10 tpy of 

VOC or NOx in SCAQMD and are considered major sources. 203 major source facilities are 

identified in the 2013 AER. 

Rule 1115 Motor Vehicle Assembly Line Coating Operations 

Background: Rule 1115 is not as stringent as the 2008 EPA CTGs for a few coating processes for 

facilities emitting > 15 lbs/day. CTG has more stringent limits for electro-deposition primer at 

84 g/L (145 g/L in Rule 1115); sprayable primer, primer-surfacer, and topcoat at 1440 g/L (1800 

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). 

Analysis: Six facilities are subject to Rule 1115 in SCAQMD. Three of the 6 facilities reported 

VOC emissions of more than 15 lbs/day. They account for a small inventory of about 0.031 tpd. 

One facility, emitting 0.45 lbs/day under Rule 1115, is a major source. EPA CTGs highlight two 

major VOC emission sources in auto and light-duty assembly coating: coating and cleaning 

activities. While CTGs provide only work practice recommendations for cleaning materials, 

SCAQMD has strict emission limits on solvent cleaning procedures (Rule 1171, emission limit = 

25 g/L for general solvent cleaning). 

Conclusion: Together with Rule 1171 (Solvent Cleaning Operations, general limit = 25 g/l), Rule 

1115 meets the federal RACT requirements. 

2012 VOC Emissions 

Name lbs/year tpd 

AMREP INC 9906 0.014 

THE PAINT DEPARTMENT 6919 0.009 

ELDORADO NATIONAL 5897 0.008 

MERCEDES-BENZ 4773 0.007 

TABC, INC 578 0.001 

U.S. GOVT, DEPT OF NAVY 164 0.000 

Grand Total 28237 0.039 
2 

Rule 1118 Control of Emissions from Refinery Flares 

Background: SJVAPCD Rule 4311 (amended 6/18/09) regulates flares emitting greater than 10 

tpy of VOC or NOx with the exemption of municipal solid waste landfills. SCAQMD Rule 1118 

covers flare emissions from refineries, sulfur recovery plants and hydrogen production plants. 

Analysis: Other than refinery flares, SJVAPCD identified flare events in the following industries: 

wastewater treatment plans, cheese production, wine, dairy operations, flat glass production and 

correctional facility1. Staff evaluated potential flare emissions from sources other than refineries, 

sulfur recovery plants, hydrogen production plants and municipal solid waste landfills in 

SCAQMD. Wastewater treatment plant is another source category with potential flare emissions 

of greater than 10 tpy of VOC or NOx. In 2012, 5 major source wastewater treatment facilities 

used flares. Total VOC emission was 0.015 tpd and 92% was attributable to Hyperion Treatment 

Plant. 

Conclusion: Rule 1118 was determined to fulfill RACT requirements in April 20072. In the 

evaluation of the recent revision of SJVAPCD Rule 4311 in August 2011, EPA determined 

SJVAPCD Rule 4311 to be as stringent as requirements in SCAQMD Rule 11183. Flare 

emissions from wastewater treatment plants (not covered in Rule 1118) have a small inventory of 

about 0.015 tpd. 

Next step: 

Rule 1118 appears to be RACT and given this determination there does not appear to be any 

reason to further analysis. If the EPA determination does not provide a basis for Rule 1118 as 

representing RACT, then 

1. Identify the major source with flare other than refineries, landfills and wastewater 

treatment plant. 

 2012 VOC Emissions 

Name lbs/year tpd 

LA CITY, SANITATION BUREAU (HTP) 10269 0.0141 

LA CITY, TERMINAL ISLAND TREATMENT PLANT 136 0.0002 

LA CO. SANITATION DIST 17 0.0000 

ORANGE COUNTY SANITATION DISTRICT 689 0.0009 

Grand Total 11110 0.0152 
3 

Rule 462 Organic Liquid Loading 

Background: Bay Area, Regulation 8, Rule 33 (Amended 4/15/09) regulates VOC emissions 

from gasoline bulk terminals with an emission limit of 0.04 lbs per 1000 gallons of liquid loaded. 

The limit in SCAQMD 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). Rule 462 regulates emissions from additional sources, including chemical plants, that load 

organic liquid with a vapor pressure above 1.5 psia. 

Analysis: In BAAQMD, the VOC emissions are 0.52 tpd from gasoline bulk terminals in 2008. 

Eight of the 13 gasoline bulk terminals in BAAQMD are regulated under the BACT limit of 

0.02-0.04 lbs per 1000 gallons of gasoline loaded. Source test results showed that 12 of the 13 

gasoline bulk terminals are in compliance of their (then) proposed limit of 0.04 pounds of 

organic compounds per 1,000 gallons of liquid loaded. Based on the above information, the cost 

of reductions was $13,200 per ton for BAAQMD. In SCAQMD, Rule 462 applies to 23 major 

source bulk loading terminals, and 8 out of 23 facilities are regulated under the emission limit of 

0.02 to 0.065 lbs per 1000 gallons. Source test results for 9 bulk loading terminals in SCAQMD 

showed that mass emission rates were in the range of 0.0004 to 0.029 lbs per 1000 gallons, well 

below their corresponding emission limits. According to the 2012 emission inventory, organic 

liquid loadings in major source bulk loading terminals accounted for about 0.33 tpd of VOC 

emissions. Since the emissions in the SCAQMD are smaller than those in the BAAQMD, the 

cost per ton would likely be higher. 

Conclusion: Rule 462 has more stringent requirements than those stated in federal CTGs and 

meets the core requirements of RACT. Although it may not be as stringent as Bay Area 

Regulation 8-33 with respect to the emission limit for Class A facilities, Rule 462 covers 

additional emission sources (chemical plants) and types (organic liquid such as ethanol and 

kerosene). 
4 

Rule 223 Emission Reduction Permits for Large Confined Animal Facilities 

Background: Rule 223 applies to large confined animal facilities (CAF). It requires 

owners/operations to obtain a permit describing the control strategies the facility chooses to 

implement from a list of mitigation measure (Class One and/or Class Two) requirements. Class 

One menu options includes a mitigation measure or combination of measures for the specific 

source category that, at the time of rule adoption, are considered to be the best available retrofit 

control technology (BARCT), as defined in the California Health and Safety Code Section 

40406. Class Two measures are considered to be more stringent than BARCT. Administrative 

requirements such as recordkeeping and noticing are also required. SJVAPCD Rule 4570 

(Amended 10/21/10) regulates both large and medium CAF, and its timeframe for feeding total 

mixed rations in the dairy feed menu is 2 hours. This is more restricted than the 24 hours 

timeframe in SCAQMD Rule 223. Rule 4570 also specifies both mandatory and optional 

mitigation measures.

Analysis: As the largest agricultural area in California, SJVAPCD Rule 4570 requires facilities to 

choose more mitigation measures and makes several mitigation measures mandatory. Rule 4570 

mitigation measures have been approved by EPA as BACT4. The mitigation measures in 

SCAQMD are mostly comparable to the ones in Rule 4570, but Rule 223 requires no mandatory 

measures. In 2010, SJVAPCD revised Rule 4570 to lower the regulatory threshold for dairy and 

poultry facilities and place more emphasis on silage emissions. Dairies in San Joaquin are larger 

and use wet silage operations. In SCAQMD, much of the feed is dried, bailed and shipped to 

local dairies. The dry feed has very low moisture content and thus negligible VOC emissions. 

Therefore, the more stringent feeding requirements in SJVAPCD Rule 4570 would not result in 

significant emission reduction if implemented in SCAQMD. In 2010, SJVAPCD also lowered 

the applicability threshold of dairies (500 milk cows in SJV vs. 1000 milk cows in SCAQMD) 

and poultry (400,000 birds in SJVAPCD vs. 650,000 birds in SCAQMD) to cover all major 

sources. In SCAQMD, facilities that fall between these applicability thresholds are not major 

source facilities (2012 AER). Additionally, SCAQMD regulates emissions from livestock waste 

through Rule 1127, which requires best management practices for dairies regarding manure 

removal, processing, and composting. Rule 1127’s minimum regulatory threshold of 50 cows, 

heifers, and/or calves is significantly lower than Rule 4570 (500 milk cows, 7500 heifers, calves 

and/or other support stock). 

Conclusion: Since the dairies in SCAQMD are largely dry feed lot operations, the more stringent 

control measures of silage emissions in SJVAPCD are not applicable in SCAQMD. Given the 

lack of CTGs/ACTs for CAF and considering the general national RACT policy and precedent, 

the Class One and Class Two mitigation measures in Rule 223 ensures that controls that are 

economically and technically feasible are required and therefore Rule 223 meets the core 

requirements of RACT. 
5 

Rule 1148.1 Oil and Gas Production Wells 

Background: VCAPCD’s Rule 71.5 (Adopted 12/13/94) controls reactive organic compound 

(ROG) emissions from glycol dehydrators used in natural gas dehydration through 

condenser/vapor disposal, flare/incinerator, or emission control system that controls glycol 

regenerator vent ROC emissions by at least 95%. In SCAQMD, VOC emissions from 

wellheads, well cellars and untreated produced gas at oil and gas production operations are 

subject to Rule 1148.1. This rule requires concentration of total organic compounds (TOC) to be 

≤ 500 ppm in well cellar, and other good management practices for the storage and transfer of 

organic liquids. Emissions of produced gas shall be collected and controlled by a system 

handling gas for fuel, sale, or underground injection; or a device with a VOC vapor removal 

efficiency demonstrated to be at least 95% by weight or by demonstrating an outlet VOC 

concentration of 50 ppm. 

Analysis: SCAQMD emissions from glycol dehydrators are regulated under Rules 1148.1 (Oil 

and Gas Production Wells). The 95% control efficiency in Rule 1148.1 is as stringent as VC 

Rule 71.5. VOC leaks and releases from components at petroleum facilities are regulated under 

Rule 1173. Both Rule 1148.1 and Rule 1173 were determined to fulfill RACT requirements by 

the US EPA in August 20115and March 20106, respectively. 

Conclusion: VOC emission from glycol dehydrations in oil and gas production is regulated under 

Rule 1148.1 and Rule 1173; both rules fulfill the federal requirements of RACT. 
6 

Rule 2002 Allocations for Oxides of Nitrogen (NOx) and Oxides of Sulfur (SOx) 

Background: BAAQMD, Regulation 9, Rule 13 (Adopted 9/17/12) limits the emissions of 

nitrogen oxides, particulate matter, and toxic air contaminants from the manufacture of Portland 

cement. According to this rule, the 30-operating day rolling average of nitrogen oxides (NOx) 

emissions from the kiln must not exceed 2.3 pounds per ton of clinker produced. In SCAQMD, 

NOx emission is regulated under the RECLAIM (REgional CLean Air Incentives Market) 

Program. According to RECLAIM Rule 2002, cement kilns’ current BARCT emission limit is 

2.73 lb NOx per ton clinker. Within the SCAQMD, there is only one facility with two Portland 

cement kilns. 

Analysis: The current NOx emission rate limit for cement kilns in SCAQMD is slightly higher 

when compared to BAAQMD Regulation 9, Rule 13 (2.73 vs. 2.3 lbs/ton of clinker). The 

SCAQMD averaging time for the NOx limit is one year using a continuous emission monitoring 

system while BAAQMD is 30 days. Staff is proposing a NOx limit of 0.5 lb NOx per ton of 

clinker. The regulated facility has proposed that BARCT should be 1.5 – 1.8 lb NOx per ton of 

clinker. Both NOx limits are below the BAQMD Regulation 9 limit. The proposed amendment 

to the NOx RECLAIM is currently underway and schedule for completion by the second quarter 

of 2015. 

Conclusion: Under the proposed amendment to Rule 2002, the federal RACT requirements for 

Portland cement kilns would be achieved. 
7 

References 

1 Rule 4311 (Flares) Further Study. San Joaquin Valley Air Pollution Control District. 

September 16, 2014.

2

 Technical Support Document for EPA's Notice of Direct Final Rulemaking on revisions to the 

California State Implementation Plan- EPA's Analysis of South Coast Air Quality Management 

District's Rule 1118, Control of Emissions from Refinery Flares. United States Environmental 

Protection Agency, Region IX, April 2007. 

3 Technical Support Document for EPA's Notice of Direct Final Rulemaking on revisions to the 

California State Implementation Plan- EPA's Analysis of San Joaquin Valley Unified Air 

Pollution Control District’s Rule 4311, Flares. United States Environmental Protection Agency, 

Region IX, August 2011. 

4 Final Draft Staff Report, Amended Revised Proposed Amendments to Rule 4570 (Confined 

Animal Facilities), Appendices G, October 21, 2010. 

5

 Technical Support Document for EPA’s Direct Final Rulemaking for the California State 

Implementation Plan- South Coast Air Quality Management District Rule 1148.1 Oil and Gas 

Production Wells, United States Environmental Protection Agency Region IX Air Division, 

August 2011.

6

 Technical Support Document for EPA’s Direct Final Rulemaking for the California State 

Implementation Plan- South Coast Air Quality Management District Rule Rule 1173, Controls of 

Volatile Organic Compound Leaks and Releases from Components at Petroleum Facilities and 

Chemical Plants, United States Environmental Protection Agency Region IX Air Division, 

March 2010.