## Antelope Valley Air Quality Management District 43301 Division St., 

## Suite 206 

# Lancaster, CA 93535-4649 661.723.8070 Fax 661.723.3450 Eldon Heaston, Executive Director 

# March I3 , 2014 Andrew Steckel Chief, Rules Office United States Environmental Protection Agency, Region IX 75 Hawthorne Street San Francisco, CA 94I05 

# Re: 8
-hour Ozone Reasonably Available Control Technology RACT State Implementation Plan (SIP) Analysis
- Supplemental Analysis Dear Mr. Steckel : The Antelope Valley Air Quality Management District (District) greatly appreciates the assistance provided by your staff in 

# suggesting improvements to the District's RACT SIP analysis. After extensive discussions with USEPA staff, the District has prepared the attached supplemental RACT SIP analysis. This supplemental analysis addresses the comments provided in your September II , 2006 comment letter, analyzes the specific rules and Control Technique Guidelines (CTGs) delineated in Tables I and 2 ofyour comment letter, and addresses applicable CTGs that have been finalized since your comment letter was prepared, as directed by your staff. This supplemental analysis also represents the final District RACT action list, replacing the RACT action list presented in the 2006 RACT SIP Analysis document. Subsequent to the 2006 RACT SIP Analysis document, the District has completed several significant RACT actions (most notably gasoline transfer and dispensing, aerospace assembly and component manufacturing, graphic arts, gas turbines, and control ofVOC from adhesive application rule makings). As specified in Section 182 ofthe Federal Clean Air Act, the District will continue promulgating RACT action rulemakings, and will update the RACT SIP Analysis in response to the current federal ozone standard revision. Ifyou have any questions regarding this letter, please contact me at (760) 245-I66I, extensi on 6726.

Supervising Air Quahty Engineer AJD/tw 

## RACT SIP Supplement 

# €te<ru Cities Antelope 

# ...,,ley2014 Supplement to the 2006 AVAQMO RACT SIP Analysis Rule Reason for Analysis Determination Action Rule 46 1 · Gasoline Transfer and Dispensi ng EP A Request-Table 1 District amended Rule 46110/21/2008
. SIP approved as RACT, 76 No action required
. FR 5277, 01/31/2011. Tabl e 1 , item 6 of the EPA comment letter asked for identification of wh ich District rule was reviewed on the RACT Evaluation Table
. Upon review, it was determined that Rule 462 required further Rule 462 · Orga n ic Liquid loading EPA Req u est-Tab le 1 evaluat ion from the "Tank" section of the Rule Evaluation Table as Update rule. it had not been properly identified. Update Rule 462 to address deficiencies in the limited Approval/limited Disapproval in the NPRM Issued 05/14/1997 (62 FR 26460, 05/14/1997). Table 1, item 6 of the EPA comment letter asked for identification of which District rule was reviewed on the RACT Evaluation Table. Upon review, it was determined that Rule 463 required further evaluation from the "Tank" section of the Rule Eva l uation Table as it had not been properly identified
. Review of the AVAQMD RACT SIP Analysis and the Federa l Negative Declaration for Three Rule 463 · Organic liquid Storage EPA Requ est-Table 1 Source Categories includes Storage of Petroleum liquids in Fixed · Update rule and remove FND. Roof Tanks and Petroleum liquid Storage in Externa l Floating Roof Tanks (CTGs referenced: Control of Volatile Organic Emissions from Storage of Petroleum liqu ids in Fixed-RoofTan ks (EPA-450/2 77-036, 12/77) and Control ofVoaltile Organic Emissions from Petroleum Liquid Storage in External Floati ng Rood Tanks (EPA· 450/2 · 78-047, 12/78). Rule 463 was incorrectly FNDed. Rule will be updated for RACT and FND w ill be removed.
Rule 1102 · Pet roleum Solvent Drydeaners EPA Request-Tab le 1 Update Rule 1102 to incorporate additional provisions as apply to Update rule
. I all machines besides PERC if determined to be cost-effective. SIP version of the rule is 03/01/1991 amendment (59 FR 32354
• 06/23/1994), rather than the 08/02/1991 version. Rule 1104 · Wood Flat Stock Coating Operat ions EPA Request·Table 1 Rule 1104 needs to be amende d t o reduce VOC content of wood Update ru l e. flat stock I nks and wood flat stock coatings for exterior wood I I siding. I Rule 1108 meets current RACT as determined by a more recent RACT rule compa ri son with N orthern Sierra AQMD Rule 227 as adopted 11/27/2006
. Also, the SCAQMD Technology Assessment for Rule 1108 ·Cutback Asphalt (June 2008) evaluated the feasibility of further limiting the use of cutback asphalt t o the fall Rule 1108 · Cutback Asphalt EPA Request -Table 1 and winter months where ozone formation is at its least, or No action requ ired. replacing It with surrogate water-based emulsion technology. Based on this assessment, SCAQMD determined that no changes were necessary to their rule. The AVAQMD accept s th is determination as having a simila r reasonable applicability in the MDAQMD to rule 1103
.20 1 4 Suppl ement to t he 2006 AVAQMO R A(T SIP An alysis Rul e Reason for Analysis Determination Actio n District rescinded Rule 1110 on 01/15/2013. Rule was submitted to ARB on 09/23/2013 requesting removal from S IP. ARB has not submitted the rescission f or removal from the SIP to US EPA at this Rule 1110 · Emissio ns from Stationa ry I nternal time
. Combustion Engines (Demon stration ) AVAQMD Requ i red RACT Acti ons N o action required. Th is rule was i napplicab le due to the termination of th e SCAQMD program prior to the formation of the AVAQMD and th e fact that none of the program engines w ere located w ithin what is now the jurisdiction of the AVAQMD. Rule 1110.2 • Emissions from Gaseo us and Liqu id Rule 1110.2 is not RACT (69 FR 2 1 482, 04/21/2004). Rul e 1110.2 Update rule, and/o r adopt a separat e AG I CE F ue l ed Internal Combustion Engines EPA Request-Table 2/ AVAQM D Required RACT Actio ns must be updated to re move the Ag exemption and addre ss other rule EPA co mments identified in the LA/LD (69 FR 21483, 04/21/2004). District amended Rule 1124 on 08/20/2013
. Submitted to ARB Rule 1124 · Aerospace Assembly and Component AVAQMD Required RACT Acti ons 9/24/13. ARB indicated they had no comments and were No action required if U SE PA makes RACT Manu facturing Operations fo rwarding the rule to USEPA as a revision to the S I P on determ ination on su bm ission
. 10/21/2013. R ule 1128 · Pape r, Fabric and Film Coating EPA Request/Table 2 District amended Rule 1130 - Graphic Arts and rescinded Rule Operations 1128- Paper, F abric, and Film Coating Operations on 11/19/2013. No action required if USEPA makes RACT The provisions of Rule 1128 were incorporated into Rule 1130. detrmination on submission. Rule 1130 ·G raphic Arts EPA Request-Table 2 Submitted to ARB on 01/07 /20 14
. Request ed ARB to forward these actions t o US EPA as revi sions t o the SIP. Ru le 1134 • E m i ssions of Oxides of Nitroge n from EPA Request-Tab le 2 D istrict amended Rule 1134 on 01/19/20 10. SIP approved/RACT No action require d
. Stationary Gas Tu rbines 77 FR 2469, 01/18/2012. Rule 1141.1- Coatings and Ink Manufacturing EPA Request-Table 2 Update Rule 1141
. 1 to address deficiencies noted in RACT rule Update rule or file a FND. analysi s w it h SCAQMD Rul e 1141
. 1 , or file 

### a FND for this source. Ru le 1145 · Pl astic, Rubbe r, and Glass Coatings EPA Request-Table 2 Update Rule 1145 to address defi ciencies noted in RACT rule Updat e rule. ana lys is w i th SCAQMD Rule 1145
. Rule 1146 - Emissio ns ofOxides of Nitrogen f rom Will survey affected units for app licabili ty and determine if it is Industrial, Institutional and Commercial Boilers, EPA Request-Table 1 Updat e rule
. Steam Generators, an d Process Heaters feasible to update limits as RACT.
Ru le 1146
. 1 - Em iss io ns of Oxides of Nit rogen from NOx and CO limits are consiste n t wi t h cu rre nt RACT limits I n SJVUAPCD Ru le 4307 as well as SCAQM D Rule 11 46.1. These Small i ndustrial, Institutional and Com mercia l EPA Request-Tab le 1 rules, as we ll as the TSD for the SCAQMD 09/05/2008 amendment No action required. Boilers, Steam Gene rators, and Process Heaters w ill be used for updating requirements during next rule update. Rule 1168 - Control of VOC Emiss ions f ro m Adhesive EPA Request -Tab le 2 District amen ded Rule 1168 09/20/2011
. SIP approved/RACT 77 No action required. Application ______ FR 58313, 09/20/2012.

# ---
.... 

## --,..,..._...

# _. ... ....... 

## .. -**~ ~** **~** he 2006 . Q !**~** . CT SIP Anal
. r - ·- Ru le Reason for Analysis Determination Action I Review of the AVAQMD RACT S IP Analys is and the Federa l Negative Declarat ion for Fifty-One CTG Categories includes the Industrial Wastewate r sou rce category (referenci ng ACT Document: Air Emissions from Industrial Wastewate r (4/ 94), Contr ol of VOC Emissio ns from Indu s tria l Wastewate r CTG Draft Rule 1176- VOC Emissio ns from Wastewater EPA Request-Table 2 ( EPA-453/0· 93·056, 9/92), and Contro l of Refinery Vacuum Rescind Ru le (FND Filed)
. Syste ms Produci ng Systems, Wastewater Separators, and Process Unit Turnarounds (EPA-450/2-77.025, 10/77)). Although Rule 1176 was not specifically ref erenced in the RACT SIP Analysis, this so urce category has been**~NDed.** Rule can be re scinded a$ there are no so urces subje ct to the applicability of the ru le in the AVAQMD.AVAQMO Rule 462 ·O rganic liquid Loading 1 AV Rule 462 - Organic Liquid Loading SCAQMO Rule 462 · Organic Liquid Loading RACT Deficienci es RACT Version 06/09/1995 (62 FR 60784, 11/13/1997) 2 05/14/1999 , 64 FR 39037,7/21/1999 Facilities that load organic liquids w i th a vapor pressure of Faci li ties that load organic liqu ids with a vapor pressure of 1.5 psia or Applicability 1
. 5 psla or greater under actual loading condit ions into any greate r under actual loading conditions into any tank truck, tra iler or tank truck, trailer or railroad car as defined as Class A, B or C railroad car as defined as Class A, B or C facilities. facil ities
. Facil ity Vapor leak: Escape of organic vapors from a source Faci l ity Vapor leak: Escape of o rgani c vapors from a source other TSD for SCAQMD Rule 462 than a tank truck, trail er or railroad ca r in excess of 3,000 ppm as other than a tank truck, trailer or ra i l ro ad car in excess of methane above background when m eas u red according to EPA identified that the rev ision of the Definitions 3,000 ppm as methane above background when measured Method 2 1. A facil ity vapor leak so u rce does not i nclude liquid d efi nition of "facility vapor lea k" at a distance of 2 em from the source acco rding to EPA spillage or condensate resulting from "liquid leak s. " to remove the 2 em Method 21. A facility vapor leak source does not include measurement distance was a liquid spillage o r co ndensate resulting from "liquid leaks." New and revised definitions added for rule clarity per SCAQMD TSD. deficiency In the rule. Provision added as a compliance mechanism f or District approval of Suggested Contro l Opti ons vapor recovery and/or disposa l system s that do not require CARB Update for RACT
. Certification per SCAQM D TSD. Evaluation of RACT and recommend ation U pdate Rule 462 to address deficiencies In the Li mited A pproval/limited Disapprova l in the NPRM Issued 05/14/1 997
. App licable CTG(s) Control of Hydrocarbons from Tank Truck Gasoline loadingTerminals,**EPA-450/2 77~26**  Control of Volatile Organic Compound Leaks from Gasoline Tank Trucks and Vapor Collection Systems, EPA**450/2-78~51** Control of Volatile Organic Emissions from Bulk Gasoline Plants,**EPA-450/2 77~35**  'Table 1, item 6 of the EPA comment letter asks for identificat io n of which District rule was reviewed on the RACT Eva l uation Table. Upon review, it was determined that Ru le 462 required further eva l uation from the "Tank" sectio n of the Rule E valuation Table.
1 The AVAQMD does not believe that the SI Pversion of Rule 462 is as listed on the EPA Region 9 website. EPA lists the SIP version as amended on 06/09/1995 (11/13/1997 62 FR 60784)
. This FR notice specifically excludes the AVAQMD from t he SCAQMD approval. The S/14/1997 NPRM does not exclude the AVAQMD
. The AVAQMD separated from the SCAQMD on 07/01/1997 , between the NPRM and the Final rule. Since the 05/14/1997 NPRM does not exclude the AVAQMD, the 06/09/1995 version of Rule 462 is still techn ically "SIP pend i ng ." The last SIP approved version of Rule 462 w ould be the 10/14/1979 SCAQMD amendment (no action shown for the 04/04/86 version, and no f ina l on t he 12/07/1990 vers ion).

### AVAQMD Rule 463- O rganic liquid Storage 1 

### AVAQMD Rule 463 - Organic liquid Storage SCAQMD Rule 463 - Organic liquid Storage RACT Deficiencies Amended 03/11/1994 (SIP Approved 10/23/1996 Amended 11/04/2011 (SIP approved 03/28/2013 61 FR 54941) 78 FR 18854) Above-ground stationary tanks with a capacity of Above-ground stationary tanks with a capacity of 75,000 liters or greater used for storage of 75,000 liters or greater used for storage of Applicability organic l iquid, and any above -ground tank w i th a organic liquid, and any above-ground tank with a Same capcity between 950 l iters and 75,000 liters used capcity between 950 l iters and 75,000 liters used for the storage of gasoline. for the storage of gasoline. Definitions added for: Actual Storage Conditions, Update definitions if rule i s updated
. Ambient Temperature, Certified Person, DrainDry Breakout Tank, Heavy Crude Oil, and Working Update definition of "Vapor Tight" to sp ecify 500 Definitions Day. ppm, expressed as methane, above background, Definition for Vapor Tight has been modified to from 1,000 ppm expressed as methane, above 500 ppm, expressed as methane , above background
. background. Equivalency for vapor control device to be reviewed by District, ARB and USEPA and approved in writing by Executive Office r , ARB and Add equivalency review cri teria
. Tank Roof Requirements USEPA. Allow tank to vent emissions to a fuel gas system. For vapor recovery systems, efficiency sha ll be 95%, or vent tank emissions to a fue l gas system. Provision added that organic liquids listed in addendum shall be deemed in compliance with appropriate vapor pressure limits for the tank in Add additional SCAQMD provisio n. Other Performance Requirements No crude o i l containing in excess of 70 ppm by which it is stored provided the actual storage weight of HS shall be stored in floating roof tank. temp does not exceed the corresponding max Eval uate if crude oil with 70 ppm HS provision temp listed. should be removed. AV crude oil provision has been removed. Self -I nspection o f Floating Roof Tanks Out of date compliance dates for inspection and Remove compliance dates that have expired from maintenance plan req . AV rule for inspection and maintenance plan req. Emissions reporting updates allowable methods Reporting and Recordkeeping f o r providing emissions information to include Update emissions reporting programs to include Requirements USE PAs most recent version of "Tanks 4.0 USEPA "Tanks 4
.0 Program." Program." Exemptions Added exemption provision for drain-dry Evaluate if this provi sion should be added. breakout t anks su bject to Rule 1149.

### AVAQMD Rule 463- O rganic Liqui d Storage 1 

### AVAQMD Rule 463 - Organic Liquid Storage SCAQMD Rule 463- Organic Liquid Storage RACT Deficiencies Vapor t i ght cond ition appears t o need to be Updated/added test meth ods: TVP less t han 5 Test Methods updated. mmHg, TVP of crude oils and distillates, API Updated test methods as applicable. gravity. Severa l pages of Attachment C have been Remove i nformation from Append i x C i f no longer Addendum removed in the most recent SCAQMD applicable or necessary. amendment. E val u ati on f or RACT and recom m end ati on Update Rule 463 to address deficiencies noted in RACT rule ana l ysis with SCAQMD Rule 463. Appl icable CTG(s) Emissions from Petroleum Liquid Storage in External Floating RoofTanks, EPA-450/2 - 78-047, 12/78 Control of Volatile Organic Em i ssions from Storage of Petroleum Liquids in Fixed - Roof Tanks, EPA 450/2 - 77-036, 12/77

- ---··--·-·--

1 

### Tab l e 1, item 6 of the EPA comment lette r asked for i dentification of which District rule was reviewed on the RACT Evaluation Table. Upon review, it was determined that Rule 463 required further evaluation from the " Tank" section of the Rule Evaluation Table as it had not been properly identi fied. Review of the AVAQMD RACT SIP Analysis and the Federal Negative Declaration for Three Source Categories includes Storage of Petroleum Liquids in Fixed-Roo f Tanks and Petrole um Li quid Storage in External Floating Roof Tanks (CTGs referenced: Control of Volatile Organ i c Em iss ions from Storage of Petroleum Liquids in Fixed - RoofTanks (EPA- 450/2- 77-036, 12/77) and Control ofVoaltile Organic Emissions from Petroleum Li quid Storage i n External Floating Rood Tanks (EPA-450/2- 78- 047, 12/78)). Rule 463 was incorrectly FNDed
. Rule will be updated for RACT and FND will be removed
.

### Rul e 11 02 - Petrol eum Solve nt D ry Cl ea n e rs SCAQMD Rule 1102 (Amended 11/17/2000, SIP AVAQMD Rule 1102 (Amended 12/07/1990, SIP AV Rule 1102 RACT Deficiencies approved, 67 FR 46876 07/17 /2002) approved, 57 FR 10136 03/24/1992) Appl i cability Dry cleaning faci l ity using solvent other than PERC Petroleum Solvent Dry Cleaners Applicability does not incl ude all solvents besides PERC. Definitions Terms added/removed from previous version to Not as comprehensive, does not cover SCAQMD Would need to be updated to cover more cover additiona l requirements expanded applicability. comprehensive applicability
. Cartridge fi lters conta i ning paper or carbon shall Increased drai nage time for cartridge filters from be fully drained in a sealed filter housing for 24 12 to 24 hours
. hou rs before removal. Cartri dge filters co n taining paper o r carbon shall Additional specifications for closed-loop machines Operating Requirements Additional specifications for closed-loop machines. be fully drained in a sealed filter housing for 12 not specified. hours before removal. Transfer machines no longer allowed. Transfer machines no longer allowed
. Leak check and repair requirements specified. Leak check and repair requirements n ot specified as to frequency, specificity of SCAQMD Ru le 1102. ' 

### Pre-wash weight of materials/load ' 

### Purchase and delivery receipts for solvent. Log of solvent added by operato r. Inventory of solvent. Pre-washed weight of articles. Record keep i ng Amount of solvent used. Solvents purchased and solvent inventory. Less comprehensive record keeping than SC 1102. Dates of leak inspections. Maintain records pursuant to Rule 109. Detection and repair log for leaks
. Facility mileage for solvent used. All records maintained pursuant to Rule 109. Test Methods EPA Test Method 25 or SCAQMD Test Method EPA Test Method 25 or SCAQMD Test Method Same test methods specified
. 25
. 1 (March 1989). 25
. 1 (March 1989). Not allowed after 01/01/2001 - dip tanks, drying cabinets, closed-loop machine opened before By 01/01/1993 all petro l eum solvent dry-cleaning SCAQMD Rule no l onger allows t he operation of Compliance Schedule completion of drying cycle. transfer machines, and they are still allowed in Not allowed after 01/01/2005 -Transfer facilities were to meet rule provisions. AVAQMD rule
. machines. Notes AV SIP rule was the SC version prior to their most r ecent amendment. Eval uation of R ACT and recom m endation Update Rule 1102 to i n corporate additional provisions as apply to all machines besides PERC if determined to be cost-effect ive .

--·-·-·-··--

### Rule 1104 - Wood Flat Stock Coating Operatio ns SCAQMD Rule 1104 (Amended 08/13/1999, AVAQMD Rule 1104 (Amended 03/01/1991, AV Rule 1102 RACT Defi ciencies SIP approved, 65 FR 15240 03/22/2000) SIP approved, 59 FR 32354 06/23/1994) Applies to all persons applying coatings, inks, Applies to all persons applying coatings, inks, and adhesives to flat wood stock for the and adhesives to flat wood stock for the purpose of manufacturing a finished wood purpose of manufacturing a finished wood panel for attachme nt to the inside walls of panel for attachment t o the inside walls of Applicability buildings, including but not limited to, homes buildings, includin g but n ot li mited to, hom es Same applicability. and office buildings, mobile homes, traile rs , and office buildings, mobile homes, trailers, prefab buildings and similar structures, boats prefab buildings and similar structures, boats and ships; or a finished ext erior wood siding and ships; or a finished exterior wood siding intended for use in construction. intended for use in construction
. *Wood flat stock coatings and adhesives fo r Wood flat stock coatings, inks, and adhesives wood panels- <250 

### g/1 of coating or for i nterior wood panels and exterior wood adhesive, less water and exempt compound. Wood flat sock inks for wood panels and siding - <250 

### g/1 of coating, ink or adhesive, *Wood f lat stock inks - <300 

### g/1 of VOC per wood flat stock coatings for exterior wood Requirements less water and exempt compound. liter of i nk, less water and exempt siding exceed the limits in SC RACT version. compound. Ad ded reference to Ru le 1171- Solvent *Wood flat stock coatings for exterior wood No Ru l e 1171 reference
. Cleaning Operations siding - <350 

### g/1 of VOC per liter of coating, less water and exempt compound. Recordkeepi ng Pursuant to Rule 109 (Amended 05/02/2003, Pursuant to Rule 109 (Amended 4/20/2010, Same recordkeeping requirements. Approved 69 FR 3018 01/22/2004) Approved 77 FR 12495 03/01/2012) Test Methods, AECP, E xemption Same test methods, AECP, Exemptions cited. Notes AV SI P rule was the SC version prior to their most current amendment. Applicable CTGs Control of Vo latile Organic Compounds Emissions from Existing Stationary Sources Volume VII: Factory Surface Coating of Flatwood Panell i ng ( EPA-450/2 - 78-032, June 1978) E va lu ation of RACT and recommendation Update Rule 1104 to reduce VOC content of wood flat stock inks and wood flat stock coatings for**~xteljc>r** 

### w_Qod siding.

-- -----

## AVAQMD Rule 1110.2- Emissions From Stationary, Non-road 

## & Portable Internal Combustion Engines 1

1 

## Rule 

## 1110.2 was originally adopted by SCAQMD on 

## 08/03/1990 and amended 

## 09/07/1990,08/12/1994 and 

## 12/09/1994. EPA did not approve any of these rule versions into the SIP. The AVAQMD subsequently amended Rule 

## 1110.2 on 

## 05/15/2001 and 

## 01/21/2003. On 

## 04/21/2004, EPA proposed a limited approval/limited disapproval 

## (69 FR 

## 21482, 04/21/2004) of the revision. The LA/LD was based on the agricultural ICE exemption
. The LA/LD also included a request for ju stification of the season al exemption for ICE used for snow manufacturing and ski lift operation , request for correction of several citations, and increasing record retention from 

## 2 years to 5 years. Specifically, EPA determined that the Ag exemption, and possibly the snow/ski exemption, disqualified Rule 

## 1110.2 from meeting RACT. Evaluation for RACT and re commendation Rule 

## 1110.2 is not RACT. Rule 

## 1110.2 must be updated to remove the Ag exemption and address other EPA comments i dentifi ed in the LA/LD 

## (69 FR 

## 21482, 04/21/2004).

-······---·--··---·--- -----···- ------

### Rule 1141 .1 - Coatings and Ink Manufacturing 

### AVAQMD Rule 1141.1- Coatings and In k SCAQMD Rule 1141.1 -Coatings and Ink Manufacturing Manufacturing RACT Deficiencies Amended 03/06/1992 (SIP version amended Amended 11/17/2000 (02/12/2002, 67 FR 6410) 03/14/1984, approved 01/24/1985, SO 

### FR 3338) Coati ngs manufacturer- establishment that Coatings man u facturer - establishment that mixes, blends, an d/o r compounds paints, mixes, blends, and/or compo unds paints, varnishes, l acquers, enamels, shellacs, or sealers, varnishes, lacquers, enamels, shellacs, or sealers, Applicability and is classified as 2851 in the SIC Manual. and is class if ied as 2851 in the SIC Manual. Same applicability. Ink manufacturer - establishment that mixes, Ink manufacturer- establishment that mixes, blends, and/or compounds printing inks and is b lends, and/or compounds printing inks and is classified as 2893 in the SIC Manual. classified as 2893 in th e SIC Manual. Definitions S t ill have definition for ROG. Definition ad d ed for exempt compound, updated Update definitions I 

### for VOC and waterbased coating. Requirements Reference ROG rather than VOC. Same requirements, but reference VOC rather Update reference from ROG to VOC. I 

### than ROG. I ! 

### M aintain daily or monthly records, including type and amount of each coating/ink manufactured, type and amount of each VOC containing material Record keeping None in each coating or ink, the type and VOC content Add recordkeeping requirements. of each so l vent used for clean-u p used. Maintain records for 2 years. Added exemption from rule provisions except Exemptions record keeping if manufacture less than 11,000 Will evaluate adding additional exempti on. All gallons of coatings and/or inks per calendar other exemptions the same. month. Have been removed from SCAQMD rule Compliance Lists dates for compliance with rule requirements. amendment. M ay be removed f rom AVAQMD

.. 

### r ule if no longer necessa ry.

### Rule 1141.1 -Coat in gs and Ink Ma nufacturing 

### AVAQMD Rule 1141. 1 - Coati ngs and Ink SCAQMD Rule 1141.1 - Coatings and Ink Manufacturi ng Manufacturi ng RACT Deficiencies Permit app li cation linked to filing of compliance This provision has been removed from SCAQMD F ees plan
. May be required to submit engineering ru le. May be removed from AVAQMD ru le if no evaluatio n fee as well. longer necessary. Applicab l e CTGs Control of Volatile Organic Em issio ns from Existing Stationary Sources, Volume 1 : 

### Control Methods for Surface Coati ng Operations (EPA-450/2 -76-028, 11/76, NTIS PB- 260 386) Control of VOC Emissions from In k and Paint Manufacturing Processes (EPA-450/3-92-013 , 4/92) Evaluation for RACT and recommendation 

### Update Rule 1141.1 t o address def iciencies noted i n RACT rule analys i s with SCAQMD Ru l e 1141.1, or fi l e FND.

### Ru l e 1145- Plastic, Rubber and Glass C o ati n gs AV Rule 1145 - Plastic, Rubber, and Glass SC Rule 1145 - Plastic, Rubber, leather, and G l ass RACT Deficiencies Coatings 1 

### Coatings S

I P Version Amended 01/10/92 (12/20/1993, 58 FR 66286) Amended 12/04/2009 (07/14/2010, 75 FR 40726) Reduce VOC emissions from the application of Reduce VOC emissions from the application of Eval uate if need to expand applicability to inc lude Applicability coatings to any plastic, rubber or glass product. coat ings to any plastic, rubber, leather or glass leather coatings. products. Several definitions have been added/removed/updated: carpet backing, coating,extreme performance coating, HVLP, Update definition s as needed and add defin iti o ns Definitions l eather antique coat in g, leather color coating, for leather coatings if leather is added to leather sealer coating, leather stain coating, app l icability. l eather top coating, refrigerated glass door coating, vacuum metalizing/physical vapor deposition. Several higher VOC limits: Genera l Coatings (one- Added categories: extreme perform ance, leather, Update VOC lim it s if cost-effective, and add new VOC limits and two-component), multi -colored coatings, mirror backing (roll coated), optical coatings
. refrigerated glass doors. categories if needed. Remove 1151 references if now contained i n Add extreme performance coating qualificati on, Requirements 1151. Added qualification for classification as extreme update transfer efficiency requ i rement, r emove performance
. 1151 reference if applicable. Update transfer efficiency requirement. Compliance Test Update test methods to include additional Added determination of efficiency of emission Update test methods. Methods references. control system. Prohibition of Sale Additional language. Update prohibition of sale requirements if applicable. Exemptions Update exemption for clear and translucent Added exemption applicable to polyurethane Update exemptions. coatings. shoe sol e coating. Eval uation of RACT and recom mendation Update Ru l e 1145 to address deficiencies noted in RACT rule analysis with SCAQMD Rule 1145. Appl icable CTGs CTG for Mi sce l l aneous Metal and Plastic Parts**Coating~_(E PA** **453/R 08** **003,** 

### September 2008)

---- 1 

### The version of Rule 1145 in the AVAQMD Rule book is as amended by SCAQMD 02/14/1997. The AVAQMD se parated from the SCAQMD on 07/01/1997, prior to the submi ss ion of this rule to USEPA on 08/01/1997
. The SCAQMD approval of the 02/14/1997 version (05/04/1999, 64 FR 23774) specifi ca lly excluded the AVAQMD from the aprova l action. The RACT analysis w ill compare th e rulebook version to the SCAQMD SI P version.AVAQMO Rule 1146 . Emissions of OJddH of Nltro«on from lndustrlal,lnstltutiOJ'Ial, ond Commerdolllollers, Steam G.nerators, and Pro<Hs Heaters AVAQMO Ru&e 1146 - Emissions ofOxkfes of Nitrocen SCAQMO Rule 1146 · Emissions of Olcldes of N luocen SIVUAPCO Ru1 e 4306- aoilers. Stnm Generators, and tTOm Industrial, Institutional, and Commerdal8oilers, from Industrial, Institutional, and**Commerdo~IBoUer~.** PrOC4u Heaters- Phase 3. Amended 10/16/2008(SIP RACT Deficiency Steam Genenton, and Process Heateu, Adopted Steam Generators, and Process Htilttrs,**Amend~** Approved 01/13/2010. 7SFR 1715 ) 5/13/1- (SIP approved 09/06/1995, 60 FR 46220) 11/17/2000 (SIP approved 04/08/2002, 67 FR 16640) Boilen, steiilm cenerators, and process heaters of equal Boi&en, steam generators , and process heaters of**~qua l**  to orcreaterthan S million Bt u per hour rated heat to orc reater than S million Btu per hour rated heat Input**(a~eoity** used in all industrlal,lnstltudonal input capadty used I n all indus trial, I nstitutional Any eueousfue l or liquid fue l f ired boiler. steam Applicability operations with the except ion of boners used by e lttt rk: operations with the exception of bolte rs used by el ectric generator, or pr ocess heiter with a total rated heat utilitiesto aenerate elect ricity, boilers and process utilities to generate e\ectric:ity, boilers and process input greater than 5 miiUon Btu per hour
. heaters with a rated input capacity gre . ater than 40 heaters with a rated input capacity creater than 40 MMBtu per hour used in petroleumrefinerl4>s, and MM8tu per hour used in petroleum refinerlu. and sutfur plant**react~n** boners. sulfur plant reaction**bo ~rs** **.** 40 ppm NO. (Jaseous fuels)**~** 5 mtnion 8tufhr and 40 ppm NO. (caseous. liquid or solid fuel) 40 ppm Nox (combination**caseous/ non-caseous·~**  > 90,000 Therms fuel use 400CO ond <40) 400ppmCO**~** 40 milbon Btu/hr and 30 ppm NO. 30ppmNox > 25" annual**Ul~city** factor 400CO 400ppmCO**~** 40 million Btu/hr and 40ppmNOx 40 ppm**NO.(~** 40 million Btu/hr and rated hut**input~** > 25% annual Qpacity less than factor and >90,000 25" burning**a~seous** and non-eneous) Therms 400CO 400ppmCO Any unit with rat e d heat Input**capacity~** S million Btu/hr, annual heat unput 

### s: 90,000Therms shall:**ma in** **ain** stack cas [0 2) at s 3% on a dry basis fo r any conse<:utive 15-m in averaging period; or ./ ./ ./ -be tuned at least 2x/year accordinc to**procedure~** In atta(lhment or**milnufadurer'~** spKiflc.atlons for tune · up.**~** 40 milhon Btu/hr ilnd ind annual heilt input >200 x 10' sh.aU h.ave a continuousin,..stack nRrocen oxfdeJ ./ ./ CEMS for i.OY unit subjectto em iss&on limits or monitor or equiva&ent verifiution system i n compliance approved •ttemative monitorinc system with 40 CFR 60Appendix B Spec. 2. 30 ppm Nox**~** 10 million Btu/hr and burnin& raseous fuels 400ppmCO Will survey affected units for Emission Limi ts 

### a: 10 million Btu/hr and bu rni ng combination of 30ppmNox applicability aMI determine iffc Is aaseous and non -caseous fuels 400ppmCO feasible to**pdat~t** limits as RACT. 30ppmNox**~** 5 million Btu/hr and < 10 Btu/hr 400ppmCO Std/Ga seou s • 15 ppmv**~** 20MMBtu/hr Enhanced/Gaseous • 9 ppmv UquM:t
- 40 ppmv C0
- 400ppm Std/G•seous- 9 ppmv > 20MMBtu/hr Enh•noed/Goseous
- 6 ppmv liquid
- 40 ppmv C0 · 400ppm Std/GasOOU$ • 15 ppmv load-'followinl Units Enhanced/G.as.ous • 9 ppmv liquid
- 40 ppmv C0-400ppm Units limited by PTO to annual heat input of 9 b i llion Gaseous · 30 p pmv Liquid
- 40 ppmv Btu/vur to 30 billion Btu/ve•r C0 -400 ppmv Unit in which the ,.ted h eat inpu t of each b urner Js sS MMBtu/hr bvt total of all b u rners in unit is> 5 Gaseous
- 30 ppmv MM8tv/hr, and the p roducts of combustion do not L iquid • 40 ppmv come in**cont~t** with the products of combustion of anv C0·400ppmv other burner Evaluation lor RACT ond determination Will survey affected units for applicability and determine if 1t is feasible to update lrmlts as AACT.AVAQMD Rule 1146.1- Emissions of Oxides of Nitrogen from Small Industrial, Institutional, and Commercial Boilers, Steam Generators, and Process Heaters1 SJVUAPCD Rule 4307- Boilers, Steam Generators, and AVAQMD Rule 1146.1, Amended 0S/13/199S Process Heaters- 2.0 MMBtu/hr to 5.0 MMBtu/hr, RACT deficiencies Amended 10/16/2008 SIP Version SIP approved 09/06/1995, 60 FR 46220 SIP approved 01/13/2010, 75 FR 1715 AVAQMD rule does not have different limi ts for liquid Boilers, steam generators, and process heaters that are Gaseous fue l or liquid fuel fired boiler, steam generator, and gaseous fueled boilers, steam generators, or Applicability greater than 2 million Btu per hour and less than 5 or process heater with a tota l rated heat input of 2.0 process h eaters in applicability. Both liquid and million Btu per hour rated h eat input capacity used in million Btu per hour up to and including 5.0 MMBtu/hr. gaseous h ave same lim it in AVAQMD rule, where liquid any industrial, institutiona l , or commercial operation. fired units in SJUAPCD rule has higher NOx lim it for liquid fueled units
. Definiti ons Many definitions have been added or modified. May need to be updated for clarification or new requ ire ments. NOx and CO limits do not apply if: 1
. Solid fuel fired units. Non- resettable, totalizing fuel meter demonstrating 2. Dryers and glass melting furnaces. that unit operates l ess than 18,000 therms per calendar 3. Kilns, humidifiers, and smelters wh ere th e products year. of combustion come in direct contact with the material to be heated. Exemptions Records list cumulative fuel annua l usage for preceding 4
. Unfired or fired waste heat recovery boilers that are Add exemptions if applicable. calendar year. used to recover or augment heat from the exhaust combustion of gas turbines or ICE
. Must maintain stack-gas oxygen concentrations, be 5. NOx and CO limits shall not be enforced when tuned twice per year, su bmit compliance plan
. burning other than PUC f uel during an approved curtailment. The AVAQMD is not nonattainment for PM 10 and SOx, and does not need to in co rporate these limits in the Requirements; Standards for NOx and CO. Standa rds for NOx, CO, PM and SOx, as well as new and rule. The requiremen t s for new and replacement units replacement atmospheric and non -a tmospheric units. would be evaluated for BACT at major facilities. Therefore, the RACT limits for NOx and CO in AVAQMD Rule 1146.1 are the same as those in SJVUAPCD 4307
. 

## I Equipment Tuning Procedure Appendix A, Rule 1146.1 Rule4304 Conta ins same info. No update necessary. 

## I Start-up, shutdown 6-hr time limit for start- up, shut down. Places 1 - hr or 2-hr requirements on start- up and Expand start-up, shutdown requirements. shutdown Monitor manufacturer recommended operationa l 

## I Monitoring Provisions Tune-up provision, operational non-resettable, characteristics once a month
. Add monthly monitoring of manufacturer totalizing mass or volumetric flow meters on each lin e. Operational non-resettabl e, totalizing mass or recommended operational characteri stics. volumetric flow meters on each line, or a master meter. Test Methods May need to update seve ral test methods referenced. Recordkeeping 2 years 5 years Update record retention to 5 years. Additiona l Requirements To be analyzed as necessary for a!!elicability.AVAQMD Rule 1146.1· Emissions of Oxides of Nitrogen from Small Industrial, Institutional, and Commercial Boilers, Steam Generators, and Process H eaters1 SJVUAPCD Ru l e 4307 - Boilers, Steam Generators , and AVAQMD Ru le 1146
. 1 , Amended 05/13/199S Process Heaters - 2.0 MMBtu/hr to 5. 0 MMBtu/hr, RACT deficiencies Amended 10/16/2008 Evaluation of RACT and recommendation NOx and CO limits are consistent with current RACT limits in SJVUAPCD Rule 4307 as well as SCAQMD Rule 1146.1. These rules, as well as the TSD for the SCAQMD 09/05/2008 amendment will be used for updatin g requirements durin g next rule update. Applicable CTG(s) ACT Document - NOx Emissions from Industrial/Commercial/Institutional {ICI) Boilers, US EPA 453/R -94· 022, March 1994. ACT Document - NOx Em issions from Utility Bo il ers , US EPA 452/R-93-008, March 1994
.
1 The SCAQMO rul e am e ndment in the SIP is identical to the AVAQMD rulebook version
. SCAQMD most recently amended Ru l e 1146
. 1 - Emissions of Oxides of Nitrogen from Small Industrial, I nstitutional , and Commercial Boilers, Steam Generators, and Process Heaters on 11/01/2013. This version has not been updated as a SIP approved RACT rule on the Region 9 SIP site, nor does it appear that CARS has yet subm i tted this amendment to USEPA. The prior 09/0S/2008 SC amendment received proposed limited Disapproval/limited Approval from US EPA.

## AVAQMD Ru l e 1176- VOC Emissions From Wastewater Systems1 

## Amended 5/13/1994 (SIP approved 08/25/1995, 59 FR 43751) Applies to wastewater systems and associated control equipment located at petroleum refineries, on -shore oil production fields, off-shore oil production platforms, chemical plants (any facility engaged in producing chemicals, and/or manufacturin g produ cts by chemical processes. Any facility or operation th at has Applicability 282 as the f irst three digits in its Standard Industrial Classification Code as defi ned in the Standard Industrial Classification Manual is included in this definition), and industria l facilities (engaged in the production and distri bution of natural gas, pipeline distribution or wholesale distribution of crude petroleum and petroleum products except gasoline, as classified under the Standard Indu strial Classification group numbers 492, 461, or 517, respective ly, of the Standard Industrial Classification Manual).

1 

## Review of the AVAQMD RACT SIP Analysis and the Federal Negative Declaration for Fifty-One CTG Categories includes the I ndustri al Wastewater source cat ego ry ( referencing socumen ts : Air Em i ssi ons from I ndustri al Wastewater (4/94), Control of VOC Emissions from Industrial Wastewater CTG Draft (EPA-453/D-93 -056, 9/92), and Control of Refinery Vacuum Producing Systems, Wastewater Separato rs, and Process Unit Turnarounds (EPA450/2- 77-025, 10/77))
. Although Rule 1176 was not specifically referenced in the RACT SIP Analysis , th i s source category has been FNDed. Rule can be rescinded as there are no sou rces subject to the applicability of the rule in theAVAQMD
.