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 94I 05 

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 of your 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 of the 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. 

If you have any questions regarding this letter, please contact me at (760) 245-I66I, extension 

6726. 

Supervising Air Quahty Engineer 

AJD/tw RACT SIP Supplement 

€te<ru 

Cities 

Antelope ...,,ley 
2014 Supplement to the 2006 AVAQMO RACT SIP Analysis 

Rule Reason for Analysis Determination Action 

Rule 461 · Gasoline Transfer and Dispensing EPA Request-Table 1 

District amended Rule 46110/21/2008. SIP approved as RACT, 76 No action required. FR 5277, 01/31/2011. 

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 462 required further 

Rule 462 · Organic Liquid loading EPA Request-Table 1 evaluation 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 Evaluation Table as 

it had not been properly identified. Review of the AVAQMD RACT 

SIP Analysis and the Federal Negative Declaration for Three 

Rule 463 · Organic liquid Storage EPA Request-Table 1 

Source Categories includes Storage of Petroleum liquids in Fixed· Update rule and remove FND. 

Roof Tanks and Petroleum liquid Storage in External Floating Roof 

Tanks (CTGs referenced: Control of Volatile Organic Emissions 

from Storage of Petroleum liquids in Fixed-RoofTanks (EPA-450/2 

77-036, 12/77) and Control of Voaltile Organic Emissions from 

Petroleum Liquid Storage in 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. 

Rule 1102 · Petroleum Solvent Drydeaners EPA Request-Table 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 amended to reduce VOC content of wood Update rule. 

flat stock Inks 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 comparison with Northern 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 required. 

replacing It with surrogate water-based emulsion technology. 

Based on this assessment, SCAQMD determined that no changes 

were necessary to their rule. The AVAQMD accepts this 

determination as having a similar reasonable applicability in the 

MDAQMD to rule 1103. 
2014 Supplement to t he 2006 AVAQMO RA(T SIP Analysis 

Rule Reason for Analysis Determination Action 

District rescinded Rule 1110 on 01/15/2013. Rule was submitted 

to ARB on 09/23/2013 requesting removal from SIP. ARB has not 

submitted the rescission for removal from the SIP to US EPA at this 

Rule 1110 · Emissions from Stationary Internal time. 

Combustion Engines (Demonstration) AVAQMD Required RACT Actions No action required. 

This rule was inapplicable due to the termination of the SCAQMD 

program prior to the formation of the AVAQMD and the fact that 

none of the program engines were located within what is now the 

jurisdiction of the AVAQMD. 

Rule 1110.2 • Emissions from Gaseous and Liquid Rule 1110.2 is not RACT (69 FR 21482, 04/21/2004). Rule 1110.2 Update rule, and/or adopt a separate AG ICE 

Fueled Internal Combustion Engines 

EPA Request-Table 2/AVAQMD Required RACT Actions must be updated to remove the Ag exemption and address other rule 

EPA comments 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 Actions 9/24/13. ARB indicated they had no comments and were No action required if USEPA makes RACT 

Manufacturing Operations forwarding the rule to USEPA as a revision to the SIP on determination on submission. 

10/21/2013. 

Rule 1128 · Paper, Fabric and Film Coating EPA Request/Table 2 

District amended Rule 1130 - Graphic Arts and rescinded Rule 

Operations 1128- Paper, Fabric, 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 ·Graphic Arts EPA Request-Table 2 Submitted to ARB on 01/07/2014. Request ed ARB to forward 

these actions to US EPA as revisions to the SIP. 

Rule 1134 • Emissions of Oxides of Nitrogen from 

EPA Request-Table 2 

District amended Rule 1134 on 01/19/2010. SIP approved/RACT No action required. Stationary Gas Turbines 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. 

analysis wit h SCAQMD Rule 1141.1, or file a FND for this source. 

Rule 1145 · Plastic, Rubber, and Glass Coatings EPA Request-Table 2 Update Rule 1145 to address deficiencies noted in RACT rule Updat e rule. analysis with SCAQMD Rule 1145. 

Rule 1146 - Emissions of Oxides of Nitrogen from Will survey affected units for applicability and determine if it is Industrial, Institutional and Commercial Boilers, EPA Request-Table 1 Updat e rule. 

Steam Generators, and Process Heaters feasible to update limits as RACT. 

Rule 1146.1 - Emissions of Oxides of Nitrogen from NOx and CO limits are consistent with current RACT limits In 

SJVUAPCD Rule 4307 as well as SCAQMD Rule 1146.1. These Small industrial, Institutional and Commercial EPA Request-Table 1 

rules, as well as the TSD for the SCAQMD 09/05/2008 amendment No action required. 

Boilers, Steam Generators, and Process Heaters will be used for updating requirements during next rule update. 

Rule 1168 - Control of VOC Emissions from Adhesive 

EPA Request-Table 2 

District amended 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-·-

Rule Reason for Analysis Determination Action I 

Review of the AVAQMD RACT SIP Analysis and the Federal 

Negative Declaration for Fifty-One CTG Categories includes the 

Industrial Wastewater source category (referencing ACT 

Document: Air Emissions from Industrial Wastewater (4/94), 

Control of VOC Emissions from Industrial Wastewater CTG Draft 

Rule 1176- VOC Emissions from Wastewater EPA Request-Table 2 (EPA-453/0·93·056, 9/92), and Control of Refinery Vacuum 

Rescind Rule (FND Filed). Systems Producing Systems, Wastewater Separators, and Process Unit 

Turnarounds (EPA-450/2-77.025, 10/77)). Although Rule 1176 

was not specifically referenced in the RACT SIP Analysis, this 

source category has been ~NDed. Rule can be rescinded a$ there 

are no sources subject to the applicability of the rule in the 

AVAQMD. 
AVAQMO Rule 462 ·Organic liquid Loading1 

AV Rule 462 - Organic Liquid Loading SCAQMO Rule 462 · Organic Liquid Loading RACT Deficiencies 

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 with a vapor pressure of Facilities that load organic liquids with a vapor pressure of 1.5 psia or 

Applicability 1.5 psla or greater under actual loading conditions into any greater under actual loading conditions into any tank truck, trailer 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. 

facilities. 

Facility Vapor leak: Escape of organic vapors from a source Facility Vapor leak: Escape of organic vapors from a source other 

TSD for SCAQMD Rule 462 

than a tank truck, trailer or railroad car in excess of 3,000 ppm as other than a tank truck, trailer or railroad car in excess of 

methane above background when measured according to EPA 

identified that the revision of the 

Definitions 3,000 ppm as methane above background when measured Method 21. A facility vapor leak source does not include liquid 

definition of "facility vapor leak" 

at a distance of 2 em from the source according to EPA spillage or condensate resulting from "liquid leaks." to remove the 2 em 

Method 21. A facility vapor leak source does not include measurement distance was a 

liquid spillage or condensate 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 for District approval of 

Suggested Control Options vapor recovery and/or disposal systems that do not require CARB Update for RACT. 

Certification per SCAQM D TSD. 

Evaluation of RACT and recommendation 

Update Rule 462 to address deficiencies In the Limited Approval/limited Disapproval in the NPRM Issued 05/14/1997. 

Applicable CTG(s) 

Control of Hydrocarbons from Tank Truck Gasoline loading Terminals, 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 identification of which District rule was reviewed on the RACT Evaluation Table. Upon review, it was determined that Rule 462 required further evaluation from the "Tank" 

section of the Rule Evaluation Table. 

1

The AVAQMD does not believe that the SIP version 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 technically "SIP pending." The last SIP approved version of Rule 462 would be the 10/14/1979 SCAQMD amendment (no action shown for the 04/04/86 version, 

and no final on t he 12/07/1990 version). 
AVAQMD Rule 463- Organic liquid Storage1 

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 liquid, and any above-ground tank with a organic liquid, and any above-ground tank with a Same 

capcity between 950 liters and 75,000 liters used capcity between 950 liters 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 is updated. Ambient Temperature, Certified Person, DrainDry Breakout Tank, Heavy Crude Oil, and Working Update definition of "Vapor Tight" to specify 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 Officer, ARB and Add equivalency review criteria. 

Tank Roof Requirements USEPA. 

Allow tank to vent emissions to a fuel gas system. 

For vapor recovery systems, efficiency shall be 

95%, or vent tank emissions to a fuel 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 provision. 

Other Performance Requirements 

No crude oil 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 Evaluate if crude oil with 70 ppm HS provision 

temp listed. should be removed. 

AV crude oil provision has been removed. 

Self-Inspection of 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 for 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 provision should be added. 

breakout tanks subject to Rule 1149. 
AVAQMD Rule 463- Organic Liquid Storage1 

AVAQMD Rule 463 - Organic Liquid Storage SCAQMD Rule 463- Organic Liquid Storage RACT Deficiencies 

Vapor tight condition appears to need to be Updated/added test methods: TVP less t han 5 

Test Methods 

updated. mmHg, TVP of crude oils and distillates, API Updated test methods as applicable. 

gravity. 

Several pages of Attachment C have been Remove information from Appendix C if no longer Addendum removed in the most recent SCAQMD applicable or necessary. amendment. 

Evaluation for RACT and recommendation 

Update Rule 463 to address deficiencies noted in RACT rule analysis with SCAQMD Rule 463. 

Applicable CTG(s) 

Emissions from Petroleum Liquid Storage in External Floating RoofTanks, EPA-450/2-78-047, 12/78 

Control of Volatile Organic Emissions from Storage of Petroleum Liquids in Fixed-Roof Tanks, EPA 450/2-77-036, 12/77 - ---··--·-·--

1 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 Evaluation Table as it had not been properly identified. Review of the AVAQMD RACT SIP Analysis and the Federal Negative Declaration 

for Three Source Categories includes Storage of Petroleum Liquids in Fixed-Roof Tanks and Petroleum Liquid Storage in External Floating Roof Tanks (CTGs referenced: Control of Volatile 

Organic Emissions from Storage of Petroleum Liquids in Fixed-RoofTanks (EPA-450/2-77-036, 12/77) and Control ofVoaltile Organic Emissions from Petroleum Liquid Storage in 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. 
Rule 1102 - Petroleum Solvent Dry Cleaners 

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) 

Applicability Dry cleaning facility using solvent other than PERC Petroleum Solvent Dry Cleaners Applicability does not include 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 additional requirements expanded applicability. comprehensive applicability. 

Cartridge filters containing paper or carbon shall 

Increased drainage time for cartridge filters from 

be fully drained in a sealed filter housing for 24 

12 to 24 hours. 

hours before removal. 

Cartridge filters containing paper or 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 not specified 

as to frequency, specificity of SCAQMD Rule 1102. 

' 

Pre-wash weight of materials/load ' 

Purchase and delivery receipts for solvent. 

Log of solvent added by operator. 

Inventory of solvent. Pre-washed weight of articles. 

Record keeping 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 petroleum solvent dry-cleaning 

SCAQMD Rule no longer allows the 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 

recent amendment. 

Evaluation of RACT and recommendation 

Update Rule 1102 to incorporate additional provisions as apply to all machines besides PERC if determined to be cost-effective. --·-·-·-··--
Rule 1104 - Wood Flat Stock Coating Operations 

SCAQMD Rule 1104 (Amended 08/13/1999, AVAQMD Rule 1104 (Amended 03/01/1991, AV Rule 1102 RACT Deficiencies 

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 attachment to the inside walls of panel for attachment to the inside walls of 

Applicability buildings, including but not limited to, homes buildings, including but not limited to, homes Same applicability. 

and office buildings, mobile homes, trailers, and office buildings, mobile homes, trailers, 

prefab buildings and similar structures, boats prefab buildings and similar structures, boats 

and ships; or a finished exterior 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 for 

Wood flat stock coatings, inks, and adhesives wood panels- <250 g/1 of coating or 

for interior 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 flat stock inks - <300 g/1 of VOC per wood flat stock coatings for exterior wood 

Requirements less water and exempt compound. liter of ink, less water and exempt siding exceed the limits in SC RACT version. 

compound. 

Added reference to Rule 1171- Solvent *Wood flat stock coatings for exterior wood No Rule 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, Exemption Same test methods, AECP, Exemptions cited. 

Notes AV SIP rule was the SC version prior to their 

most current amendment. 

Applicable CTGs 

Control of Volatile Organic Compounds Emissions from Existing Stationary Sources Volume VII: Factory Surface Coating of Flatwood Panelling ( EPA-450/2-78-032, June 1978) 

Evaluation 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 

justification of the seasonal 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 recommendation 

Rule 1110.2 is not RACT. Rule 1110.2 must be updated to remove the Ag exemption and address other EPA comments 

identified in the LA/LD (69 FR 21482, 04/21/2004). -······---·--··---·--- -----···- ------
Rule 1141.1 - Coatings and Ink Manufacturing 

AVAQMD Rule 1141.1- Coatings and Ink 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) 

Coatings manufacturer- establishment that Coatings manufacturer - establishment that 

mixes, blends, and/or compounds paints, mixes, blends, and/or compounds paints, 

varnishes, lacquers, enamels, shellacs, or sealers, varnishes, lacquers, enamels, shellacs, or sealers, 

Applicability and is classified as 2851 in the SIC Manual. and is classified 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 blends, and/or compounds printing inks and is 

classified as 2893 in the SIC Manual. classified as 2893 in the SIC Manual. 

Definitions Still have definition for ROG. Definition added 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 

! 

Maintain 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 solvent 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 exemption. 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. May be removed from AVAQMD 

.. 

rule if no longer necessary . 
Rule 1141.1 -Coatings and Ink Manufacturing 

AVAQMD Rule 1141.1 - Coatings and Ink SCAQMD Rule 1141.1 - Coatings and Ink 

Manufacturing Manufacturing RACT Deficiencies 

Permit application linked to filing of compliance This provision has been removed from SCAQMD 

Fees plan. May be required to submit engineering rule. May be removed from AVAQMD rule if no 

evaluation fee as well. longer necessary. 

Applicable CTGs 

Control of Volatile Organic Emissions from Existing Stationary Sources, Volume 1: Control Methods for Surface Coating Operations (EPA-450/2-76-028, 11/76, NTIS PB-260 

386) 

Control of VOC Emissions from Ink and Paint Manufacturing Processes (EPA-450/3-92-013, 4/92) 

Evaluation for RACT and recommendation 

Update Rule 1141.1 to address deficiencies noted in RACT rule analysis with SCAQMD Rule 1141.1, or file FND. 
Rule 1145- Plastic, Rubber and Glass Coatings 

AV Rule 1145 - Plastic, Rubber, and Glass SC Rule 1145 - Plastic, Rubber, leather, and Glass 

RACT Deficiencies 

Coatings 1 Coatings 

SIP 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 Evaluate if need to expand applicability to include Applicability coatings to any plastic, rubber or glass product. 

coatings 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 definitions as needed and add definitions 

Definitions 

leather antique coating, leather color coating, for leather coatings if leather is added to 

leather sealer coating, leather stain coating, applicability. leather top coating, refrigerated glass door 

coating, vacuum metalizing/physical vapor 

deposition. 

Several higher VOC limits: General Coatings (one- Added categories: extreme performance, leather, Update VOC limit 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 in Add extreme performance coating qualification, 

Requirements 

1151. Added qualification for classification as extreme 

update transfer efficiency requirement, remove 

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 sole coating. 

Evaluation of RACT and recommendation 

Update Rule 1145 to address deficiencies noted in RACT rule analysis with SCAQMD Rule 1145. 

Applicable CTGs 

CTG for Miscellaneous 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 separated from the SCAQMD on 07/01/1997, prior to the submission 

of this rule to USEPA on 08/01/1997. The SCAQMD approval of the 02/14/1997 version (05/04/1999, 64 FR 23774) specifically excluded the AVAQMD from the aproval action. 

The RACT analysis will compare the rulebook version to the SCAQMD SIP 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 of Oxkfes of Nitrocen SCAQMO Rule 1146 · Emissions of Olcldes of Nluocen SIVUAPCO Ru1e 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 or creater than S million Btu per hour rated heat to or creater than S million Btu per hour rated heat 

Input (a~eoity used in all industrlal,lnstltudonal input capadty used In all industrial, Institutional Any eueous fuel or liquid fuel fired boiler. steam 

Applicability operations with the exception of boners used by eltttrk: operations with the exception of bolters used by electric generator, or process heiter with a total rated heat utilities to aenerate electricity, 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 petroleum refinerl4>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 rated heat Input capacity~ S million 

Btu/hr, annual heat unput s: 90,000 Therms shall: 

main ain stack cas [0 2) at s 3% on a dry basis for any 

conse<:utive 15-min 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 continuous in,..stack nRrocen oxfdeJ ./ ./ CEMS for i.OY unit subject to emiss&on limits or 

monitor or equiva&ent verifiution system in compliance approved •ttemative monitorinc system 

with 40 CFR 60 Appendix B Spec. 2. 

30 ppm Nox 

~ 10 million Btu/hr and burnin& raseous fuels 400ppmCO Will survey affected units for 

Emission Limits a: 10 million Btu/hr and burning combination of 30ppmNox applicability aMI determine if fc 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/Gaseous • 15 ppmv 

~ 20 MMBtu/hr Enhanced/Gaseous • 9 ppmv 

UquM:t - 40 ppmv 

C0 - 400ppm 

Std/G•seous- 9 ppmv 

> 20 MMBtu/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 billion Gaseous · 30 ppmv 

Liquid - 40 ppmv Btu/vur to 30 billion Btu/ve•r C0 -400 ppmv 

Unit in which the ,.ted heat input of each burner Js sS 

MMBtu/hr bvt total of all burners in unit is> 5 Gaseous - 30 ppmv 

MM8tv/hr, and the products of combustion do not Liquid • 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 limits for liquid 

Boilers, steam generators, and process heaters that are Gaseous fuel 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 total rated heat input of 2.0 process heaters in applicability. Both liquid and 

million Btu per hour rated heat input capacity used in million Btu per hour up to and including 5.0 MMBtu/hr. gaseous have same limit in AVAQMD rule, where liquid 

any industrial, institutional, or commercial operation. fired units in SJUAPCD rule has higher NOx limit for 

liquid fueled units. 

Definitions Many definitions have been added or modified. May need to be updated for clarification or new 

requirements. 

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 less than 18,000 therms per calendar 3. Kilns, humidifiers, and smelters where the products 

year. of combustion come in direct contact with the material 

to be heated. 

Exemptions Records list cumulative fuel annual 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, submit compliance plan. burning other than PUC fuel during an approved 

curtailment. 

The AVAQMD is not nonattainment for PM 10 and SOx, 

and does not need to incorporate these limits in the 

Requirements; Standards for NOx and CO. 

Standards for NOx, CO, PM and SOx, as well as new and rule. The requirements for new and replacement units 

replacement atmospheric and non-atmospheric 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 Contains 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 operational 

Monitoring Provisions I Tune-up provision, operational non-resettable, characteristics once a month. Add monthly monitoring of manufacturer 

totalizing mass or volumetric flow meters on each line. Operational non-resettable, totalizing mass or recommended operational characteristics. 

volumetric flow meters on each line, or a master meter. 

Test Methods May need to update several test methods referenced. 

Recordkeeping 2 years 5 years Update record retention to 5 years. 

Additional 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 Heaters1 

SJVUAPCD Rule 4307 - Boilers, Steam Generators, and 

AVAQMD Rule 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 

updating requirements during 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 Emissions from Utility Boilers, USEPA 452/R-93-008, March 1994. 

1 The SCAQMO rule amendment in the SIP is identical to the AVAQMD rule book version. SCAQMD most recently amended Rule 1146.1 - Emissions of Oxides of Nitrogen from Small Industrial, Institutional, 

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 submitted this amendment to USEPA. The prior 09/0S/2008 SC amendment received proposed limited Disapproval/limited Approval from US EPA. 
AVAQMD Rule 1176- VOC Emissions From Wastewater Systems 1 

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 

manufacturing products by chemical processes. Any facility or operation that has 

Applicability 282 as the first three digits in its Standard Industrial Classification Code as 

defined in the Standard Industrial Classification Manual is included in this 

definition), and industrial facilities (engaged in the production and distribution of natural 

gas, pipeline distribution or wholesale distribution of crude petroleum and petroleum 

products except gasoline, as classified under the Standard Industrial Classification group 

numbers 492, 461, or 517, respectively, 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 Industrial Wastewater source category (referencing socuments: Air Emissions from Industrial 

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 Separators, and Process Unit Turnarounds (EPA450/2-77-025, 10/77)). Although Rule 1176 was not specifically referenced in the RACT SIP Analysis, this source 

category has been FNDed. Rule can be rescinded as there are no sources subject to the applicability of the rule in 

theAVAQMD.