UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105 

August 25, 2009 

Mr. Michael Villegas 

Air Pollution Control Officer 

Ventura County Air Pollution Control District 

669 County Square Drive 

Ventura, CA 93003 

Re: 2009 Reasonably Available Control Technology (RACT) State Implementation Plan 

(SIP) Revision, dated July 29,2009 

Dear Mr. Villegas: 

Ventura County Air Pollution Control District (VCAPCD) submitted to EPA a draft 2009 

RACT SIP revision to demonstrate how the District's rules meet 11 new Control Technique 

Guidelines (CTGs) issued in 2006,2007 and 2008. We greatly appreciate the District's efforts to 

complete the analysis. While there are a few potential approvability issues, the majority of our 

comments below focus on areas where additional clarification would be helpful. 

Potential approvability issues: 

1. pg 7 - Rule 74.12, amended 4/8/08, is relied on to meet the Miscellaneous Metal and Plastic 

Parts CTG. The District should submit this amendment to EPA for SIP approval. 

2. pg 21 - Rule 74.19's 80 g/l (8%) VOC limit for fountain solutions is less stringent than the 

Lithographic and Letterpress CTG's recommendation of 50 g/l(5%) alcohol or alcohol 

substitutes for sheet-fed offset lithographic printing. Although the District points out that all 

permitted sources in the county meet the 50 g/l limit, and no actual reductions would be achieved 

by changing the limit, we note that SIP approved Rule 74.19's 8% VOC limit is the federally 

enforceable limit. Therefore, facilities can be in compliance with the rule, but not meet the CTG. 

The District should amend Rule 74.19 to meet the CTG or demonstrate that total fountain 

solution emissions are de-minimis with a 5% analysis. 

Clarification required: 

3. pg 4 - The metal furniture coating category was not a negative declaration in the District's 

2006 RACT SIP, but is a negative declaration for the 2009 revised RACT SIP. A brief 

discussion would be helpful on why this category is now a negative declaration. 

4. pg 11 - Table 2 Pentair Pool Products and Perma Plaque's actual emissions are close to CTG 

threshold of 2.7 tpy before controls. Please clarify whether Pentair and Perma's actual emissions 

are "before controls". 

5. pg 14 Table 3 shows Artistic Design has average actual emissions of 14.6 lblday. Please 
provide details on how the actual emissions were calculated because its emissions are close to 

the Metal Furniture CTG threshold of 15 lblday, and the District is submitting a negative 

declaration for this category. (i.e., is the District's assumption of 2080 hrlyr of operation and 

8hrsIday valid considering the CTG's 2.7 tpy threshold is based on 15 lblday and 365 days). 

6. p24 Table 6 - Graphic Arts Solvent Cleaning Requirements - contains limits for categories 

not covered by the Lithographic CTG. For clarity, the District might consider deleting 

categories not covered by the CTG or explaining that the CTG only covers Lithographic and 

Letterpress cleaning and does not cover the other categories in Table 6. 

7. p 27 - Table 8 - For the 3 facilities in the middle of Table 8, are the reported emissions for 

both plastic and metal coating operations or just plastic parts coatings? Should these companies 

also appear in Table 7 for misc metal parts since it appears to be a part of their "business 

activity"? 

8. p27 - The sentence before Table 8 states "Matson claims to use no more than 5 gallons of 

coating per year on plastic parts". Is this substantiated with written documentation? 

9. pg 27 Table 8 - WM J Matson, a metal and plastic parts coating facility, is currently below 

the CTG threshold of 15 lbslday for "plastic parts", but is permitted for 38 lblday. Since the 

District does not have a Plastic Parts rule, the RACT SIP should briefly discuss actions the 

District would consider if Matson's emissions exceed 15 lbslday. The CTG's 15 lblday threshold 

applies to the total VOC emissions from all metal and plastic parts coating operations at a 

facility. 

10. p27 - Second paragraph after Table 8 states ". . . emissions from metal furniture operations:". 

Should this say "miscellaneous metal parts" instead of "metal furniture" operations? 

1 1. pg 27 - The last paragraph states "One limit in Rule 74.12 is less stringent than the related 

limit in the CTG and other rules: Extreme High Gloss Limit". The District may want to revise 

this statement as Table 9 shows Rule 74.12 has the same limit as the CTG, it is only less 

stringent than the South Coast limit. 

Suggestion: 

12. pg 28 - This comment is not directed at the 2009 revised RACT SIP. The District may want 

to consider replacing the 65% transfer efficiency requirement in Rule 74.12, and other coating 

rules, with a requirement that alternative spray application equipment have a transfer efficiency 

equal to or better than HVLP. This allows spray guns with a higher transfer efficiency than 

HVLP, but where neither the alternative nor the HVLP gun can achieve 65% transfer. 

If you have any questions regarding these comments, please feel free to contact me or 

Stanley Tong at (4 1 5) 947-4 122. 

Sincerely, 

Chief, Rulemaking Office 

cc: Ravi Ramalingam (CARB)