UNITED STATES ENVIRONMENTAL PROTECTIONAGENCY 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 SIPrevision to demonstrate how the District's rules meet 11new 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 fewpotential approvability issues, the majority of our commentsbelow focus on areas where additional clarification would be helpful. Potential approvability issues: 1. pg 7 -Rule 74.12, amended 4/8/08, isrelied 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'srecommendation 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 isthe federally enforceable limit. Therefore, facilities canbe 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 of2.7 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 14.6lblday. Pleaseprovide details on how the actual emissions were calculated because its emissions are close to the Metal Furniture CTGthreshold of 15lblday, 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 oftheir "business activity"?
8. p27 -The sentence before Table 8 states "Matsonclaims to use no more than 5 gallons of coating per year onplastic 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 15lbslday for "plastic parts", but is permitted for 38 lblday. Sincethe District doesnot have a Plastic Parts rule, the RACT SIP should briefly discuss actions the District would consider if Matson's emissions exceed 15lbslday. The CTG's 15lblday 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?
11.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 asthe 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 (415) 947-4 122. Sincerely,

Chief, Rulemaking Office

cc: Ravi Ramalingam (CARB)