Antelope Valley 

Air Quality Management District 

Final 

Staff Report 

Adoption of the 

2015 8-Hour Reasonably Available Control 

Technology – State Implementation 

Plan Analysis (2015 RACT SIP Analysis)

Adopted on 

July 21, 2015 

43301 DIVISION ST., SUITE 206,

LANCASTER, CALIFORNIA 93535-4649 

PHONE (661) 723-8070 

FAX (661) 723-3450 
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STAFF REPORT 

TABLE OF CONTENTS 

2015 8-Hour Reasonably Available Control Technology – State 

Implementation Plan Analysis (2015 RACT SIP Analysis) 

I. PURPOSE OF STAFF REPORT ........................................................................................... 1

II. EXECUTIVE SUMMARY .................................................................................................... 1

III. STAFF RECOMMENDATION ............................................................................................ 2

IV. LEGAL REQUIREMENTS CHECKLIST ........................................................................... 3

V. DISCUSSION OF LEGAL REQUIREMENTS ................................................................... 4

A. REQUIRED ELEMENTS/FINDINGS ........................................................................... 4

1. State Findings Required for Adoption of Rules & Regulations ...................... 4

a. Necessity .............................................................................................. 4

b. Authority .............................................................................................. 4

c. Clarity ................................................................................................... 4

d. Consistency .......................................................................................... 4

e. Non-duplication .................................................................................. 5

f. Reference .............................................................................................. 5

g. Public Notice & Comment, Public Hearing ......................................... 5

2. Federal Elements (SIP Submittals, Other Federal Submittals) ........................ 5

a. Satisfaction of Underlying Federal Requirements ............................... 5

b. Public Notice and Comment ................................................................ 5

c. Availability of Document ..................................................................... 5

d. Notice to Specified Entities ................................................................. 6

e. Public Hearing....................................................................................... 6

f. Legal Authority to Adopt and Implement ............................................ 6

g. Applicable State Laws and Regulations Were Followed ..................... 6

B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS ......................................... 6

C. ECONOMIC ANALYSIS .............................................................................................. 6

1. General ............................................................................................................. 6

2. Incremental Cost Effectiveness....................................................................... 7

D. ENVIRONMENTAL ANALYSIS (CEQA) .................................................................. 7

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS ................................................. 7

1. Potential Environmental Impacts ..................................................................... 7

2. Mitigation of Impacts ....................................................................................... 8

3. Alternative Methods of Compliance ................................................................ 8
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F. PUBLIC REVIEW .......................................................................................................... 8

VI. TECHNICAL DISCUSSION ............................................................................................... 8

A. SIP HISTORY ................................................................................................................ 9

1. SIP History ....................................................................................................... 9

2. SIP Analysis ..................................................................................................... 9

Appendix A – 2015 8-Hour Reasonably Available Control Technology – State Implementation Plan 

Analysis (2015 RACT SIP Analysis) Draft Version .............................................................A-1

Appendix B - Public Notice Documents ..................................................................................... B-1

Appendix C - Public Comments and Responses ......................................................................... C-1

Appendix D - California Environmental Quality Act Documentation ........................................D-1

Appendix E - Bibliography .......................................................................................................... E-1
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STAFF REPORT 

2015 8-Hour Reasonably Available Control Technology – State 

Implementation Plan Analysis (2015 RACT SIP Analysis) 

I. PURPOSE OF STAFF REPORT 

A staff report serves several discrete purposes. Its primary purpose is to provide a summary and 

background material to the members of the Governing Board. This allows the members of the 

Governing Board to be fully informed before making any required decision. It also provides the 

documentation necessary for the Governing Board to make any findings, which are required by law to 

be made prior to the approval or adoption of a document. In addition, a staff report ensures that the

correct procedures and proper documentation for approval or adoption of a document have been 

performed. Finally, the staff report provides evidence for defense against legal challenges regarding

the propriety of the approval or adoption of the document. 

II. EXECUTIVE SUMMARY 

The Antelope Valley Air Quality Management District (AVAQMD) Governing Board is being 

requested to conduct a public hearing, make findings, and then adopt a resolution adopting the 2015 8-

hour Reasonably Available Control Technology – State Implementation Plan Analysis (RACT SIP 

Analysis), and direct staff actions. 

The Federal Clean Air Act (FCAA) requires areas designated non-attainment and classified moderate 

and above to implement Reasonably Available Control Technology (RACT) for sources subject to 

Control Technique Guidelines (CTG) documents issued by the United States Environmental Protection 

Agency (USEPA) for “major sources” of volatile organic compounds (VOCs) and oxides of nitrogen 

(NOx) which are ozone precursors. Effective May 27, 2008 (73 FR 16436, March 27, 2008), USEPA 

lowered the primary ozone National Ambient Air Quality Standard (NAAQS) from 0.084 parts per 

million (ppm) to 0.075 ppm. For purposes of the FCAA, the District has been designated nonattainment for ozone and classified as Severe-15 for the 8-hour standard. As a result of this change,

USEPA is requiring that all non-attainment areas adopt and submit an updated RACT SIP Analysis to 

ensure that District Rules adequately address current RACT requirements. 

In 2006 the AVAQMD adopted the 8-Hour Reasonably Available Control Technology – State 

Implementation Plan Analysis (RACT SIP Analysis) in response to change on March 9, 2006 of the 

previous ozone standard from measurement on a one- hour basis (1-hour ozone standard) to an eighthour basis (8-hour ozone standard). On September 11, 2006, USEPA provided comments on the 2006 

RACT SIP Analysis requesting additional analysis on several rules to determine if they still represented 

RACT 1. On March 13, 2014, the AVAQMD sent the 8-hour Ozone Reasonably Available Control 

Technology (RACT) State Implementation Plan (SIP) Analysis – Supplemental Analysis addressing 

 

1

 USEPA comment letter Re: 8-hour Ozone Reasonably Available Control Technology – State 

Implementation Plan (RACT SIP) Analysis, dated August 2006. September 11, 2006. 
2 AVAQMD RACT SIP Analysis 

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these comments and providing the requested analysis of those rules identified by USEPA 2. This 

update was not acted on by the Governing Board pursuant to USEPA direction. 

The AVAQMD must now adopt an updated 2015 RACT SIP Analysis for the 2008 0.075 ppm 8-hour 

ozone NAAQS. The information contained in the original 2006 RACT SIP Analysis, the information in 

the supplemental 2014 RACT SIP Analysis, together with this document, will comprise an analysis 

sufficient to satisfy the RACT SIP Analysis request for the 0.075 ppm 8-hour ozone NAAQS. The

resultant 2015 RACT SIP Analysis will, upon adoption, be submitted to USEPA for approval. 

The public hearing to consider the adoption of the 2015 RACT SIP Analysis was originally noticed for 

the May 19, 2015 Governing Board meeting. The AVAQMD received substantive comments from 

USEPA and continued the hearing to June 16, 2015 and again to July 21, 2015 to address the 

comments. 

III. STAFF RECOMMENDATION 

Staff recommends that the Governing Board of the AVAQMD, after conducting a public hearing, adopt 

the proposed 2015 8-hour Reasonably Available Control Technology – State Implementation Plan 

Analysis (RACT SIP Analysis). Such action is necessary because portions of the AVAQMD has been 

designated ozone non-attainment areas and classified Severe-15 for the 8-hour ozone standard. 

Therefore the AVAQMD must submit an updated RACT SIP Analysis to the USEPA pursuant to the 

FCAA. 

The Governing Board of the Antelope Valley Air Quality Management District adopted the 2015 

RACT SIP Analysis on July 21, 2015. 

 

2

 AVAQMD letter Re: 8-hour Ozone Reasonably Available Control Technology (RACT) State 

Implementation Plan (SIP) Analysis – Supplemental Analysis. March 13, 2014. 
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IV. LEGAL REQUIREMENTS CHECKLIST 

The findings and analysis as indicated below are required for the procedurally correct adoption of the

2015 8-Hour Reasonably Available Control Technology – State Implementation Plan Analysis (RACT 

SIP Analysis). Each item is discussed, if applicable, in Section V below. Copies of documents are 

included in the appropriate Appendix. 

FINDINGS REQUIRED FOR 

RULES & REGULATIONS 

 X Necessity 

 X Authority 

 X Clarity 

 X Consistency 

 X Non-duplication 

 X Reference 

 X Public Notice & Comment 

 X Public Hearing 

REQUIREMENTS FOR STATE 

IMPLEMENTATION PLAN 

SUBMISSION (SIP): 

 X Public Notice & Comment 

 X Availability of Document 

 X Notice to Specified Entities (State, 

Air Districts, USEPA, Other States) 

 X Public Hearing 

 X Legal Authority to adopt and 

implement the document. 

 X Applicable State laws and 

regulations were followed. 

ELEMENTS OF A FEDERAL 

SUBMISSION 

 X Elements as set forth in applicable 

Federal law or regulations. 

CALIFORNIA ENVIRONMENTAL 

QUALITY ACT REQUIREMENTS 

(CEQA): 

N/A Ministerial Action 

 X Exemption 

N/A Negative Declaration 

N/A Environmental Impact Report 

N/A Appropriate findings, if necessary. 

 X Public Notice & Comment 

SUPPLEMENTAL ENVIRONMENTAL 

ANALYSIS (RULES & REGULATIONS 

ONLY): 

 X Environmental impacts of 

compliance. 

N/A Mitigation of impacts. 

N/A Alternative methods of compliance. 

OTHER: 

 X Written analysis of existing air 

pollution control requirements 

 X Economic Analysis 

 X Public Review 
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V. DISCUSSION OF LEGAL REQUIREMENTS 

A. REQUIRED ELEMENTS/FINDINGS 

This section discusses the State of California statutory requirements that apply to the adoption 

of the 2015 RACT SIP Analysis. Since this document is required to be adopted pursuant to 

public notice and other requirements under 42 USC 7410(a)(2), the District considers the rule 

adoption process pursuant to H&S Code §40702 to be a proper way to meet these requirements. 

Therefore, these are actions, that need to be performed, and/or information, that must be 

provided in order to adopt this document in a procedurally correct manner. 

1. State Findings Required for Adoption of Rules & Regulations: 

Before adopting, amending, or repealing a rule or regulation, the Governing Board of 

the AVAQMD is required to make findings of necessity, authority, clarity, consistency, 

non-duplication, and reference based upon relevant information presented at the hearing. 

The information below is provided to assist the Governing Board in making these 

findings. 

a. Necessity: 

The adoption of the 2015 RACT SIP Analysis is necessary because the 

AVAQMD has been designated as an ozone non-attainment area and classified 

Severe-15 for the 0.075 ppm 8-hour ozone standard. Therefore, the AVAQMD 

must submit a RACT SIP Analysis to the USEPA pursuant to the FCAA.

b. Authority: 

AVAQMD has the authority pursuant to California Health and Safety Code 

(H&S Code) §40702, 40725-40728 to adopt, amend or repeal rules and 

regulations that are necessary or proper to execute the powers and duties granted 

to and imposed upon AVAQMD. While this action is not specifically a rule or 

regulation it is a document necessary to execute the powers and duties grant to 

and imposed upon the AVAQMD. 

c. Clarity: 

The 2015 RACT SIP Analysis is clear in that it is written so that the persons

evaluating the analysis can easily understand the meaning. 

d. Consistency: 

The 2015 RACT SIP Analysis is in harmony with, and not in conflict with or 

contradictory to any state law or regulation, federal law or regulation, or court 

decisions. This document is required to be developed pursuant to the FCAA and 

the regulations promulgated thereunder. 
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e. Non-duplication: 

The adoption of the 2015 RACT SIP Analysis does not impose the same 

requirements as an existing state or federal law or regulation because federal law 

requires either certification of RACT status or updating rules to current RACT. 

f. Reference: 

The AVAQMD has the authority pursuant to H&S Code §40702 to adopt, 

amend or repeal rules and regulations and other documents required to execute 

the powers and duties granted to and imposed upon the AVAQMD. 

g. Public Notice & Comment, Public Hearing: 

Notice for the public hearing for the adoption the 2015 RACT SIP Analysis was 

published April 17, 2015. This hearing was continued to June 16, 2015 and again 

to July 21, 2015. See Appendix “B” for a copy of the public notice. See 

Appendix C for copies of comments, if any, and AVAQMD responses. 

2. Federal Elements (SIP Submittals, Other Federal Submittals). 

Submittals to USEPA are required to include various elements depending upon the type 

of document submitted and the underlying federal law which requires the submittal. 

The information below indicates which elements are required for the adoption of the 

2015 RACT SIP Analysis and how they were satisfied. 

a. Satisfaction of Underlying Federal Requirements: 

The adoption of the 2015 RACT SIP Analysis is subject to all the requirements 

for a SIP submittal because the 2015 RACT SIP Analysis is included in the 

AVAQMD SIP. The criteria for determining completeness of SIP submissions 

are set forth in 40 CFR Part 51, Appendix V, 2.0. 

b. Public Notice and Comment: 

Notice for the public hearing for the proposed adoption of the 2015 RACT SIP 

Analysis was published April 17, 2015. This hearing was continued to June 16, 

2015 and again to July 21, 2015. See Appendix “B” for a copy of the public 

notice. 

c. Availability of Document: 

Copies of the proposed 2015 RACT SIP Analysis and the accompanying draft 

staff report were made available to the public on or before April 17, 2015. 
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d. Notice to Specified Entities 

Copies of the proposed 2015 RACT SIP Analysis and the accompanying draft 

staff report were mailed to all affected agencies, including but not limited to 

CARB and USEPA. The proposed RACT SIP Analysis was sent to CARB and 

USEPA on April 17, 2015. 

e. Public Hearing: 

A public hearing to consider the proposed adoption of the 2015 RACT SIP 

Analysis was set for May 19, 2015. This hearing was continued to June 16, 2015 

and again to July 21, 2015 to address comments received from USEPA. 

f. Legal Authority to Adopt and Implement: 

The AVAQMD has the authority pursuant to H&S Code §40702 to adopt, 

amend, or repeal rules and regulations and to do such acts as may be necessary 

or proper to execute the duties imposed upon the AVAQMD. 

g. Applicable State Laws and Regulations Were Followed: 

Public notice and hearing procedures pursuant to H&S Code §§40725-40728 

have been followed. See Section (V)(A)(1) above for compliance with state 

findings required pursuant to H&S Code §40727. See Section (V)(B) below for 

compliance with the required analysis of existing requirements pursuant to H&S 

Code §40727.2. See Section (V)(C) for compliance with economic analysis 

requirements pursuant to H&S Code §40920.6. See Section (V)(D) below for 

compliance with provisions of the California Environmental Quality Act 

(CEQA). 

B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS 

H&S Code §40727.2 requires air districts to prepare a written analysis of all existing federal air 

pollution control requirements that apply to the same equipment or source type as the rule 

proposed for modification by the district. The adoption of the 2015 RACT SIP Analysis is to 

ensure that District rules adequately address current RACT requirements. Therefore the 

preparation of a written analysis of existing pollution control requirements that apply to the 

same equipment or source type is not required. The individual rule actions identified as a result 

of this analysis will be specifically evaluated to satisfy this requirement on a case-by-case basis 

through the rule amendment process. 

C. ECONOMIC ANALYSIS 

1. General 
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Adoption of the 2015 RACT SIP Analysis affects those facilities subject to rules 

requiring amendment to meet RACT requirements. The 2015 RACT SIP Analysis

identifies necessary rule actions. Cost analysis will be addressed on a rule specific basis 

for those actions identified in the 2015 RACT SIP Analysis through the rule amendment 

process. 

2. Incremental Cost Effectiveness 

Pursuant to H&S Code §40920.6, incremental cost effectiveness calculations are 

required for rules and regulations which are adopted or amended to meet the California 

Clean Air Act requirements for Best Available Retrofit Control Technology (BARCT) 

or “all feasible measures” to control volatile compounds, oxides of nitrogen or oxides of 

sulfur. The adoption of the 2015 8-Hour Reasonably Available Control Technology – 

State Implementation Plan Analysis (RACT SIP Analysis) is not subject to incremental 

cost effectiveness calculations because this document does not impose BARCT or “all 

feasible measures.” Potential environmental effects will be addressed on a rule by rule 

basis through the rule amendment process as specific rule changes and their potential 

impacts are currently not foreseeable. 

D. ENVIRONMENTAL ANALYSIS (CEQA) 

Through the process described below, it was determined that a Notice of Exemption would be 

the appropriate CEQA process for the adoption of the 2015 RACT SIP Analysis. 

1. The adoption of the 2015 RACT SIP Analysis meets the CEQA definition of 

“project.” It is not a “ministerial” action. 

2. The adoption of the 2015 RACT SIP Analysis is exempt from CEQA review 

because it will not create any adverse impacts on the environment. Because 

there is no potential that the adoption might cause the release of additional air 

contaminants or create any adverse environmental impacts, a Class 8 categorical 

exemption (14 Cal. Code Reg. §15308) applies. Potential environmental effects 

are currently not foreseeable as the particular rule amendments have not been 

identified with enough specificity at this time. Therefore, environmental effects 

will be addressed on a rule by rule basis through the rule amendment process as 

specific rule changes and their potential impacts are currently not foreseeable. 

Copies of the documents relating to CEQA can be found in Appendix “D.” 

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS 

1. Potential Environmental Impacts 

There are no potential negative environmental impacts of compliance with the adoption 

of the 2015 RACT SIP Analysis. Potential environmental effects will be addressed on a 

rule by rule basis through the rule amendment process as specific rule changes and their 

potential impacts are currently not foreseeable. 
8 AVAQMD RACT SIP Analysis 

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2. Mitigation of Impacts 

N/A 

3. Alternative Methods of Compliance 

N/A 

F. PUBLIC REVIEW 

See Staff Report Section (V)(A)(1)(g) and (2)(b), as well as Appendix B. 

VI. TECHNICAL DISCUSSION 

The FCAA requires that ozone non-attainment areas implement RACT for sources that are 

subject to CTGs and for major sources of ozone precursors. The 2015 RACT SIP Analysis

document: (1) reviews all available instances of RACT for applicability to the AVAQMD; (2) 

reviews all AVAQMD major sources for RACT applicability; and (3) identifies any actions the 

AVAQMD must take to address applicable RACT requirements. This document satisfies 42 

U.S.C. §§7511a (FCAA §182) regarding RACT requirements for the 8-hour ozone National 

Ambient Air Quality Standard (NAAQS). 

The AVAQMD has evaluated its adopted rules and all of its major sources of ozone precursors 

to ensure that current rules meet the definition of RACT. A current and complete analysis for 

each rule will be completed at the time of each specific rule amendment. Those reasons 

identified below as a basis for updating the rule to federal RACT are not necessarily inclusive 

of all rule changes that will be made at the time of amendment. This section gives a brief 

overview of the elements identified for further action proposed in the 2015 RACT SIP Analysis. 

Complete rule analysis is available in the 2015 RACT SIP Analysis presented in Appendix “A” 

of this Staff Report. 

The AVAQMD 2012 CARB inventory includes stationary source NOX emissions from mobile 

sources. In particular, Lancaster Landfill and Recycling Center and Granite Construction were 

not major stationary sources of NOX in 2012, when mobile source emissions are accounted for. 

Summary of Rules to be amended to update Federal RACT requirements 

Rule 462 – Organic Liquid Loading to be amended to address deficiencies in the Limited 

Approval/Limited Disapproval in the NPRM issued 62 FR 26560, 05/14/1997. 

Rule 1107 – Coating of Metal Parts and Products is consistent with CTG control 

recommendations, but several VOC limits in SCAQMD Rule 1107 are lower and have been 

identified as RACT. 

Rule 1110.2 – Emissions from Gaseous and Liquid Fueled Internal Combustion Engines is not 

a RACT rule but will be updated to meet other federal requirements. Rule 1110.2 must be 

updated to remove the agricultural exemption and address other USEPA comments identified in 

the LA/LD (69 FR 21482, 04/21/2004). 
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Rule 1145 – Plastic, Rubber and Glass Coatings to be amended to incorporate additional 

RACT provisions identified in SCAQMD Rule 1145, including but not limited to updating 

definitions, possibly adding several coating categories and VOC limits, transfer efficiency, and 

updating test methods. 

Rule 1146 - Emissions Of Oxides Of Nitrogen From Industrial, Institutional And Commercial 

Boilers, Steam Generators, And Process Heaters. Will survey affected units for applicability 

and determine if it is feasible to update limits as RACT. 

Rule 1151 – Motor Vehicle and Mobile Equipment Coating Operations will be amended to 

incorporate provisions of Control Techniques Guidelines for Automobile and Light-Duty Truck 

Assembly Coating as applicable to “Heavier” vehicles, which includes all vehicles that meet the 

definition of the term “other motor vehicles”, as defined at 40 CFR §63.3176. BYD Coach and 

Bus is not a major source but is permitted above the CTG for Automobile and Light Duty Truck 

Assembly Coatings (EPA-453/R-08-006, September 2008) threshold. 

Rule 1171 – Solvent Cleaning Operations will be amended to include work practices, adjust 

categories for consistency with source specific rules, include alternative composite vapor 

pressure limit 

A. SIP HISTORY 

1. SIP History. 

The AVAPCD came into existence pursuant to statute on July 1, 1997 Health & Safety 

Code 40106, A.B. 266-Knight Ch. 542, statutes of 1996). The rules and regulations of 

the SCAQMD remain in effect within the AVAPCD until the AVAPCD Governing 

Board adopts, amends or rescinds new ones (H&S Code 40106(e)). Since the SIP 

applies to the territory for which it was approved at the time it was approved, the 

AVAPCD also inherited the SCAQMD SIP applicable to the Los Angeles County 

portion of the South East Desert Air Basin (now called the Mojave Desert Air Basin) 

prior to July 1, 1997. On January 1, 2002 the AVAQMD was created pursuant to statute 

H&S Code 41300 et seq.) to replace the AVAPCD. Once again the SIP in effect at the 

time of the change remained in effect until the AVAQMD Governing Board superceded, 

amended or rescinded it. There is no equivalent document to the 2015 RACT SIP 

Analysis currently in the AVAQMD SIP.

2. SIP Analysis. 

The 2015 RACT SIP Analysis will be submitted to the USEPA for inclusion into the 

State Implementation Plan. 
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APPENDIX “A”

Draft Version 

Please see the AVAQMD 2015 8-Hour Reasonable Available Control Technology – State 

Implementation Plan Analysis (2015 RACT SIP Analysis) as attached to the Resolution contained in the 

July 21, 2015 adoption package. 
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APPENDIX "B" 

PUBLIC NOTICE DOCUMENTS

1. Proof of Publication for Notice of Public Hearing – Antelope Valley Press, 04/17/2015 
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APPENDIX "C" 

PUBLIC COMMENTS AND RESPONSES

1. EPA Comments (2015 AV RACT SIP D1 JS COMMENTS st 5-1-15 (2)) 

2. EPA Email, Subject: AVAQMD Negative Declarations, 07/06/2015 
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1. EPA Comment 
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Comment [SJ1]

1. Potential to emit exceeds major source threshold. 

2. Required to obtain a Title V permit under 40 CFR Part 60 subpart WWW §60.752(b). 

3. The 2012 CARB inventory of 39.8 tons of NOX for this facility includes emissions of 37.64 

tons of NOX from mobile sources. 

4. The 2012 CARB inventory of 32 tons of NOX for this facility includes emissions of 30.74 tons

of NOX from mobile sources. 

Comment [TS2] 

A statement was added to the RACT SIP Analysis that a current and complete rule analysis will 

be completed at the time of specific rule amendment. See page 15 of the RACT SIP Analysis. 

Comment [TS3] 

A current and complete rule analysis will be completed at the time of specific rule amendment. 

This will include evaluation of the limit included in BAAQMD Reg 8-33. 

Comment [TS4] 

No source exceeds the CTG threshold. A FND will be filed. 

Comment [TS5] 

A FND will be filed. 

Comment [TS6] 

Removed from list. 

Comment [TS7] 

A current and complete rule analysis will be completed at the time of specific rule amendment. 

This will include evaluation of the limit included in BAAQMD Reg 8-33. 

Comment [TS8] 

1. Rule 1171 has been added to list of rules to update. 

2. A FND will be filed. 

Comment [TS9] 

A FND will be filed for Rule 1102. 

Rule 1107 will be updated to meet current Federal RACT. 

Rule 1141.1 has been removed from the list as it is not a CTG category. 

Rule 1145 will be updated to meet current Federal RACT. 

A current and complete rule analysis will be completed at the time of amendment of Rule 1146.1. 

Rule 1106.1 was analyzed and determined no RACT Update necessary at this time. 

1. District Response to EPA Comment 
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2. EPA Email 
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1. The AVAQMD will add FNDs for those source categories where there is an existing SIP rule but 

that source category does not meet the CTG threshold (Fixed-Roof Tanks, Floating Roof Tanks, Large 

Petroleum Dry Cleaners, and Flat Wood Paneling). 

2. District Response to EPA Email 
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APPENDIX "D" 

CALIFORNIA ENVIRONMENTAL QUALITY ACT 

DOCUMENTATION

(to be included as available) 

1. Notice of Exemption – Los Angeles County 
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APPENDIX "E" 

BIBLIOGRAPHY

The following documents were consulted in the preparation of this staff report and the adoption of the

8-Hour Reasonably Available Control Technology – State Implementation Plan Analysis (RACT SIP 

Analysis): 

1. 73 FR 16436, March 27, 2008 

2. 77 FR 26950, May 8, 2012 

3. 78 FR 33178, June 6, 2013 

4. USEPA – various CTGs, ACTs, and other documents 

5. USEPA – letter from Andrew Steckel, EPA Region IX to Alan De Salvio, AVAQMD, dated 

September 11, 2006 

6. California Health and Safety Code – various sections 
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