# 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

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Final Staff Report, 08/14/2015 

### STAFF REPORT TABLE OF CONTENTS 2015 8-Hour Reasonably Available Control Technology – State Implementation Plan Analysis (2015 RACT SIP Analysi s)

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 Rule s & 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 Fede ral Submittals) ........................ 5 a. Satisfaction of Underlying Federal Requireme nts ............................... 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 F ollowed ..................... 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 ..........

................................................... ... 8TC- 2 AVAQMD RACT SIP Analysis Final Staff Report, 08/14/2015 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 D ocumentation ...................................... ..D-1

Appendix E - Bibliography .........................

................................................... .............................. E-1AVAQMD RACT SIP Analysis 1

Final Staff Report, 08/14/2015 

### STAFF REPORT

2015 8-Hour Reasonably Available Control Technology – State Implementation Plan Analysis (2015 RACT SIP Analysi s)

I. PURPOSE OF STAFF REPORT

A staff report serves several discrete purposes. I ts 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 docu ment. In addition, a staff report ensures that the correct procedures and proper documentation for app roval or adoption of a document have been performed. Finally, the staff report provides evid ence for defense against legal challenges regarding the propriety of the approval or adoption of the do cument.

II. EXECUTIVE SUMMARY

The Antelope Valley Air Quality Management District (AVAQMD) Governing Board is being requested to conduct a public hearing, make finding s, and then adopt a resolution adopting the 2015 8- hour Reasonably Available Control Technology – Stat e Implementation Plan Analysis (RACT SIP Analysis), and direct staff actions.

The Federal Clean Air Act (FCAA) requires areas des ignated 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 orga nic 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 Qual ity Standard (NAAQS) from 0.084 parts per million (ppm) to 0.075 ppm. For purposes of the FC AA, the District has been designated nonattainment for ozone and classified as Severe-15 fo r the 8-hour standard. As a result of this change, USEPA is requiring that all non-attainment areas ad opt and submit an updated RACT SIP Analysis to ensure that District Rules adequately address curre nt RACT requirements.

In 2006 the AVAQMD adopted the 8-Hour Reasonably Available Control Technology – St ate 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 1 1, 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) A nalysis – Supplemental Analysis addressing

1 USEPA comment letter Re: 8-hour Ozone Reasonably A vailable Control Technology – State Implementation Plan (RACT SIP) Analysis, dated Augu st 2006. September 11, 2006.2 AVAQMD RACT SIP Analysis Final Staff Report, 08/14/2015 these comments and providing the requested analysis of those rules identified by USEPA 2 . This update was not acted on by the Governing Board purs uant 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 orig inal 2006 RACT SIP Analysis , the information in the supplemental 2014 RACT SIP Analysis , together with this document, will comprise an ana lysis 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 app roval.

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 AVAQ MD received substantive comments from USEPA and continued the hearing to June 16, 2015 an d again to July 21, 2015 to address the
comments.

III. STAFF RECOMMENDATION

Staff recommends that the Governing Board of the AV AQMD, 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 AV AQMD has been designated ozone non-attainment areas and classifie d 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 Qual ity Management District adopted the 2015 RACT SIP Analysis on July 21, 2015.

2 AVAQMD letter Re: 8-hour Ozone Reasonably Availabl e Control Technology (RACT) State Implementation Plan (SIP) Analysis – Supplemental A nalysis. March 13, 2014.AVAQMD RACT SIP Analysis 3

Final Staff Report, 08/14/2015 IV. LEGAL REQUIREMENTS CHECKLIST

The findings and analysis as indicated below are re quired 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 Review4 AVAQMD RACT SIP Analysis Final Staff Report, 08/14/2015 V. DISCUSSION OF LEGAL REQUIREMENTS

A. REQUIRED ELEMENTS/FINDINGS

This section discusses the State of California stat utory requirements that apply to the adoption of the 2015 RACT SIP Analysis. Since this document is required to be adopted pur suant to public notice and other requirements under 42 USC 7 410(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 perfo rmed, and/or information, that must be provided in order to adopt this document in a proce durally correct manner.

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

Before adopting, amending, or repealing a rule or r egulation, the Governing Board of the AVAQMD is required to make findings of necessit y, authority, clarity, consistency, non-duplication, and reference based upon relevant information presented at the hearing. The information below is provided to assist the Gov erning 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-attainme nt 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 pursua nt to the FCAA.

b. Authority:

AVAQMD has the authority pursuant to California Hea lth and Safety Code (H&S Code) §40702, 40725-40728 to adopt, amend or r epeal rules and regulations that are necessary or proper to execute the powers and duties granted to and imposed upon AVAQMD. While this action is n ot specifically a rule or regulation it is a document necessary to execute th e 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 m eaning.

d. Consistency:

The 2015 RACT SIP Analysis is in harmony with, and not in conflict with or contradictory to any state law or regulation, feder al law or regulation, or court decisions. This document is required to be develop ed pursuant to the FCAA and the regulations promulgated thereunder.AVAQMD RACT SIP Analysis 5

Final Staff Report, 08/14/2015

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 upd ating 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 doc uments required to execute the powers and duties granted to and imposed upon t he 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 continu ed to June 16, 2015 and again to July 21, 2015. See Appendix “B” for a copy of t he public notice. See Appendix C for copies of comments, if any, and AVAQ MD 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 la w 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 completen ess 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 adop tion of the 2015 RACT SIP Analysis was published April 17, 2015. This hearing was co ntinued 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 o r before April 17, 2015.6 AVAQMD RACT SIP Analysis Final Staff Report, 08/14/2015 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 contin ued to June 16, 2015 and again to July 21, 2015 to address comments rece ived 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 su ch acts as may be necessary or proper to execute the duties imposed upon the AV AQMD.

g. Applicable State Laws and Regulations Were Follo wed:

Public notice and hearing procedures pursuant to H& S Code §§40725-40728 have been followed. See Section (V)(A)(1) above fo r compliance with state findings required pursuant to H&S Code §40727. See Section (V)(B) below for compliance with the required analysis of existing r equirements pursuant to H&S Code §40727.2. See Section (V)(C) for compliance w ith economic analysis requirements pursuant to H&S Code §40920.6. See Se ction (V)(D) below for compliance with provisions of the California Enviro nmental 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 sa me equipment or source type as the rule proposed for modification by the district. The ado ption of the 2015 RACT SIP Analysis is to ensure that District rules adequately address curre nt RACT requirements. Therefore the preparation of a written analysis of existing pollu tion 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. GeneralAVAQMD RACT SIP Analysis 7

Final Staff Report, 08/14/2015

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 w ill 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 eff ectiveness calculations are required for rules and regulations which are adopte d or amended to meet the California Clean Air Act requirements for Best Available Retro fit Control Technology (BARCT) or “all feasible measures” to control volatile comp ounds, oxides of nitrogen or oxides of sulfur. The adoption of the 2015 8-Hour Reasonably Available Control Technology – State Implementation Plan Analysis (RACT SIP Analys is) is not subject to incremental cost effectiveness calculations because this docume nt does not impose BARCT or “all feasible measures.” Potential environmental effect s will be addressed on a rule by rule basis through the rule amendment process as specifi c rule changes and their potential impacts are currently not foreseeable.

D. ENVIRONMENTAL ANALYSIS (CEQA)

Through the process described below, it was determi ned that a Notice of Exemption would be the appropriate CEQA process for the adoption of th e 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 t he environment. Because there is no potential that the adoption might cause the release of additional air contaminants or create any adverse environmental im pacts, a Class 8 categorical exemption (14 Cal. Code Reg. §15308) applies. Pote ntial environmental effects are currently not foreseeable as the particular rul e amendments have not been identified with enough specificity at this time. T herefore, environmental effects will be addressed on a rule by rule basis through t he rule amendment process as specific rule changes and their potential impacts a re currently not foreseeable. Copies of the documents relating to CEQA can be fou nd in Appendix “D.”

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS

1. Potential Environmental Impacts

There are no potential negative environmental impac ts of compliance with the adoption of the 2015 RACT SIP Analysis . Potential environmental effects will be addresse d on a rule by rule basis through the rule amendment proce ss as specific rule changes and their potential impacts are currently not foreseeable.8 AVAQMD RACT SIP Analysis Final Staff Report, 08/14/2015 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), a s well as Appendix B.

VI. TECHNICAL DISCUSSION

The FCAA requires that ozone non-attainment areas i mplement RACT for sources that are subject to CTGs and for major sources of ozone prec ursors. The 2015 RACT SIP Analysis document: (1) reviews all available instances of RA CT for applicability to the AVAQMD; (2) reviews all AVAQMD major sources for RACT applicabi lity; and (3) identifies any actions the AVAQMD must take to address applicable RACT require ments. This document satisfies 42 U.S.C. §§7511a (FCAA §182) regarding RACT requireme nts 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 spe cific rule amendment. Those reasons identified below as a basis for updating the rule t o federal RACT are not necessarily inclusive of all rule changes that will be made at the time o f amendment. This section gives a brief overview of the elements identified for further act ion 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 NO X emissions from mobile sources. In particular, Lancaster Landfill and Rec ycling Center and Granite Construction were not major stationary sources of NO X in 2012, when mobile source emissions are accounte d for.

Summary of Rules to be amended to update Federal RA CT requirements

Rule 462 – Organic Liquid Loading to be amended to address deficiencies in the Limit ed 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 R ule 1107 are lower and have been identified as RACT.

Rule 1110.2 – Emissions from Gaseous and Liquid Fueled Internal C ombustion Engines is not a RACT rule but will be updated to meet other feder al requirements. Rule 1110.2 must be updated to remove the agricultural exemption and ad dress other USEPA comments identified in the LA/LD (69 FR 21482, 04/21/2004).AVAQMD RACT SIP Analysis 9

Final Staff Report, 08/14/2015 Rule 1145 – Plastic, Rubber and Glass Coatings to be amended to incorporate additional RACT provisions identified in SCAQMD Rule 1145, inc luding but not limited to updating definitions, possibly adding several coating catego ries and VOC limits, transfer efficiency, and updating test methods.

Rule 1146 - Emissions Of Oxides Of Nitrogen From Industrial, In stitutional 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 Operatio ns will be amended to incorporate provisions of Control Techniques Guidel ines for Automobile and Light-Duty Truck Assembly Coating as applicable to “Heavier” vehicle s, which includes all vehicles that meet the definition of the term “other motor vehicles”, as d efined at 40 CFR §63.3176. BYD Coach and Bus is not a major source but is permitted above th e 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 rul es, 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 19 96). 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 cal led the Mojave Desert Air Basin) prior to July 1, 1997. On January 1, 2002 the AVAQM D was created pursuant to statute H&S Code 41300 et seq.) to replace the AVAPCD. Onc e again the SIP in effect at the time of the change remained in effect until the AVA QMD Governing Board superceded, amended or rescinded it. There is no equivalent do cument 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.10 AVAQMD RACT SIP Analysis Final Staff Report, 08/14/2015 This page intentionally left blank.AVAQMD RACT SIP Analysis A

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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 Analysi s) as attached to the Resolution contained in the July 21, 2015 adoption package.A-2 AVAQMD RACT SIP Analysis Final Staff Report, 08/14/2015 This page intentionally left blank.AVAQMD RACT SIP Analysis B

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### APPENDIX "B" PUBLIC NOTICE DOCUMENTS

1. Proof of Publication for Notice of Public Hearing – Antelope Valley Press, 04/17/2015B-2 AVAQMD RACT SIP Analysis Final Staff Report, 08/14/2015 This page intentionally left blank.AVAQMD RACT SIP Analysis B

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Final Staff Report, 08/14/2015B-4 AVAQMD RACT SIP Analysis Final Staff Report, 08/14/2015 This page intentionally left blank.AVAQMD RACT SIP Analysis C

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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 , 07/06/2015C-2 AVAQMD RACT SIP Analysis Final Staff Report, 08/14/2015 This page intentionally left blank.AVAQMD RACT SIP Analysis C

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Final Staff Report, 08/14/2015 1. EPA CommentC-4 AVAQMD RACT SIP Analysis Final Staff Report, 08/14/2015AVAQMD RACT SIP Analysis C

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Final Staff Report, 08/14/2015 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 NO X for this facility includes emissions of 37.64 tons of NO X from mobile sources. 4. The 2012 CARB inventory of 32 tons of NO X for this facility includes emissions of 30.74 tons of NO X 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 comple ted at the time of specific rule amendment. This will include evaluation of the limit included in BAAQMD Reg 8-33.

Com ment [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 comple ted 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 upd ate. 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 R ACT. 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 R ACT. A current and complete rule analysis will be comple ted at the time of amendment of Rule 1146.1. Rule 1106.1 was analyzed and determined no RACT Upd ate necessary at this time. 1. District Response to EPA CommentC-6 AVAQMD RACT SIP Analysis Final Staff Report, 08/14/2015 This page intentionally left blank.AVAQMD RACT SIP Analysis C

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Final Staff Report, 08/14/2015 2. EPA EmailC-8 AVAQMD RACT SIP Analysis Final Staff Report, 08/14/2015 1. The AVAQMD will add FNDs for those source catego ries where there is an existing SIP rule but that source category does not meet the CTG threshol d (Fixed-Roof Tanks, Floating Roof Tanks, Large Petroleum Dry Cleaners, and Flat Wood Paneling). 2. District Response to EPA EmailAVAQMD RACT SIP Analysis D

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### APPENDIX "D"

CALIFORNIA ENVIRONMENTAL QUALITY ACT

DOCUMENTATION (to be included as available)

1. Notice of Exemption – Los Angeles CountyD-2 AVAQMD RACT SIP Analysis Final Staff Report, 08/14/2015 This page intentionally left blank.AVAQMD RACT SIP Analysis D

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Final Staff Report, 08/14/2015D-4 AVAQMD RACT SIP Analysis Final Staff Report, 08/14/2015AVAQMD RACT SIP Analysis E-1

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### APPENDIX "E" BIBLIOGRAPHY

The following documents were consulted in the prepa ration of this staff report and the adoption of the 8-Hour Reasonably Available Control Technology – St ate 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 I X to Alan De Salvio, AVAQMD, dated September 11, 2006 6. California Health and Safety Code – various sect ionsE-2 AVAQMD RACT SIP Analysis Final Staff Report, 08/14/2015 This page intentionally left blank.