 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for 

EPA's Proposed Rulemaking

for the

California State Implementation Plan

EPA’s Evaluation of

Imperial County Air Pollution Control District, 

Final 2009 Reasonably Available Control Technology 

State Implementation Plan  

Dated July 13, 2010

Adopted July 13, 2010

Prepared by: James Shears

Reviewed by:  Andrew Steckel

July 2015



RULE IDENTIFICATION -

Agency:			Imperial County Air Pollution Control District (ICAPCD)

SIP Approved Version:	None

Subject of this TSD:	ICAPCD Final 2009 Reasonably Available Control
Technology State Implementation Plan – Dated July 13, 2010 (“2009
RACT SIP”)

				Adopted 		July 13, 2010 

				Submitted 		December 21, 2010

				

BACKGROUND

Volatile organic compounds (VOCs) and nitrogen oxides (NOx) in the
presence of sunlight can lead to the formation of ground-level ozone or
“smog” which can result in significant impacts to human health and
the environment. Section 182 of the Clean Air Act (CAA) requires areas
that are classified as moderate or above for ozone nonattainment to
implement reasonably available control technology (RACT) for specific
types of sources. 

With the implementation of the 1997 8-hour National Ambient Air Quality
Standard (NAAQS) for ozone, Imperial County Air Pollution Control
District (ICAPCD or the District) was classified as a marginal
nonattainment area.  Subsequently, EPA found that Imperial County did
not meet the attainment deadline of June 15, 2007, and reclassified it
as a moderate nonattainment area with an attainment deadline of June 15,
2010.   On December 3, 2009, EPA issued a final rule  determining that
Imperial County attained the 1997 8-hour NAAQS based on ambient air
monitoring data for the years 2006 through 2008.  Although the finding
of attainment by EPA suspended certain State Implementation Plan (SIP)
related requirements, it did not suspend the RACT requirements for VOCs
and NOx under CAA section 182.  Pursuant to 40 CFR 51.912(a)(1), the
State (or local air district) must submit a SIP revision that meets the
VOC and NOX RACT requirements in CAA section 182(b)(2) and (f) for each
area classified moderate or higher. Therefore, ICAPCD must, at a
minimum, adopt RACT-level controls for sources covered by a Control
Techniques Guidelines (CTG) document and for any major stationary source
of VOCs or NOx. 

EPA defines RACT as the “lowest emissions limitation that a particular
source is capable of meeting by the application of control technology
that is reasonably available considering technological and economic
feasibility.” A RACT analysis should, therefore, take into account the
technological and economic feasibility of controls, and may differ from
source to source and location to location.

SUBMITTAL SUMMARY and EPA EVALUATION

The District adopted its 2009 RACT SIP on July 13, 2010 and the
California Air Resources Board (CARB) submitted it to EPA on December
21, 2010.  The CARB submittal included a completeness checklist which
indicated the package met the completeness criteria in 40 CFR Part 51,
Appendix V.  The submittal became complete by operation of law on June
21, 2011 pursuant to CAA §110(k)(1)(B).  

 

ICAPCD’s 2009 RACT SIP included the following documents:

Imperial County Air Pollution Control District Final 2009 Reasonably
Available Control Technology State Implementation Plan, July 13, 2010.

Resolution of the Imperial County Air Pollution Control District Board
approving and adopting the Final 2009 Reasonably Available Control
Technology State Implementation Plan - adopted on July 13, 2010.

ICAPCD’s analysis evaluated the following areas. Further discussion is
provided below.

VOC rules for sources subject to a CTG.

Negative declarations where there are no facilities subject to a CTG.

Major non-CTG sources of VOC or NOx.

Subsequent to its adoption of the 2009 RACT SIP, ICAPCD amended or
adopted a number of rules and submitted them to EPA for approval into
the SIP. Upon SIP approval, these submittals effectively supplanted the
corresponding rules, if any, in the 2009 RACT SIP.

EPA evaluated the following elements of ICAPCD’s 2009 RACT SIP and
subsequent submittals:

Efforts to identify all source categories within the District requiring
RACT.

Negative declarations where there are no facilities subject to a CTG.

List of the State/local regulations that implement RACT.

The bases for concluding that all referenced regulations fulfill RACT.

The following documents were also used to support our review:

“Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality
Standard – Phase 2” (70 FR 71612; November 29, 2005).

“State Implementation Plans, General Preamble for the Implementation
of Title I of the Clean Air Act Amendments of 1990” (57 FR 13498;
April 16, 1992).

Enforceability - Section 110(a) of the CAA requires enforceable emission
limitations and other control measures. Several EPA guidance documents
are used to evaluate rule enforceability, including Issues Relating to
VOC Regulation Cutpoints, Deficiencies, and Deviations: Clarification to
Appendix D of November 24, 1987 FEDERAL REGISTER, May 25, 1988, Revised
January 11, 1990 ("The Blue Book"), and EPA Region IX’s Guidance
Document for Correcting Common VOC and Other Rule Deficiencies, August
21, 2001 (the "Little Bluebook"). 

“State Implementation Plans; Nitrogen Oxides Supplement to the General
Preamble for Implementation of Title I of the Clean Air Act Amendments
of 1990” (57 FR 55620, November 25, 1992) ("the NOx Supplement").

“Model Volatile Organic Compound Rules for Reasonably Available
Control Technology”, EPA (June 1992).

“Beyond VOC RACT Requirements”, EPA (April 1995).

Memorandum from William T. Harnett to Regional Air Division Directors,
(May 18, 2006), “RACT Qs & As – Reasonably Available Control
Technology (RACT) Questions and Answers”.

RACT SIPs, Letter dated March 9, 2006 from EPA Region IX (Andrew
Steckel) to CARB (Kurt Karperos) describing Region IX’s understanding
of what constitutes a minimally acceptable RACT SIP.

EPA's CTGs   HYPERLINK
"http://www.epa.gov/groundlevelozone/SIPToolkit/ctgs.html" 
http://www.epa.gov/groundlevelozone/SIPToolkit/ctgs.html  

CARB’s emissions inventory database   HYPERLINK
"http://www.arb.ca.gov/app/emsinv/facinfo/facinfo.php" 
http://www.arb.ca.gov/app/emsinv/facinfo/facinfo.php 

CARB and EPA Region IX databases of ICAPCD rules

		CARB:    HYPERLINK "http://www.arb.ca.gov/rldb/rldb.htm" 
http://www.arb.ca.gov/rldb/rldb.htm  

EPA:   HYPERLINK "http://epa.gov/region09/air/sips/index.html" 
http://epa.gov/region09/air/sips/index.html 

VOC Rules for Sources Subject to a CTG 

ICAPCD Action:

Table 1 of the 2009 RACT SIP identifies 11 CTGs which apply to sources
in Imperial County and therefore must be addressed in the RACT SIP. The
11 CTGs identified by ICAPCD and the corresponding ICAPCD rules are as
follows: 

CTG Source Category	CTG Reference Document 	ICACPD Rule

Gasoline Service Stations	Design Criteria for Stage I Vapor Control
Systems – Gasoline Service Stations, EPA-450/R-75-102 1975/11	415
Transfer and Storage of Gasoline

Tank Trucks, Gasoline Loading Terminals	Control of Hydrocarbons from
Tank Truck Gasoline Loading Terminals, EPA-450/2-77-026 1977/10	415
Transfer and Storage of Gasoline

Bulk Gasoline Plants	Control of Volatile Organic Emissions from Bulk
Gasoline Plants, EPA-450/2-77-035 1977/12	415 Transfer and Storage of
Gasoline

External Floating Roof Tanks, Petroleum Liquid Storage in	Control of
Volatile Organic Emissions from Petroleum Liquid Storage in External
Floating Roof Tanks, EPA-450/2-78-047 1978/12	414 - Storage of Reactive
Organic Compound Liquids

Tank Trucks, Gasoline and Vapor Collection Systems	Control of Volatile
Organic Compound Leaks from Gasoline Tank Trucks and Vapor Collection
Systems, EPA-450/2-78-051 1978/12	415 Transfer and Storage of Gasoline

Solvent Metal Cleaning	Control of Volatile Organic Emissions from
Solvent Metal Cleaning, EPA-450/2-77-022 1977/11

	413 Organic Solvent Degreasing Operations



Storage of Petroleum Liquids in Fixed Roof Tanks	Control of Volatile
Organic Emissions from Storage of Petroleum Liquids in Fixed-Roof Tanks,
EPA-450/2-77-036 1977/12	414 - Storage of Reactive Organic Compound
Liquids

Industrial Cleaning Solvents	Control Techniques Guidelines for
Industrial Cleaning Solvents, EPA-453/R-06-001 2006/09	417 Organic
Solvents

Cutback Asphalt	Control of Volatile Organic Emissions from Use of
Cutback Asphalt, EPA-450/2-77-037 1977/12	426 Cutback Asphalt and
Emulsified Paving

Automobile Refinishing	Reduction of Volatile Organic Compound Emissions
from Automobile Refinishing, EPA-450/3-88-009 1988/10	413 Organic
Solvent Degreasing Operations



427 Automotive Refinishing Operations

Aerospace	Aerospace(CTG&MACT), EPA-453/R-97-004 1997/12	425 Aerospace
Coating Operations



Table 5 of the 2009 RACT SIP presents a comparison of the District’s
rules to similar rules in other air districts.  Based on this analysis,
ICAPCD concluded that its rules fulfill RACT requirements.  

EPA Evaluation:

EPA reviewed the above rules, found they satisfied RACT, and approved
them into the SIP on the following dates.  We are not aware of
information suggesting that additional controls are needed to fulfill
RACT since our approval of these rules. Where applicable, additional
details and suggestions for future rule improvements are provided below.

Rule 413 Organic Solvent Degreasing Operations (67 FR 67313, November 5,
2002); 

Rule 414 Storage of Reactive Organic Liquid Compounds (73 FR 70883,
November 24, 2008); Rule 415 Transfer and Storage of Gasoline (70 FR
8520, February 22, 2005); 

Rule 417 Organic Solvents (67 FR 67313 November 5, 2002); 

Rule 425 Aerospace Coating Operations (76 FR 67369, November 1, 2011); 

Rule 426 Cutback Asphalt and Emulsified Paving Materials (66 FR 20084
April 19, 2001); and Rule 427 Automobile Refinishing Operations (76 FR
67369, November 1, 2011). 

For Rule 413, subsequent to the 2009 RACT SIP submittal, ICAPCD found it
had no sources of organic solvent cleaning within the District that
would be subject to the 1977 Solvent Metal Cleaning CTG.  ICAPCD should
formally adopt a negative declaration including a public hearing, and
submit it to EPA for inclusion into the SIP.  We also recommend ICAPCD
update Rule 413 (last amended in 2001) to more closely match VOC solvent
cleaning limits adopted by nearby air districts with a similar ozone
nonattainment classification.  Some air districts have adopted solvent
cleaning limits of 25 g/l for general solvent cleaning operations.

Rule 415 was approved by EPA in 2005 as meeting RACT.  Although this
approval occurred before ICAPCD was reclassified from marginal to
moderate ozone nonattainment, we believe the rule still satisfies RACT. 
We recommend ICAPCD consider lowering the gasoline bulk terminal
emissions limit to 0.04 pounds/1000 gallons the next time this rule is
amended.  

For Rule 417, subsequent to the 2009 RACT SIP submittal, ICAPCD found it
had no sources subject to the 2006 Industrial Cleaning Solvents CTG’s
nine unit operations.7   ICAPCD should formally adopt a negative
declaration with a public hearing, and submit it to EPA for inclusion
into the SIP.  We also recommend ICAPCD update Rule 417 (last amended
1999) to more closely match VOC content limits adopted by other air
districts.  Some air districts have adopted solvent cleaning limits of
25 g/l for general solvent cleaning operations.9 

Regarding Rule 426, the VOC limits for cutback and emulsified asphalt
are similar to South Coast Air Quality Management District (SCAQMD)
Rules 1108 and 1108.1, both of which are SIP-approved.  In 2008, SCAQMD
conducted a technical assessment of Rules 1108 and 1108.1 and concluded
that slow cure asphalt does not emit as much VOC as replacement
emulsions do, and did not recommend making any changes to their asphalt
rules. EPA reviewed SCAQMD’s technical assessment which estimated that
slow cure cutback asphalt would emit 0.04 tons/day, but emissions could
increase to 0.98 tons/day if emulsified asphalt (3% VOC) were
substituted for slow cure (0.5% VOC) cutback asphalt. The increased
emissions would primarily be due to the higher VOC limit allowed for
emulsified asphalt. EPA accepted the SCAQMD technical assessment of its
asphalt rules as satisfying RACT.  For the same reasons, we believe that
ICAPCD Rule 426 satisfies RACT. If additional VOC/PM2.5/ NOx reductions
are needed for attainment of the NAAQS, the District may want to
investigate use of warm mix asphalt as an alternative to hot mix
asphalt.

Regarding Rule 427, automobile refinishing is not a CTG category and
ICAPCD does not have any major sources of automobile refinishing, so
this rule is not required to meet RACT.

   Negative Declarations Where There are no Facilities Subject to a CTG

ICAPCD Action:

Table 2 “CTG/ACT Listing with no applicable sources” of the ICAPCD
2009 RACT SIP identifies the CTG source categories for which the
District has no relevant stationary sources. ICAPCD compiled this list
by comparing its rules against EPA’s list of CTGs and ACTs, reviewing
its permits and emissions inventory, and consulting with knowledgeable
staff of the District’s permit and enforcement divisions. For the
negative declarations listed in ICAPCD’s 2009 RACT SIP Table 2, the
District also indicated it does not anticipate sources in these
categories in the future. 

EPA Evaluation:

Negative declarations are only required for CTG source categories where
the District has no sources subject to a CTG. A negative declaration is
not required for ACTs or for other non-CTG source categories. Table 1
below lists the CTG source categories included in ICAPCD’s 2009 RACT
SIP Table 2. We searched CARB’s emissions inventory database to verify
there are no facilities in ICAPCD that might be subject to these CTGs,
and concur with the District’s negative declarations.

Table 1 – ICAPCD Negative Declarations

CTG Source Category	CTG Reference Document

Aerospace	EPA-453/R-97-004, Aerospace CTG and MACT

Automobile and Light-duty Trucks, Surface Coating of	EPA-450/2-77-008,
Control of Volatile Organic Emissions from Existing Stationary Sources
– Volume II: Surface Coating of Cans, Coils, Paper, Fabrics,
Automobiles, and Light-Duty Trucks

EPA-453/R-08-006, Control Techniques Guidelines for Automobile and
Light-Duty Truck Assembly Coatings

Cans and Coils, 

Surface Coating of	EPA-450/2-77-008, Control of Volatile Organic
Emissions from Existing Stationary Sources – Volume II: Surface
Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty
Trucks

Fiberglass Boat Manufacturing	EPA-453/R-08-004, Control Techniques
Guidelines for Fiberglass Boat Manufacturing

Flat Wood Paneling, 

Surface Coating of	EPA-450/2-78-032, Control of Volatile Organic
Emissions from Existing Stationary Sources – Volume VII: Factory
Surface Coating of Flat Wood Paneling

EPA-453/R-06-004, Control Techniques Guidelines for Flat Wood Paneling
Coatings

Flexible Packing Printing	EPA-453/R-06-003, Control Techniques
Guidelines for Flexible Package Printing

Graphic Arts – Rotogravure and Flexography	EPA-450/2-78-033, Control
of Volatile Organic Emissions from Existing Stationary Sources, Volume
III: Graphic Arts – Rotogravure and Flexography

Large Appliances, 

Surface Coating of	EPA-450/2-77-034, Control of Volatile Organic
Emissions from Existing Stationary Sources – Volume V: Surface Coating
of Large Appliances

EPA-453/R-07-004, Control Techniques Guidelines for Large Appliance
Coatings

Large Petroleum Dry Cleaners	EPA-450/3-82-009, Control of Volatile
Organic Compound Emissions from Large Petroleum Dry Cleaners

Offset Lithographic Printing and Letterpress Printing	EPA-453/R-06-002,
Control Techniques Guidelines for Offset Lithographic Printing and
Letterpress Printing

Magnet Wire, 

Surface Coating for Insulation of	EPA-450/2-77-033, Control of Volatile
Organic Emissions from Existing Stationary Sources – Volume IV:
Surface Coating of Insulation of Magnet Wire

Metal Furniture Coatings	EPA-450/2-77-032, Control of Volatile Organic
Emissions from Existing Stationary Sources – Volume III: Surface
Coating of Metal Furniture

EPA-453/R-07-005, Control Techniques Guidelines for Metal Furniture
Coatings

Miscellaneous Metal and Plastic Parts Coatings	EPA-453/R-08-003, Control
Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings

Miscellaneous Metal Parts and Products, Surface Coating of
EPA-450/2-78-015, Control of Volatile Organic Emissions from Existing
Stationary Sources – Volume IV:  Surface Coating of Miscellaneous
Metal Parts and Products

Miscellaneous Industrial Adhesives	EPA-453/R-08-005, Control Techniques
Guidelines for Miscellaneous Industrial Adhesives

Natural Gas/Gasoline Processing Plants Equipment Leaks	EPA-450/2-83-007,
Control of Volatile Organic Compound Equipment Leaks from Natural
Gas/Gasoline Processing Plants

Paper, Film and Foil Coatings	EPA-453R-07-003, Control Techniques
Guidelines for Paper, Film and Foil Coatings

Petroleum Refineries	EPA-450/2-77-025, Control of Refinery Vacuum
Producing Systems, Wastewater Separators, and Process Unit Turnarounds

EPA-450/2-78-036, Control of Volatile Organic Compound Leaks from
Petroleum Refinery Equipment

Pharmaceutical Products

	EPA-450/2-78-029, Control of Volatile Organic Emissions from
Manufacture of Synthesized Pharmaceutical Products

Pneumatic Rubber Tires, Manufacture of	EPA-450/2-78-030, Control of
Volatile Organic Emissions from Manufacture of Pneumatic Rubber Tires

Polyester Resin	EPA-450/3-83-008, Control of Volatile Organic Compound
Emissions from Manufacture of High-Density Polyethylene, Polypropylene,
and Polystyrene Resins

EPA-450/3-83-006, Control of Volatile Organic Compound Leaks from
Synthetic Organic Chemical Polymer and Resin Manufacturing Equipment

Shipbuilding/Repair	61 FR-44050 8/27/96, Control Techniques Guidelines
for Shipbuilding and Ship Repair Operations (Surface Coating) 



Synthetic Organic Chemical	EPA-450/3-84-015, Control of Volatile Organic
Compound Emissions from Air Oxidation Processes in Synthetic Organic
Chemical Manufacturing Industry

EPA-450/4-91-031, Control of Volatile Organic Compound Emissions from
Reactor Processes and Distillation Operations in Synthetic Organic
Chemical Manufacturing Industry

Wood Furniture	EPA-453/R-96-007, Wood Furniture



Major non-CTG Sources of VOC or NOx

CAA § 182(b)(2) and (f) require RACT for stationary source categories
covered by CTG documents and all major stationary sources of VOCs or
NOx. ICAPCD was initially classified as a marginal nonattainment for the
1997 ozone NAAQS, but was subsequently reclassified as a moderate
nonattainment area. A major source in a moderate ozone nonattainment
area is defined as a stationary source that emits, or has the potential
to emit, at least 100 tons per year of VOCs or NOx. 

 

ICAPCD Action:

ICAPCD’s 2009 RACT SIP, Table 3, lists nine facilities that were major
sources of VOC or NOx at that time, along with the respective RACT
rules, where applicable, for each facility.  Table 5 in the 2009 RACT
SIP presents a comparison of each ICAPCD RACT rule for these facilities
with the corresponding RACT rule in other California air districts.

ICAPCD’s 2009 RACT SIP Table 3 referenced the following NOx rules for
the major sources:

Rule 400: 	Fuel Burning Equipment

Rule 400.1:	Stationary Gas Turbines

Rule 400.2:	Boilers, Process Heaters and Steam Generators 

Rule 403:  	General Limitations on the Discharge of Air Contaminants
(NOx/VOC)

ICAPCD’s 2009 RACT SIP Table 3 referenced the following VOC rules for
the major sources:

Rule 414:  Storage of Reactive Organic Compound Liquids

Rule 415:  Transfer and Storage of Gasoline  

EPA Evaluation:

We found that CalEnergy, one of the nine facilities listed in the 2009
RACT SIP as a major source of VOC, is currently permitted with a total
annual potential to emit of 1.8 tons per year of benzene (VOC).  ORMAT
Nevada, Inc. was also listed as a major source of VOC in the 2009 RACT
SIP, but a regenerative thermal oxidizer was added to the facility, and
the potential to emit is now 19.6 tons per year of VOC.  Each
facility’s potential to emit is now well below the major source
threshold, so neither is a major source.  We also reviewed CARB’s
emissions inventory for Imperial County, and did not find any additional
relevant major sources that are not included in Table 3 of the RACT SIP.

VOC Rules:  The two remaining major sources of VOC identified in the
2009 RACT SIP are GEM Resources (ORMESA, LLC) (Permit Number 2002) and
SFPP, L.P. (Permit Number 2046). SFPP is subject to two VOC rules that
EPA previously approved into the California SIP:  Rule 414 and Rule 415.
 Our previous approval of Rule 414 found that it fulfilled RACT
requirements.  We are not aware of information suggesting that
additional controls are needed to fulfill RACT since our approval of
this rule.

As discussed earlier, our previous approval of Rule 415 concluded that
it satisfied RACT.  

GEM Resources is not currently subject to any VOC prohibitory rules. 
GEM Resources is subject to permit conditions which limits its annual
potential to emit to 28.29 tons/year for VOCs and 9.94 tons/year for
benzene.  The emissions are below the major source threshold, so the
facility is not a major source.

NOx Rules:  ICAPCD identified five major sources of NOx: Imperial
Irrigation District (Rockwood) (Permit Number 1365), Holly Sugar (Permit
Number 1697), Imperial Valley Resource Recovery (Permit Number 1929),
Imperial Irrigation District (ECGS) (Permit Number 2152) and USG (Permit
Number 2834). The District also identified the NOx rules that apply to
one or more of these sources and that EPA has approved into the
California SIP: Rule 400 Fuel Burning Equipment – Oxides of Nitrogen,
Rule 400.1 Stationary Gas Turbines – Reasonably Available Control
Technology, and Rule 400.2 Boilers, Process Heaters and Steam
Generators. Table 3 of the 2009 RACT SIP indicates that four of the five
major NOx sources (Imperial Irrigation District (Rockwood), Holly Sugar,
Imperial Valley Resource Recovery, and Imperial Irrigation District
(ECGS) are subject to Rules 400, 400.1 and 400.2. Our previous approvals
of Rules 400.1 and 400.2 found that they fulfilled RACT requirements. We
are not aware of information suggesting that additional controls are
needed to fulfill RACT since our approval of these rules. Our approval
of Rule 400 did not include an evaluation of ozone RACT requirements.
However, since each of the NOx sources subject to Rule 400 is also
subject to at least one additional NOx rule that EPA has found to
fulfill RACT requirements, it is not necessary to determine whether Rule
400 fulfills RACT requirements at this time.

Subsequent to the 2009 RACT SIP submittal, ICAPCD adopted Rule 400.4,
Emissions of Oxides of Nitrogen from Wallboard Kilns to ensure USG, the
last major NOx source listed in Table 3 of the 2009 RACT SIP, is subject
to RACT.  EPA approved it into the California SIP (79 FR 60070, October
6, 2014).  As part of this approval, we found that Rule 400.4 fulfilled
RACT requirements.  We are not aware of information suggesting that
additional controls are needed to fulfill RACT since our approval of
this rule.  

RECOMMENDATIONS

The following rules have recommendations that are provided for future
consideration the next time the rules are open for amendment. None of
these recommendations listed in the referenced EPA technical support
documents justify less than full approval of ICAPCD’s 2009 RACT SIP
demonstration at this time.

1. Rule 400.1 Stationary Gas Turbine(s) – Reasonably Available Control
Technology (RACT) – 

Refer to EPA’s technical support document for ICAPCD Rule 400.1,
December 2011, page 4 for the suggested rule improvements for the next
time the rule is revised.

2. Rule 400.2 Boilers, Process Heaters and Steam Generators –

Refer to EPA’s technical support document for ICAPCD Rule 400.2, April
2012, page 5 for the suggested rule improvements for the next time the
rule is revised.

3. Rule 400.4 Emissions of Oxides of Nitrogen from Wallboard Kilns – 

Refer to EPA’s technical support document for ICAPCD Rule 400.4, June
2014, page 4 for the added rule recommendations for the next time the
rule is revised.

4. Rule 413 Organic Solvent Cleaning and Rule 417 Organic Solvents –

Adopt and submit for SIP approval a negative declaration for the 1977
Solvent Metal Cleaning and 2006 Industrial Solvent Cleaning CTGs. 
Consider adopting a VOC content limit of 25 g/l for cleaning solvents
similar to other air districts.

5. Rule 415 Transfer and Storage of Gasoline –

If additional VOC reductions are needed, consider lowering the bulk
gasoline terminal emissions limit to 0.04 pounds/1000 gallons loaded.
See Bay Area AQMD Rule 8-33 section 8-33-301.2 (effective 1/10/2011).

6. Rule 425 Aerospace Coating Operations – 

Refer to EPA’s technical support document for ICAPCD Rule 425, January
2011, page 4 for the added rule recommendations for the next time the
rule is revised.

7. Rule 426 Cutback Asphalt and Emulsified Paving Materials –

If additional VOC/NOx/PM2.5 reductions are needed, consider use of warm
mix asphalt as an option to hot mix asphalt. See pg C-220   HYPERLINK
"http://www.valleyair.org/Air_Quality_Plans/docs/PM25-2015/C.pdf" 
http://www.valleyair.org/Air_Quality_Plans/docs/PM25-2015/C.pdf .

8. Rule 427 Automotive Refinishing Operations – 

Refer to EPA’s technical support document for ICAPCD Rule 427,
February 2011, page 3 for the added rule recommendations for the next
time the rule is revised.

9. If additional VOC reductions are needed, consider adopting controls
for composting operations similar to South Coast Rule 1133 (series) or
San Joaquin Rule 4566.

SUMMARY

We concur with ICAPCD’s 2009 RACT SIP certification, including rules
that were amended or adopted after 2009 as they fulfill the requirements
for RACT for the 1997 8-hour ozone standard, and recommend the 2009 RACT
SIP be approved.

REFERENCES

1.  Imperial County Air Pollution Control District, Final 2009
Reasonably Available Control Technology State Implementation Plan Dated
July 13, 2010, Adopted July 13, 2010; submitted December 21, 2010.

2. “Final Rule to Implement the 8-Hour Ozone National Ambient Air
Quality Standard – Phase 2” 70 FR 71612; November 29, 2005).   
HYPERLINK "http://www.gpo.gov/fdsys/pkg/FR-2005-11-29/pdf/05-22698.pdf" 
http://www.gpo.gov/fdsys/pkg/FR-2005-11-29/pdf/05-22698.pdf 

3. ICAPCD - Supplemental to 2009 RACT SIP - Analysis of Control
Technologies Guidance (CTG) Documents, July 31, 2015.

4. “Air Quality Designations and Classifications for the 8-Hour Ozone
National Ambient Air Quality Standards; Early Action Compact Areas With
Deferred Effective Dates” – Final Rule (  HYPERLINK
"http://www.gpo.gov/fdsys/pkg/FR-2004-04-30/pdf/04-9152.pdf"  69 FR
23858 ; April 30, 2004).

5. “Final Rule to Implement the 1997 8-Hour Ozone National Ambient Air
Quality Standard: Classification of Areas That Were Initially Classified
Under Subpart 1; Revision of the Anti-

Backsliding Provisions to Address 1-Hour Contingency Measure
Requirements; Deletion of Obsolete 1-Hour Ozone Standard Provision”
– Final Rule (  HYPERLINK
"http://www.gpo.gov/fdsys/pkg/FR-2012-05-14/pdf/2012-11232.pdf"  77 FR
28424 ; May 14, 2012)

6.  “State Implementation Plans, General Preamble for the
Implementation of Title I of the Clean Air Act Amendments of 1990” (57
FR 13498; April 16, 1992).

 

7.  Issues Relating to VOC Regulation Cutpoints, Deficiencies, and
Deviations: Clarification to Appendix D of November 24, 1987 FEDERAL
REGISTER, May 25, 1988, Revised January 11, 1990 ("The Blue Book").  
HYPERLINK
"http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf" 
http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf  

8.  EPA Region IX’s Guidance Document for Correcting Common VOC and
Other Rule Deficiencies, August 21, 2001 (the "Little Bluebook").  
HYPERLINK "http://epa.gov/region9/air/sips/littlebluebook2001.pdf" 
http://epa.gov/region9/air/sips/littlebluebook2001.pdf    

9. “State Implementation Plans; Nitrogen Oxides Supplement to the
General Preamble for the Implementation of Title I of the Clean Air Act
Amendments of 1990” (57 FR 55620, November 25, 1992) (“the NOx
Supplement”).

10.  “Model Volatile Organic Compound Rules for Reasonably Available
Control Technology”, EPA (June 1992).   HYPERLINK
"http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_modelrules.pdf" 
http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_modelrules.pdf  

11.  EPA-453/R-95-010, “Beyond VOC RACT Requirements”, EPA (April
1995). 

  HYPERLINK "http://www.epa.gov/ttncatc1/dir1/byndract.pdf" 
http://www.epa.gov/ttncatc1/dir1/byndract.pdf  

12.  RACT Qs & As – Reasonably Available Control Technology (RACT):
Questions and Answers, May 18, 2006 Memorandum from William T. Harnett,
Director, Air Quality Policy Division, to Regional Air Division
Directors.   HYPERLINK
"http://www.epa.gov/ttn/caaa/t1/memoranda/ractqanda.pdf" 
http://www.epa.gov/ttn/caaa/t1/memoranda/ractqanda.pdf  

13.  RACT SIPs, Letter dated March 9, 2006 from EPA Region IX (Andrew
Steckel) to CARB (Kurt Karperos) describing Region IX’s understanding
of what constituted a minimally acceptable RACT SIP.

14.  EPA's CTGs and ACTs   HYPERLINK
"http://www.epa.gov/groundlevelozone/SIPToolkit/ctgs.html" 
http://www.epa.gov/groundlevelozone/SIPToolkit/ctgs.html  .

15.  CARB’s emissions inventory database   HYPERLINK
"http://www.arb.ca.gov/app/emsinv/facinfo/facinfo.php" 
http://www.arb.ca.gov/app/emsinv/facinfo/facinfo.php .

16. CARB and EPA Region IX databases of ICAPCD rules

CARB:    HYPERLINK "http://www.arb.ca.gov/drdb/imp/cur.htm" 
http://www.arb.ca.gov/drdb/imp/cur.htm  .

EPA: 	  HYPERLINK "http://epa.gov/region09/air/sips/index.html" 
http://epa.gov/region09/air/sips/index.html .

ICAPCD:   HYPERLINK
"http://www.co.imperial.ca.us/AirPollution/Web%20Pages/RULES%20AND%20REG
ULATIONS.htm" 
http://www.co.imperial.ca.us/AirPollution/Web%20Pages/RULES%20AND%20REGU
LATIONS.htm  

17. ICAPCD Synthetic Minor Permit Review, 1641B-3 ORMAT Nevada Inc.,
September 23, 2010.

18. ICAPCD Authority to Constrct and Permit To Operate Review, 2002I-3
Ormesa, LLC., April 1, 2014.

19. ICAPCD Authority to Construct and Permit to Operate Review Review,
#2000H-9 CalEnergy Operating Corporation, March 4, 2015.

20. South Coast Air Quality Management District, “Technical Assessment
for Rule 1108 – Cutback Asphalt”, June 2008.

 69 FR 23858 (April 30, 2004)

 73 FR 8209 (February 13, 2008)

 74 FR 63309 (December 3, 2009)

 CAA § 182(b)(2) and (f).

   HYPERLINK
"http://www.gpo.gov/fdsys/pkg/FR-2005-11-29/pdf/05-22698.pdf"  70 FR
71612 , 71652, n. 57 (November 29, 2005) (citing 44 FR 53761 (September
17, 1979))

 With regard to Rule 425, we note that ICAPCD has certified that it has
no sources subject to the aerospace coating CTG.  Therefore, ICAPCD is
not required to adopt RACT requirements for this source category. 

 ICAPCD - Supplemental to 2009 RACT SIP - Analysis of Control
Technologies Guidance (CTG) Documents, July 31, 2015.

 See Sacramento Metropolitan AQMD Rule 466 (  HYPERLINK
"http://airquality.org/rules/rule466.pdf" 
http://airquality.org/rules/rule466.pdf ) and South Coast AQMD Rule 1171
(  HYPERLINK
"http://www.aqmd.gov/docs/default-source/rule-book/reg-xi/rule-1171.pdf?
sfvrsn=4" 
http://www.aqmd.gov/docs/default-source/rule-book/reg-xi/rule-1171.pdf?s
fvrsn=4 ).

 See Bay Area AQMD Rule 8-33 section 8-33-301.2 (effective 1/10/2011)

 See South Coast Air Quality Management District, “Technical
Assessment for Rule 1108 – Cutback Asphalt”, June 2008.

 See pg C-220   HYPERLINK
"http://www.valleyair.org/Air_Quality_Plans/docs/PM25-2015/C.pdf" 
http://www.valleyair.org/Air_Quality_Plans/docs/PM25-2015/C.pdf 

 The document listed by ICAPCD as a CTG for Automotive Refinishing,
“Reduction of Volatile Organic Compound Emissions from Automobile
Refinishing, EPA-450/3-88-009 1988/10” is in fact an Alternative
Control Techniques (ACT) Document.  

 See   HYPERLINK
"http://www.gpo.gov/fdsys/pkg/FR-2004-04-30/pdf/04-9152.pdf"  69 FR
23858  (April 30, 2004), and   HYPERLINK
"http://www.gpo.gov/fdsys/pkg/FR-2012-05-14/pdf/2012-11232.pdf"  77 FR
28424  (May 14, 2012) (codified at 40 CFR § 81.305 (California—1997
8-Hour Ozone NAAQS)).  

 See CAA §§ 182(b)(2) and (f) and 302(j).

 Imperial County Air Pollution Control District, Authority to Construct
and Permit to Operate Review, Permit #2000H-9 (March 4, 2015) Table 8.

 Imperial County Air Pollution Control District, Synthetic Minor Permit
Review, Permit 1641B-3 (September 23, 2010) page 7.

 Approved in 73 FR 70883 (November 24, 2008).

 Approved in 70 FR 8520 (February 22, 2005).

 Imperial County Air Pollution Control District, Conditions for
Authority to Construct and Permit to Operate #2002I-4 (April 1, 2014). 

 Approved in 68 FR 14161 (March 24, 2003)

 Approved in 77 FR 2469 (November 18, 2012)

 Approved in 78 FR 896 (January 7, 2013)

 Approved in 79 FR 60070 (October 6, 2014)

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