MEMORANDUM
DATE: January 29, 2025
TO: Camarillo City Council
FROM: Kirsten Marble
SUBJECT: Report on the Activities of the Ventura County Air Pollution Control District (VCAPCD) Advisory Committee in 2024
The VCAPCD Advisory Committee met once in 2024 to review proposed amendments to the VCAPCD Rules and Regulations and make recommendations to the VCAPCD Board. The proposed amendments were in response to deficiencies identified during the U.S Environmental Protection Agency's (EPA) review of the VCAPCD portion of the California State Implementation Plan (SIP).
The proposed amendments were considered administrative in nature and would not provide measurable emissions reductions. VCAPCD staff held a public workshop for the proposed amendments to Rules
74.15 and 74.23 on June 12, 2024, and did not receive any substantive comments from stakeholders.
The City of Camarillo representative, Kirsten Marble, was in attendance at the July 23, 2024 VCAPCD Advisory Committee meeting and voted in favor of all proposed amendments. The Advisory Committee unanimously voted to recommend approval of all proposed amendments, and all proposed amendments were ultimately approved by the VCAPCD Board
The rule amendments and other activities of the VCAPCD Advisory Committee are summarized below.
July 23, 2024 Meeting
1. Election of Officers
The Advisory Committee voted unanimously to reelect Sara Head as Chair of the Advisory Committee and reelect Paul Mechan as Vice Chair of the Advisory Committee.
2. Proposed Amendments to Rule 71.3 Transfer of Reactive Organic Compound Liquids Rule 71.3 applies to equipment used to transfer reactive organic compound (ROC) liquids with a modified Reid Vapor Pressure (MRVP) greater than or equal to 0.5 psia. This rule reduces ROC emissions by requiring the use of vapor recovery systems during the transfer of ROC liquids into a ROC liquid delivery vessel.
VCAPCD staff proposed amendments to Rule 71.3 to implement the EPA's annual reporting requirement and to add titles for the referenced test methods. Rule language in sections B, D, and E was also clarified to correctly reference the subsections in the rule.
Recommended for approval, approved by the Board on September 10, 2024 1 of 2
3. Proposed Amendments to Rule 74.15 Boilers, Steam Generators, and Process Heaters Rule 74.15 applies to portable and stationary boilers, steam generators, and process heaters with a rated heat input capacity greater than or equal to 5 MMBtu/hr. This rule reduces nitrogen oxides (NOx) emissions from regulated equipment by imposing numerical concentration limits.
VCAPCD staff proposed amendments to Rule 74.15 to implement the EPA's annual reporting requirement, modify the tune-up exemption condition, remove the exemption from emission limitations for emergency standby units, and remove the exemption from emission tests during startup, shutdown, and malfunction (SSM) events.
Recommended for approval, approved by the Board on September 10, 2024
4. Proposed Amendments to Rule 74.23 Stationary Gas Turbines Rule 74.23 applies to stationary gas turbines with a rated output greater than or equal to 0.3 MW.
Similar to Rule 74.15, this rule reduces NO, emissions from regulated equipment by imposing numerical concentration limits.
VCAPCD staff proposed amendments to Rule 74.23 to implement the EPA's annual reporting requirement, remove obsolete provisions, and impose a NO, limit of 100 ppm at 15% Oz during SSM events.
Recommended for approval, approved by the Board on September 10, 2024 2 of 2