Eastern Kern Air Pollution Control District (EKAPCD) has adopted the Reasonably Available Control Technology (RACT) State Implementation Plan (SIP) for the 2015 Ozone National Ambient Air Quality Standards (NAAQS). In 2018, EPA classified most of EKAPCD as moderate nonattainment pursuant to the 2015 8-hour ozone (O3) NAAQS. The Clean Air Act (CAA) requires air districts classified as moderate nonattainment or higher to implement RACT emission standards for major sources of O3 precursors, nitrogen oxides (NOX) and volatile organic compounds (VOCs). RACT is defined as the lowest emissions limitation that a particular source is capable of meeting, by the application of air pollution control technology that is reasonably available considering technological and economic feasibility. RACT requirements assure the significant O3 source categories are controlled to a “reasonable” extent, but not necessarily to the more stringent Best Available Control Technology (BACT) or Maximum Achievable Control Technology (MACT) levels that are expected for new or modified major stationary sources. RACT is required for sources subject to Control Techniques Guidelines (CTGs) and for non-CTG sources that exceed the major source threshold.
EKAPCD reviewed the list of CTG sources and non-CTG sources that exceed the major source threshold and compared them to the existing applicable rules. The RACT SIP includes a comparison between the CTG documents and the applicable EKAPCD rules. The comparison determined that all rules applicable to CTG source categories meet or exceed the CTG requirements. The RACT SIP also compares rules applicable to the non-CTG major sources and the RACT requirements. EKAPCD's analysis found three NOX rules with deficiencies in the 2008 RACT SIP. These three rules have all been amended in 2018 to fulfill the RACT requirements. These include Rule 425 (Stationary Gas Turbines), Rule 425.2 (Boilers, Steam Generators, and Process Heaters), and Rule 425.3 (Portland Cement Kilns). In addition to the rule comparison, the RACT SIP includes negative declarations for CTG source categories that have no applicable sources operating within the nonattainment area. The full EKAPCD RACT SIP for 2015 NAAQS can be found here. There are no additional rule changes expected from the adoption of this RACT SIP.