UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for the 

California State Implementation Plan

El Dorado County Air Quality Management District, 

Negative Declarations for Control Techniques Guidelines (CTG) 

Source Categories

Adopted December 11, 2012

Prepared by: Stanley Tong

November 2013
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RULE IDENTIFICATION -

Agency: El Dorado County Air Quality Management District (EDAQMD)

SIP Approved Version: There is no previous version of this document in the SIP

Subject of this TSD: EDAQMD Negative Declarations

Adopted – December 11, 2012

Submitted – September 30, 2013

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. The El Dorado County Air 

Quality Management District (EDAQMD) falls under this requirement as it is classified as a

severe ozone nonattainment area for the 1997 8-hour national ambient air quality standard 

(“NAAQS”) for ozone (40 CFR 81.305).

Under CAA § 182(b)(2) and (f), EDAQMD must, at a minimum, adopt RACT level controls for 

sources covered by a Control Techniques Guidelines (CTG) document and for any other major 

stationary source of VOCs or NOx. Alternatively, areas may adopt a negative declaration 

documenting that the air district has no stationary sources or emitting facilities subject to the 

CTG documents. The negative declaration must go through the same public review 

requirements as any other SIP submittal. 

SUBMITTAL SUMMARY -

EDAQMD analyzed its rules to determine if they satisfied RACT for the 1997 8-hour ozone 

standard. The District documented its findings in a staff report, RACT SIP Update Analysis 

"2006 RACT SIP" and submitted its analysis along with a number of negative declarations1to 

EPA as a SIP revision. EPA's review of EDAQMD's 2006 RACT SIP identified three additional 

CTG source categories where it appeared EDAQMD had sources below the CTG's 

applicability threshold and could therefore submit a negative declaration in lieu of adopting or 

amending a RACT rule. EDAQMD submitted the following negative declarations:

1. Surface Coating of Miscellaneous Metal Parts

EDAQMD's 2006 RACT SIP states2that the District has non-major source(s) in this CTG 

category and recommended adoption of a rule to limit VOC emissions since the District did not 

 

1

See Approval of Air Quality Implementation Plans; California; El Dorado County Air Quality Management District; 

Reasonably Available Control Technology for Ozone, Proposed Rule; 78 FR 63934 (October 25, 2013).

2

See EDAQMD 2006 RACT SIP page 10, Part 4.
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have a rule covering this CTG category. EPA's rulemaking proposing to approve EDAQMD's 

2006 RACT SIP analysis identified that the subject facilities did not exceed the applicability 

threshold for the Miscellaneous Metal Parts and Products CTG and recommended EDAQMD 

submit a negative declaration for this source category.3

2. Solvent Metal Cleaning

EDAQMD's 2006 RACT SIP states that District Rule 225 – Organic Solvent Cleaning and 

Degreasing meets the 1977 solvent cleaning CTG. EPA's evaluation of Rule 225 concluded 

that the rule could be improved to more closely match VOC solvent cleaning limits in nearby 

air districts with a similar ozone non-attainment classification, but that it was not required to 

meet RACT since the District's sources were below the 1977 CTG's applicability threshold.4

Our proposed approval of EDAQMD's 2006 RACT SIP recommended the District submit a 

negative declaration for this category and suggested the District consider updating its rule.

3. Graphic Arts – Rotogravure and Flexography

EDAQMD's 2006 RACT SIP states that District Rule 231 – Graphic Arts meets RACT. EPA's 

evaluation of Rule 231 concluded that the District did not appear to have any graphic arts 

facilities that exceeded the 100 tpy applicability threshold of the Rotogravure and Flexography 

CTG. Our proposed approval of EDAQMD's 2006 RACT SIP recommended the District submit 

a negative declaration for this category and suggested the District also review the 2006 

Lithographic, Letterpress and Flexible Package Printing CTG to determine if there are facilities 

subject to its lower applicability threshold of 15 lb/day or 2.7 tpy.

EDAQMD reviewed its permit database and files and conducted public outreach inviting public 

comment on the District's conclusion that there are no sources or reasonably foreseeable 

sources within the District to which the above CTGs apply. No comments were received by 

EDAQMD during the 30 day public comment period.

EPA EVALUATION AND RECOMMENDED ACTION -

In lieu of adopting RACT rules, Districts may adopt negative declarations for CTG source 

categories if there are no sources in the District covered by the CTG documents. 

EPA has evaluated the appropriate background and submittal documentation, including our 

original recommendation to EDAQMD to submit negative declarations on the following CTGs.

 

3

See 78 FR 63934 (October 25, 2013). One facility emitted 0.24 tons and 0.28 tons of VOCs in 2010 and 2011 and 

another facility emitted 0.7 tons of VOCs in 2011, well below the CTG’s applicability threshold of 10 tons per year.

4

See TSD accompanying proposed approval of EDAQMD's 2006 RACT SIP. 78 FR 63934 (October 25, 2013).
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CTG Source Category Negative Declaration – CTG Reference Document

Miscellaneous Metal Parts 

and Products

EPA-450/2-78-015 – Control of VOC Emissions from 

Existing Stationary Sources, Volume VI: Surface 

Coating of Miscellaneous Metal Parts and Products

Solvent Metal Cleaning EPA-450/2-77-022 – Control of VOC Emissions from 

Solvent Metal Cleaning

Graphic Arts –

Rotogravure and 

Flexography

EPA-450/2-78-033 – Control of VOC Emissions from 

Existing Stationary Sources, Volume VIII: Graphic Arts 

– Rotogravure and Flexography

EPA is approving these negative declarations submitted on September 30, 2013 under section 

110(k)(3) as meeting the requirements of section 110 and Part D of the CAA as amended in 

1990. 

REFERENCES -

1. El Dorado County Air Quality Management District Reasonably Available Control 

Technology (RACT) State Implementation Plan (SIP) Update Analysis Staff Report, dated 

December 15, 2006, adopted February 6, 2007; submitted July 11, 2007.

2. EPA proposed approval of EDAQMD 2006 RACT SIP. 78 FR 63934 (October 25, 2013).

3. EPA's TSD supporting proposed approval of EDAQMD's 2006 RACT SIP.

4. 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").

5. September 7, 1978 memo from Rhoads to EPA Regions, Clarification of Degreasing 

Regulation Requirements.

6. EPA-450/2-78-015 – Control of VOC Emissions from Existing Stationary Sources, Volume 

VI: Surface Coating of Miscellaneous Metal Parts and Products.

7. EPA-450/2-77-022 – Control of VOC Emissions from Solvent Metal Cleaning.

8. EPA-450/2-78-033 – Control of VOC Emissions from Existing Stationary Sources, Volume 

VIII: Graphic Arts – Rotogravure and Flexography.