**UNITED STA TES ENVIRONMENTA**  **L PROTECTION A GENCY**  **REGION IX A IR DIVISION** 

Technical Support Document

for the California State Implementation Plan El Dorado County Air Quality Management District , Negative Declarations for Control Techniques Gu idelines (CTG)

Source Categories Adopted December 11, 2012

Prepared by: Stanley Tong November 2013- 2 -

**RULE IDENTIFICA**

**TION** - **Ag ency**  **:** El Dorado County Air Quality Management District ( EDAQMD ) **SIP A pproved**  **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 **BA CKGROUND**  **-** 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 ozo ne 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 (“NAAQ S”) 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 fo r 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 thro ugh the same public review requirements as any other SIP submittal. **SUBMITTA L**  **SUMMA RY**  **-** 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 U pdate Analysis "2006 RACT SIP" and submitted its analysis along with a number of negative declarations 1 to 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 c ould 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 RAC T SIP states 2 that 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 Imp lem entation 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.- 3 -

have a rule covering this CTG category. EPA 's rulemaking propos ing to approve EDAQMD's 2006 RA CT SIP analysis identified that the subject facilities d id 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 wa s 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 eval uation 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 Dist rict 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 EVA**  **LUA**

**TION AN**  **D RECOMMENDED A CTION**  **-** 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, 2 013). O ne facility em itted 0.24 tons and 0.28 tons of VOCs in 2010 and 2011 and another facility

emitted 0.7 tons o f VOCs in 2011, well below the CTG’s applicability threshold of 10 tons per year. 4 See TSD accompany ing proposed approval of EDAQMD's 2006 RACT SIP. 78 FR 63934 (October 25, 2013).- 4 -

CTG Source Category Negative Declaration – CTG Reference Document Miscellaneous Metal Parts and Products EPA-45 0 /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 – Co ntrol 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 ne gative 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 Contro l Technology (RACT) State Implementation Plan (SIP) Update Analysis Staff Report, dated December 15, 2006, adopted February 6, 2007; s ubmitted July 11, 2007 . 2. EPA proposed approval of EDAQMD 2006 RACT SIP . 78 FR 63934 (October 25, 2013). 3. EPA's TSD s upporting propos ed 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-45 0 /2 - 78 - 015 – Control of VOC Emissions from Existing Stationary Sources, Volume VI: Surface Coating of Miscellaneous Metal Parts and Pro ducts. 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 .