December 11, 2012 

El Dorado County 

Air Quality Management District Board of Directors 

330 Fair Lane 

Placerville, CA 95667 

Subject: Public Hearing to adopt Negative Declarations for three Control Techniques 

Guidelines (CTG) concerning Miscellaneous Metal Parts coating, Solvent 

Cleaning, and Graphic Arts operations. 

Honorable Board Members: 

Recommendation

Acting as the Board of Directors of the El Dorado County Air Quality Management 

District, Air Quality Management District (EDCAQMD) recommends the Board adopt 

Negative Declarations for three Control Techniques Guidelines (CTG) to comply with 

Section 182(b)(2) of the Federal Clean Air Act. EDCAQMD recommends the Board: 

1) Approve three Negative Declarations for each of the following US Environmental 

Protection Agency (EPA) Control Techniques Guidelines (CTG) indicating there are no 

sources within El Dorado County subject to any of these three CTG. 

 a. Miscellaneous Metal Parts and Products CTG (EPA 450/2-78-015) 

 b. Solvent Metal Cleaning CTG (EPA 450/2-77-022) 

 c. Graphic Arts - Rotogravure and Flexography CTG (EPA 450/2-78-033). 

Adoption of these Negative Declarations will allow the United States Environmental 

Protection Agency (EPA) to fully approve the 2006 Reasonably Available Control 

Technology (RACT) State Implementation Plan (SIP) Update. No changes would be 

made to any existing EDCAQMD rules. 

Fiscal Impact/Change to Net County Cost

There is no direct fiscal impact from this action. Adoption of the Negative Declarations 

will mean EDCAQMD will not assume the costs associated new Rule development. 

Additionally, there will be no new fiscal impact on industry. 

Background

EDCAQMD prepared a Reasonably Available Control Technology / State 

Implementation Plan (RACT/SIP) Update Analysis in 2006, since a portion of El Dorado 

County was designated as “severe” non-attainment for the federal 8-hour ozone 

standard. This Update Analysis covered Major Sources, non-Major Sources, and Major 

non- CTG. A “Major Source” of Volatile Organic Compounds (VOC) in El Dorado County 

is defined as an emission source having a potential to emit of 25 tons or more of VOC 

per year. 
Reasonably Available Control Technology (RACT) is defined in 44 FR 53762, as “the 

lowest emission limitation that a particular source is capable of meeting by the 

application of control technology that is reasonably available considering technological 

and economic feasibility”. Section 182(b)(2) of the Federal Clean Air Act requires 

districts designated as “moderate” or worse for ozone non-attainment to implement 

applicable VOC RACT rules for stationary sources. EPA publishes source-specific 

Control Techniques Guidelines (CTG) that define RACT level controls and Alternate 

Control Technique (ACT) Guidance that discusses control technology but does not 

explicitly define RACT. If a District does not contain any sources subject to the CTG, 

the District may adopt a Negative Declaration in lieu of adopting a prohibitory rule. 

 

The 2006 RACT / SIP Update Analysis concluded that seven (7) EDCAQMD Rules met 

the RACT requirement, one (1) new Rule for Miscellaneous Metal Parts coating was 

required, and 18 Negative Declarations would be adopted for the remaining CTG. The 

Board adopted the 2006 RACT / SIP Update Analysis in early 2007 and forwarded the 

document to the California Air Resources Board (CARB) and EPA for approval. The 

EPA has yet to provide final approval of the entire 2006 RACT / SIP Update because 

EDCAQMD has not adopted a Miscellaneous Metal Parts Rule or a Negative 

Declaration in lieu of this rule. Additionally, the EPA did not agree with EDCAQMD's 

assessment that the existing Solvent Cleaning Rule 225 and Graphic Arts Rule 231 

meet current RACT. 

Reason for Recommendation

Miscellaneous Metal Parts: By adopting the 2006 RACT / SIP Update Analysis, the 

Board directed EDCAQMD to prepare and implement a prohibitory Miscellaneous Metal 

Parts Rule for existing non-Major Volatile Organic Compounds emitting sources. 

Preparation and adoption of this Rule would have satisfied the requirement to comply 

with the Miscellaneous Metal Parts and Products Control Techniques Guideline 

(EPA 450/2-78-015). This Rule has yet to be adopted. However, according to Page 2-

16 of “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations: 

Clarification to Appendix D of November 24, 1987 Federal Register” published by the 

EPA on May 25, 1988, Miscellaneous Metal Parts sources which do not exceed 10 tons 

per year (tpy) potential VOC emissions are exempt from the CTG. EDCAQMD has reevaluated the existing sources and believes there are only two sources in the County 

which fall into this CTG category, and neither of them emits more than 1 tpy VOC, or 

would emit more than 10 tpy in the reasonably foreseeable future. Therefore 

EDCAQMD has determined there are no sources that would be subject to the CTG and 

now recommends the Board adopt a Negative Declaration instead of developing a 

Miscellaneous Metal Parts rule. 

Solvent Cleaning: The 2006 RACT / SIP Update Analysis states EDCAQMD's current 

Rule 225 Organic Solvent Cleaning and Degreasing (adopted 9/27/94) meets 

Reasonably Available Control Technology and therefore satisfies the Solvent Metal 

Cleaning Control Techniques Guidelines (EPA 450/2-77-022). The EPA disagrees 

citing that other adjacent District’s have adopted Rules with more stringent RACT 

requirements with respect to Solvent Cleaning. EDCAQMD recently reviewed the 
September 7, 1978 memorandum entitled “Clarification of Degreasing Regulation 

Requirements,” by Richard G. Rhoads, Director of the Control Programs Development 

Division of the US EPA’s Office of Air Quality Planning and Standards. This memo 

states sources emitting less than 100 tpy VOC in jurisdictions with less than 200,000 

people can be exempted from complying with the CTG. EDCAQMD has re-evaluated 

the existing sources and determined there are no sources or reasonably foreseeable 

sources within El Dorado County emitting above this level and thus no sources would be 

subject to the Solvent Metal Cleaning Control Techniques Guidelines. Therefore, 

EDCAQMD now recommends the Board instead adopt a Negative Declaration; no 

changes to the existing Solvent Cleaning Rule 225 are recommended. 

Graphic Arts: The 2006 RACT / SIP Update Analysis states EDCAQMD’s current Rule 

231 Graphic Arts Operations (adopted 9/27/94) meets Reasonably Available Control 

Technology and therefore satisfies the Graphic Arts - Rotogravure and Flexography 

Control Techniques Guidelines (EPA 450/2-78-033). The EPA disagrees citing that 

other adjacent District’s have adopted Rules with more stringent RACT Technology 

requirements with respect to Graphic Arts. However, according to Page 2-25 of “Issues 

Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations: Clarification to 

Appendix D of November 24, 1987 Federal Register” published by the EPA on May 25, 

1988, Graphic Arts Operations sources which do not exceed 100 tpy potential Volatile 

Organic Compounds emissions are exempt from the CTG. EDCAQMD has reevaluated the existing sources and determined there are no sources within El Dorado 

County emitting above this level and thus no sources would be subject to the Graphic 

Arts CTG. Therefore, EDCAQMD now recommends the Board instead adopt a 

Negative Declaration; no changes to the existing Graphic Arts Rule 231 are 

recommended. 

Upon approval of the Negative Declarations by the Board, EDCAQMD staff will forward 

the approvals to the CARB and ultimately on to the EPA for approval of the Reasonably 

Available Control Technology State Implementation Plan. 

By adopting these Negative Declarations, EDCAQMD is not adopting new requirements 

for emissions sources or altering existing requirements. No source will need to change 

its operations to comply with a requirement. Therefore, the action is not subject to the 

California Environmental Quality Act (CEQA) pursuant to Guidelines Section 

15060(c)(2) & (3). No further CEQA review is required. 

EDCAQMD held a noticed public meeting on November 1, 2012 to allow the public to 

provide comments on the proposed Negative Declarations. No other public meetings 

were held. No public comments were received. 

The Board Hearing to consider the adoption of above resolution was noticed in the 

Mountain Democrat and the Tahoe News Tribune. The purpose of the Board Public 

Hearing is to consider public comments regarding the three proposed Negative 

Declarations. 

Action(s) to be taken following Board approval
1. Upon adoption, the Board Clerk’s office will forward copies of the resolution to 

AQMD. 

2. AQMD will forward the approved resolution to CARB for CARB Board approval and 

inclusion in the California Reasonably Available Control Technology State 

Implementation Plan submittal. 

Contact

Dave Johnston, x7578 

Concurrences

The Resolutions have been reviewed and approved by County Counsel. 

Attachments: (A) Resolution: Negative Declaration for Miscellaneous Metal Parts CTG 

 (B) Resolution: Negative Declaration for Solvent Cleaning CTG 

 (C) Resolution: Negative Declaration for Graphic Arts CTG