UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA's Notice of Proposed Rulemaking

for the

California State Implementation Plan

EPA’s Evaluation of

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

“2006 RACT SIP TSD”

Prepared by: Stanley Tong

September 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 Reasonably Available Control Technology (RACT) State 

Implementation Plan (SIP) Update Analysis Staff Report dated 

December 15, 2006 (“2006 RACT SIP”)

Adopted – February 6, 2007

Submitted – July 11, 2007

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

severe1ozone 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. The following provides a brief discussion of RACT and how 

it differs from other types of control standards such as those for new sources. EPA defines 

RACT as the “lowest emissions limitation that a particular source is capable of meeting by the 

application of control technology that is reasonably available considering technological and 

economic feasibility.” 44 FR 53761 (September 17, 1979). A RACT analysis should, therefore, 

take into account the technological and economic impacts of controls, and may differ from 

source to source and location to location.

RACT applies to existing sources in nonattainment areas and differs from the more stringent 

lowest achievable emission rate (LAER) controls required for new and modified sources in 

nonattainment areas. LAER is defined in CAA Section 171(3) and 40 CFR 51.165(a)(1)(xiii) as 

“the most stringent emissions limitation which is contained in the implementation plan of any 

 

1

On May 5, 2010 (75 FR 24409), EPA granted the State of California's request to reclassify the 

Sacramento Metropolitan ozone nonattainment area from "serious" to "severe-15". Since EDAQMD’s 

submittal identified major VOC/NOx sources emitting at least 25 tons per year (tpy), EPA evaluated it as a 

“severe” ozone nonattainment area even though at the time of EDAQMD’s submittal, the District was 

classified as a “serious” ozone nonattainment area.
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State for such class or category of source, unless the owner or operator of the proposed 

source demonstrate that such limitations are not achievable; or ... the most stringent 

emissions limit which is achieved in practice by such class or category of stationary sources.”

Best available control technology (BACT) controls apply to new and modified major sources in 

areas designated as attainment or unclassifiable for the NAAQS and is defined as an emission 

limitation based on the maximum degree of pollutant reduction which the reviewing authority, 

on a case-by-case basis, taking into account energy, environmental, and economic impacts 

and other costs, determines is achievable for the source or modification. CAA Section 169(3), 

40 CFR 51.166(b)(12).

Unlike LAER, RACT allows for consideration of the economic impact of the controls. 

Therefore, if a certain type of emission control or emission limitation is determined to be too 

costly in light of the amount of emission reduction it achieves, that control might not be 

considered RACT. Also, as economic factors may vary within a State and between different 

States, a control technology or emission limitation approved as RACT in one location does not 

necessarily define RACT for another location. 

Section IV.G of EPA’s final rule to implement the 8-hour ozone national ambient air quality 

standard (70 FR 71612, November 29, 2005) discusses RACT requirements. It states in part 

that where a RACT SIP is required, State SIPs implementing the 8-hour standard generally 

must assure that RACT is met, either through a certification that previously required RACT 

controls represent RACT for 8-hour implementation purposes or through a new RACT 

determination. 70 FR 71612 at 71655.

The preamble to the final rule further explains that “many areas subject to the major source 

RACT requirement under the 8-hour ozone standard have previously addressed the RACT 

requirement with respect to the 1-hour ozone standard.... We believe that, in many cases, a 

new RACT determination under the 8-hour standard would result in the same or similar control 

technology as the initial RACT determination under the 1-hour standard because the 

fundamental control techniques, as described in the CTGs and ACTs, are still applicable.” 70 

FR 71612 at 71654.

It adds that “States and other interested parties should consider available information that may 

supplement the CTG and ACT documents. In cases where additional information is presented, 

for example, as part of notice-and-comment rulemaking on a RACT SIP submittal, States (and 

EPA) would necessarily consider the additional data in reviewing what control obligation is 

consistent with RACT... The State should submit a certification as part of its SIP revision, with 

appropriate supporting information, such as consideration of new data, that these sources are 

already subject to SIP-approved requirements that still meet the RACT obligation.” 70 FR at 

71612 at 71655.

To help California and its local air districts with their RACT SIP certifications, on March 9, 

2006, EPA Region IX sent a letter to the California Air Resources Board (CARB) and local air 

districts discussing EPA Region IX’s understanding of what might constitute a minimally 

acceptable RACT SIP submittal. In that letter we reminded States that we believed they must 
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consider new information that has become available and certify that a 1-hour RACT 

determination, even where controls were required, still represent an appropriate RACT level of 

control for the 8-hour ozone program. The letter offered the following suggestions to be 

included in a RACT SIP analysis and indicated that the more rigorous the analysis and 

aggressive the requirements, the more likely that EPA will be able to approve them:

 Describe efforts to identify all source categories within the District requiring RACT, 

including CTG sources (i.e., covered by an EPA Control Techniques Guidelines

document) and major non-CTG sources.

 Submit negative declarations where there are no facilities (major or minor) within the 

District subject to a CTG.

 For all categories subject to RACT, list the state/local regulation that implements RACT. 

 Describe the basis for concluding that the regulations fulfill RACT. Documents useful in 

establishing RACT include CTGs, Alternative Control Technique guidance (ACTs), 

Maximum Achievable Control Technology (MACT) standards, New Source 

Performance Standards (NSPS), California Suggested Control Measures (SCM) and 

RACT/Best Available Retrofit Control Technology (BARCT) determinations, regulations 

adopted in other Districts, and guidance and rules developed by other state and local 

agencies.

 Where a District relies on the California Air Pollution Control Officer Association’s 

(CAPCOA's) September 2003, Potential All Feasible Measures (AFM) Report to help 

demonstrate RACT, the RACT SIP should certify that local regulations are equivalent to 

AFM, justify the assumption that the AFM fulfilled RACT in 2003, and include a 

certification/demonstration that no additional controls have become more reasonably 

available since then.

EPA Region IX also provided CARB and the local air districts with a list of current CTGs and 

ACTs, and suggested language for negative declarations to cover cases where the local air 

district had no sources covered by a CTG.

Where public commenters submit specific information to a State about controls that are 

reasonably available in light of technological and economic feasibility, the State should 

consider such information in developing its RACT SIP. EPA generally considers controls that 

have been achieved in practice by a significant number of sources to be technologically and 

economically feasible.

SUBMITTAL SUMMARY -

EDAQMD Reasonably Available Control Technology (RACT) State Implementation Plan (SIP)

Update Analysis Staff Report, dated December 15, 2006. [hereinafter “2006 RACT SIP”]

EDAQMD's submittal included the following documents:

a. EDAQMD Board Letter, dated December 15, 2006
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b. Resolution 016-2007, dated February 6, 2007

c. “Reasonably Available Control Technology (RACT) State Implementation Plan (SIP) 

Update Analysis Staff Report,” dated December 15, 2006

d. EPA Comments, dated November 28, 2006

e. EDAQMD Responses, dated December 15, 2006

EDAQMD researched its rules to verify that all major sources and sources covered by a CTG 

category were regulated by a SIP approved rule that satisfied RACT. The District's submittal 

listed a large number CTGs for which the District did not have any sources.

EPA EVALUATION CRITERIA –

EPA evaluated the following elements of EDAQMD’s RACT SIP submittal as listed in our

March 9, 2006 letter to CARB.

 Efforts to identify all source categories within the District requiring RACT

 Negative declarations where there are no facilities subject to a CTG

 List of the State/local regulations that implement RACT

 The bases for concluding that all referenced regulations fulfill RACT

The following documents were also used to support our review:

 "Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard –

Phase 2" (70 FR 71612; November 29, 2005).

 "State Implementation Plans, General Preamble for the Implementation of Title I of the 

Clean Air Act Amendments of 1990" (57 FR 13498; April 16, 1992).

 Enforceability - Section 110(a) of the CAA requires enforceable emission limitations and 

other control measures. Several EPA guidance documents are used to evaluate rule 

enforceability, including 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"), and EPA Region IX’s 

Guidance Document for Correcting Common VOC and Other Rule Deficiencies, August 

21, 2001 (the "Little Bluebook").

 "State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for 

Implementation of Title I of the Clean Air Act Amendments of 1990” (57 FR 55620, 

November 25, 1992) ("the NOx Supplement").

 Memorandum from William T. Harnett to Regional Air Division Directors, (May 18, 2006), 

“RACT Qs & As – Reasonably Available Control Technology (RACT) Questions and 

Answers”.

 RACT SIPs, Letter dated March 9, 2006 from EPA Region IX (Andrew Steckel) to CARB 

(Kurt Karperos) describing Region IX’s understanding of what constitutes a minimally 

acceptable RACT SIP.

 Letter dated April 4, 2006 from EPA Region IX (Andrew Steckel) to CARB (Kurt 

Karperos) listing EPA’s current CTGs, ACTs, and other documents which may help to 

establish RACT.

 EPA's CTGs and ACTs http://www.epa.gov/ttn/naaqs/ozone/ctg_act/index.htm

 CARB’s emissions inventory database 

http://www.arb.ca.gov/app/emsinv/facinfo/facinfo.php

 CARB and EPA Region IX databases of EDAQMD rules
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CARB: http://www.arb.ca.gov/rldb/rldb.htm

EPA: http://epa.gov/region09/air/sips/index.html

The following summarizes EDAQMD actions to address RACT requirements and EPA’s

evaluation of those actions.

1. Efforts to identify all source categories within the District subject to RACT.

RACT is required for source categories covered by an EPA Control Techniques Guidelines 

document (“CTG sources”) and all sources that are not covered by a CTG document but are 

“major sources” (i.e., for EDAQMD, “non-CTG sources” emitting at least 25 tons per year of 

VOCs or NOx based on an ozone nonattainment classification of “severe”.)2

El Dorado AQMD action:

EDAQMD’s staff report indicates "District rules that have been SIP-approved by U.S. EPA 

are considered to meet RACT requirements" because EPA evaluated the rules fulfill RACT 

in the process of approving these rules into the SIP. EDAQMD also points out that the 

District is required by the California Health and Safety Code to implement All Feasible 

Control Measures and Best Available Retrofit Control Technology and that in general; these 

requirements are more stringent than RACT. Lastly, the District points out that all CTG 

source categories were compared against adopted District rules and determined whether 

the adopted rules meet or exceed the CTG.

The District's staff report indicates it has a new non-major source subject to the 

Miscellaneous Metal Parts and Products CTG for which there is no District rule.

Also, as a serious ozone nonattainment area, EDAQMD is required to analyze RACT for all 

sources that emit or have the potential to emit at least 50 tpy of VOC and NOx (CAA 182(c)

and (f)). However, on being redesinated as a “severe” ozone nonattainment area, the major 

source threshold is lowered to 25 tpy. EDAQMD’s 2006 RACT SIP searched for sources 

emitting at least 25 tpy of VOC or NOx and identified only one major source in the District, 

Sierra Pacific Industries.

EPA evaluation:

The District's 2006 analysis identified potential new source(s) covered under the 1978 

Miscellaneous Metal Parts and Products CTG for which it did not have a SIP approved rule.

A RACT rule is required if sources are subject to a CTG and exceed the CTG's emissions 

threshold cutoff. However, recent discussions with EDAQMD indicate the subject facilities 

do not exceed the applicability threshold for the Miscellaneous Metal Parts and Products 

 

2 While the El Dorado AQMD was classified as “serious” nonattainment for the 1997 8-hour ozone NAAQS at the 

time that California submitted the 2006 RACT SIP to EPA, the District’s 2006 RACT SIP considered major sources 

at the “severe” classification (e.g., sources emitting at least 25 tons per year of VOC or NOx. See 2006 RACT SIP 

at 8). On May 5, 2010, EPA approved California’s request to reclassify EDAQMD as a “severe” ozone 

nonattainment area.
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CTG. Based on this, a new RACT rule is not required, but EDAQMD should submit a 

negative declaration. Further discussion of this issue is provided in section 4.1 below.

We reviewed CARB's 2007 emissions inventory to identify major VOC and NOx emission 

sources in EDAQMD. Other than Sierra Pacific Industries, there were no stationary sources 

with VOC or NOx emissions exceeding 25 tpy. As discussed later, Sierra Pacific Industries 

closed its operations in 2009 and does not appear in CARB's 2010 emissions inventory. 

The next largest source of VOC/NOx in EDAQMD was Union Mine Landfill at 4.2 tpy VOCs 

and 2.1 tpy NOx.

Based on our review of CARB's emissions inventory database, no additional CTG source 

category or major source in the District that is subject to section 182 RACT were identified 

as requiring RACT but missing from EDAQMD’s analysis.

2. Submit negative declarations where there are no facilities subject to a CTG

EDAQMD action:

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

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

EDAQMD concludes that there are no sources subject to the following CTG categories after 

reviewing: its records for permitted sources, public notices, SIC codes, other source data, 

emissions inventory and personal knowledge. These categories are listed in Part 2, Table C 

of the District’s 2006 RACT SIP, and in Table A of the Appendix to its staff report.

Negative Declarations

CTG Source Category Negative Declaration – CTG Reference Document

Aerospace EPA-453/R-97-004 - Control of VOC Emissions from 

Coating Operations at Aerospace Manufacturing and

Rework 

Automobile Coating;

Metal Coil Container, &

Closure; Paper & Fabric

EPA-450/2-77-008 - Control of Volatile Organic 

Emissions from Existing Stationary Sources - Volume 

II Surface Coating of Cans, Coils, Paper, Fabrics,

Automobiles, and Light-Duty Trucks

Large Appliances EPA-450/2-77-034 - Control of Volatile Organic 

Emissions from Existing Stationary Sources, Volume 

V: Surface Coating of Large Appliances

Magnet Wire EPA 450/2-77-033 - Control of Volatile Organic 

Emissions from Existing Stationary Sources, Volume 

IV: Surface Coating of Insulation of Magnet Wire

Metal Furniture EPA-450/2-77-032 - Control of Volatile Organic 

Emissions from Existing Stationary Sources, Volume 

III: Surface Coating of Metal Furniture

Ships 61 FR 44050 Shipbuilding and Ship Repair 

Operations (Surface Coating)

Wood Coating: Factory EPA 450/2-78-032 - Control of Volatile Organic 
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CTG Source Category Negative Declaration – CTG Reference Document

Surface of Flat Wood 

Paneling

emissions from Existing Stationary Sources, Volume 

VII: Factory Surface of Flat Wood Paneling

Wood Furniture EPA 453/R-96-007 - Control of VOC Emissions from 

Wood Furniture Manufacturing Operations

Natural Gas/Gasoline EPA-450/2-83-007 - Control of VOC Equipment Leaks 

from Natural Gas/Gasoline Processing Plants

Refineries EPA-450/2-77-025 - Control of Refinery Vacuum 

Producing Systems, Wastewater Separators, and 

Process Unit Turnarounds

EPA-450/2-78-036 - Control of VOC Leaks from 

Petroleum Refinery Equipment

Synthetic Organic 

Chemical

EPA-450/3-84-015 - Control of VOC Emissions from 

Air Oxidation Processes in Synthetic Organic 

Chemical Manufacturing Industry

EPA-450/4-91-031 - Control of VOC Emissions from 

Reactor Processes and Distillation Operations in 

SOCMI

Tanks EPA-450/2-77-036 – Control of VOC Emissions from 

Storage of Petroleum Liquids in Fixed Roof Tanks

EPA-450/2-78-047 – Control of VOC Emissions from 

Petroleum Liquid Storage in External Floating Roof 

Tanks

Dry Cleaning EPA-450/3-82-009 - Control of VOC Emissions from 

Large Petroleum Dry Cleaners

Pharmaceutical Products EPA-450/2-78-029 – Control of Volatile Organic 

Emissions from Manufacture of Synthesized 

Pharmaceutical Products

Polyester Resin EPA- 450/3-83-008 - Control of VOC Emissions from 

Manufacture of High-Density Polyethylene,

Polypropylene, and Polystyrene Resins

EPA-450/3-83-006 - Control of VOC Fugitive 

Emissions from Synthetic Organic Chemical Polymer 

and Resin Manufacturing Equipment

Rubber Tires EPA-450/2-78-030 - Control of Volatile Organic 

Emissions from Manufacture of Pneumatic Rubber 

Tires

EPA evaluation:

EPA's review of EDAQMD's emissions inventory did not identify sources that were covered 

by the above CTGs.
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Our review identified three potential source categories EDAQMD should consider for 

negative declarations. Further discussion is provided in Section 4.1 below.

CTG Source Category Negative Declaration – CTG Reference Document

Metal Parts & Products EPA-450/2-78-015 – Control of VOC Emissions from 

Existing Stationary Sources, Volume VI: Surface 

Coating of Miscellaneous Metal Parts and Products

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

Existing Stationary Sources, Volume VIII: Graphic Arts 

– Rotogravure and Flexography

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

Solvent Metal Cleaning

3. List the State/local regulations that implement RACT

EDAQMD action:

Part 3 of EDAQMD's 2006 RACT SIP identifies the District rule history for seven rules which 

implement RACT and the SIP approval status of those rules. Table A of the Appendix to the 

2006 RACT SIP lists the CTG categories, the associated rule implementing those CTGs 

and a brief statement on whether the applicable rule satisfies RACT. 

EPA evaluation:

We believe that four of the seven rules are not required to meet RACT because the District 

does not have sources exceeding the applicability threshold for the CTGs for solvent 

cleaning and graphic arts and their only major source, a biomass boiler, has ceased 

operations. Specifically, we believe the following rules are not required to demonstrate 

RACT: 

Rule 225 Organic Solvent Cleaning and Degreasing Operation;

Rule 231 Graphic Arts;

Rule 232 Biomass Boilers; and

Rule 234 VOC RACT Rule – Sierra Pacific Industries. 

4. The bases for concluding that all referenced regulations fulfill RACT

EDAQMD action:

EDAQMD's bases for concluding its rules continue to satisfy RACT for the 8-hour ozone 

standard involved reviewing the SIP status of the rules; the adoption date and date of the 

latest amendments; and comparing the SIP approval date with the adoption/amendment 

date to determine if any rules were subsequently amended after they were last approved 

into the SIP.

Table A of the Appendix to EDAQMD's staff report lists the rules corresponding to specific 

CTGs and provides a brief statement why EDAQMD believes the rules continue to satisfy 

RACT. On November 28, 2006, EPA provided comments to improve EDAQMD’s 2006 

RACT SIP Update Analysis Staff Report, dated November 17, 2006. On December 15, 
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2006, EDAQMD responded to our comments and provided a short statement on why the 

District believes the individual rules continue to meet RACT.

EPA evaluation:

Generally, EDAQMD concludes its rules continue to satisfy RACT for the 8-hour standard 

based on the following criteria: 1) EPA SIP-approved rules meet RACT; 2) District rules that 

implement California's Best Available Retrofit Control Technology fulfill RACT; and 3) a 

comparison of CTG source category controls against controls in District rules to determine if 

the rules met or exceeded the CTG. Because several of the CTGs were issued a number of 

years ago and because RACT can change over time, we believe EDAQMD's analysis could 

have been more thorough by also comparing its rules against rules in other ozone nonattainment areas. 

Our evaluation of EDAQMD's responses to our November 28, 2006 comments is provided 

below:

4.1 EPA’s 11/2006 comment: Page 7 of EDAQMD’s staff report states the District has new 

non-major emission sources covered by the Miscellaneous Metal Parts and Products

CTG, but has no rule at this time. EDAQMD’s response indicated a RACT rule will be 

promulgated as expeditiously as possible.

ACTION – EDAQMD should submit a negative declaration – The 1978 Metal Parts 

and Products CTG applies to coating operations with a potential-to-emit of 10 tpy of 

VOC or actual emissions of 15 lbs/day3. Discussion with District staff indicates that 

emissions from their metal coating facilities are below the CTG's applicability threshold.4

In December 2012, EDAQMD adopted a negative declaration for the 1978 

miscellaneous metal parts and products CTG. The negative declaration should be 

submitted to EPA.

To comply with the 2008 Miscellaneous Metal and Plastic Parts CTG, a RACT rule must 

be submitted if actual emissions at these facilities ever equal or exceed 2.7 tpy.

4.2 EPA’s 11/2006 comment: Negative declarations are needed for Bulk Gasoline Plants; 

Petroleum Liquids in Fixed Roof Tanks; and Petroleum Liquids in Floating Roof Tanks if 

the District has no sources in these CTG categories. EDAQMD’s response indicated the 

Bulk Gasoline Plants CTG is covered by Rule 244, and that they do not have any 

sources covered by the remaining two CTGs. 

Complete – EDAQMD's December 15, 2006 response to EPA's comments clarified that

the District had no sources covered by the fixed and floating roof CTGs. In addition, 

 

3

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") page 2-

16.

4

email dated February 29, 2012 from Stanley Tong (EPA Region 9) to Adam Baughman (El Dorado AQMD) 

Update – El Dorado Disposal and Rack It Truck Racks Permits, reporting El Dorado Disposal only emitted 0.24 

and 0.28 tons of VOC in the two previous years and Rack It emitted 0.7 tons of VOC in 2011.
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Table C of the District’s December 15, 2006 RACT SIP listed Tanks as a negative 

declaration.

4.3 EPA’s 11/2006 comment: Particularity where the last RACT determination may have 

occurred many years ago, the staff report should reflect some analysis that RACT has 

not subsequently changed. Our comment pointed out that Rule 232: Biomass Boilers

and Rule 234: VOC RACT Rule – Sierra Pacific Industries apply to the District’s only 

major source, Sierra Pacific Industries, and were last amended in 2001 and 1995

respectively. EDAQMD indicated a 1993 RACT determination performed for EPA 

Region IX by Radian Corporation5 was still appropriate and that Rule 232 was identical 

to Placer Rule 233 and meets RACT.

Source ceased operations, no action required at this time – EDAQMD's only major 

source covered by Rules 232 and 234, Sierra Pacific Industries, ceased operations in 

2009 and has not restarted.

6 EPA is not recommending any action to evaluate and 

update these rules to meet current RACT until such time that sawmill operations 

resume and the facility is determined to be a major source of VOC or NOx. 

Analysis of six additional rules

EPA’s November 2006 comment letter also recommended that at a minimum, for six 

rules listed in Enclosure (1) of our comment letter, a short comparison of EDAQMD 

controls versus rules in two or three other air districts should be conducted. The 

analysis should clarify if there are any significant changes in technology that might 

affect the District's RACT determination.

Incomplete but does not affect RACT – recommendations for rule improvement

EDAQMD’s response did not contain further details of how the District concluded their

rules still represent current RACT, but primarily asserted that the rules met RACT by 

referencing the current CTG. A brief statement that a rule meets the CTG, some of 

which were written more than 20 years ago, is not adequate to demonstrate the rule 

meets current RACT level controls. The following summarizes EPA's RACT review of 

the EDAQMD rules listed in Enclosure (1) of our comment letter.

Rule 224 – Cutback Asphalt – EDAQMD response: “Rule 224 meets RACT from the 

current CTG.” 

EPA's comment letter indicated the South Coast AQMD was reviewing cutback asphalt 

as part of its RACT SIP demonstration. The SCAQMD analysis concluded7no further 

emission reductions from this category was reasonably available.

EDAQMD Rule 224 is generally similar to South Coast AQMD Rules 1108 and 1108.1.

 

5

RACT Determination for Michigan-California Lumber Company Technical Support Document Final Report, 

Prepared by Radian Corporation, December 17, 1993; copy filed with docket for 60 FR 43718 September 12, 1995 

(EPA Region IX docket CA 9535).

6

“Perfect Storm” Shuts Camino Sawmill, June 11, 2009 

http://www.news10.net/news/local/story.aspx?storyid=60970&provider=topstories

7

South Coast AQMD Technical Assessment for Rule 1108 – Cutback Asphalt, June 2008
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– no further EDAQMD action required

Rule 225 – Organic Solvent Cleaning and Degreasing – EDAQMD response: “Rule 

225 meets RACT from the current CTG”.

EPA guidance exempts cold solvent cleaning sources in rural areas (< 200,000 

population) from the CTG recommendations and also exempts vapor degreasers that 

are <100 tpy on a facility-wide basis8in rural areas. EDAQMD's population is < 

200,0009and therefore not subject to the 1977 CTG for Solvent Metal Cleaning (EPA450/2-77-022).

ACTION – EDAQMD should submit a negative declaration – In December 2012, 

EDAQMD adopted a negative declaration for the 1977 solvent cleaning CTG. The 

negative declaration should be submitted to EPA.

Additional Recommendation: 

Although Rule 225 is not subject to the 1977 Solvent Metal Cleaning CTG, EDAQMD 

should consider updating Rule 225 to match VOC solvent cleaning limits used in 

practice in nearby air districts with a similar ozone non-attainment classification. Some 

air districts have adopted solvent cleaning limits of 25 g/l for general solvent cleaning

operations10.

Rule 231 – Graphic Arts – EDAQMD response: “Rule 231 meets RACT from the 

current CTG. The applicability threshold from the new CTG will be evaluated in the 

future”

The 1978 Rotogravure and Flexographic CTG has an applicability threshold of 100 tpy 

potential-to-emit11. CARB's 2010 emissions inventory does not list any graphic arts 

facilities in EDAQMD and indicates the largest VOC source in the District is a landfill 

emitting 4.2 tpy and the next largest VOC source is an asphalt plant emitting 0.1 tpy. 

ACTION – EDAQMD should submit a negative declaration – In December 2012, 

EDAQMD adopted a negative declaration for the 1978 rotogravure and flexographic 

CTG. The negative declaration should be submitted to EPA.

Additional Recommendation:

Although EDAQMD does not have graphic arts facilities exceeding the 100 tpy 

applicability threshold of the 1978 CTG, we recommend EDAQMD review the 2006 

Lithographic, Letterpress and Flexible Package Printing CTGs to determine if there may 

now be facilities with actual emissions exceeding the 2006 CTG’s threshold of 15 lb/day 

 

8 September 7, 1978 memo from Rhoads to EPA Regions, Clarification of Degreasing Regulation Requirements.

9

El Dorado's population is 181,000 http://quickfacts.census.gov/qfd/states/06/06017.html

10 See Sacramento Metropolitan AQMD Rule 466 (http://airquality.org/rules/rule466.pdf) and South Coast AQMD 

Rule 1171 (http://aqmd.gov/rules/reg/reg11/r1171.pdf).

11 See http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf page 2-25.
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or 2.7 tpy. Rule 231 should also be updated as appropriate based on the District's 

review. See section 4.8 below.

Rule 232 Biomass Boilers – EDAQMD response: “PCAPCD Rule 233 has the same 

NOx limits.”

As stated above, since the only major source of NOx in EDAQMD has ceased 

operations, this rule is no longer required to satisfy current RACT. 

PCAPCD amended Rule 233 on June 14, 2012 to strengthen the NOx limit and to add 

a longer averaging time as a result of EPA’s limited disapproval of an earlier version of 

PCAPCD Rule 23312. EDAQMD should similarly amend Rule 232 to meet current RACT 

if biomass boiler operations resume within the District and emissions exceed the major 

source threshold.

– no EDAQMD action required at this time.

Rule 234 VOC RACT Rule – Sierra Pacific Industries – See comments on Rule 232

above. Sierra Pacific closed its Camino, CA operations in 2009. This rule is no longer 

required to demonstrate it satisfies current RACT since there is no longer a VOC major 

stationary source in the District.

– no EDAQMD action required at this time.

Rule 237 Wood Products Coating Operations – EDAQMD response: “EDCAQMD 

has no sources which meet the CTG applicability threshold of 25 tpy of potential VOC 

emissions.”

EDAQMD submitted a negative declaration for the two wood coating CTGs. 

– no further EDAQMD action required.

4.4 EPA’s 11/2006 comment: Rule 216, Organic Compounds; adopted 3/12/1984; is SIP 

approved under the Mountain Counties Air Basin. The rule defines a VOC using a 

vapor pressure limit. This conflicts with EPA’s definition of VOCs in 40 CFR 51.100(s). If

Rule 216 is needed for RACT, it should be updated and adopted for EDAQMD.

EDAQMD response stated Rule 216 is not needed for RACT and will be deleted from 

the analysis.

Recommendation:

Although Rule 216 was removed from the District's RACT SIP analysis it should also be 

formally rescinded from the SIP if it is no longer needed. Rule 216 appears in 

EDAQMD’s list of effective rules on CARB’s webpage13 and on EPA's list of SIP rules 

for the Mountain Counties Air Basin. Rule 216 contains a vapor pressure cutoff (1.5 

psia) that effectively exempts some VOCs such as ethanol and toluene from VOC 

controls. Further, the use of a vapor pressure cutoff is a deficiency pointed out in Issues 

 

12 See 77 FR 2643, January 19, 2012.

13 See http://www.arb.ca.gov/DRDB/ED/CURHTML/R216.HTM and 52 FR 45105,45108 November 24, 1987.
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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"). It is unclear how Rule 216 interfaces with other 

EDAQMD rules since many District rules we reviewed contain their own definition for 

VOC.

Recommendation:

EDAQMD should review the list of SIP rules from El Dorado County, Lake Tahoe Air 

Basin, and Mountain Counties Air Basin14 that pre-date the formation of EDAQMD and 

determine which rules along with Rule 216 should be rescinded from the SIP.

4.5 EPA’s 11/2006 comment: Rule 244, Organic Liquid Loading, was approved into the SIP 

on 7/8/2002, so it does not need to be re-submitted for SIP approval by EDAQMD.

– No action required by EDAQMD.

4.6 EPA’s 11/2006 comment: Rule 215, Architectural Coatings’ 250 g/l limit for traffic 

coatings is less stringent than EPA’s national rule limit of 150 g/l. Architectural coatings 

is not a CTG category.

EDAQMD response states the traffic coatings VOC limit will be addressed when Rule 

215 is opened for amendment and that since there are no CTGs or major sources, this 

is not a RACT issue.

Recommendation:

EPA's more stringent national limits apply to manufacturers of architectural coatings 

used or sold in the United States, whereas EDAQMD's rule applies to the end user of 

architectural coatings. Since the national rule allows manufacturers to continue selling

non-compliant coatings if they qualify for certain provisions such as a tonnage 

exemption (40 CFR 59.404) or pay an exceedance fee (40 CFR 59.403), it is possible 

that non-compliant coatings can still be available. We therefore encourage EDAQMD to 

amend Rule 215 and to consider incorporating CARB’s 2007 architectural coatings 

suggested control measure as a means to comply with the California Health and Safety 

Code requirement to consider every feasible measure.

http://www.arb.ca.gov/coatings/arch/Approved_2007_SCM.pdf

4.7 EPA’s 11/2006 comment: California State Law SB 700 removed the permit exemption 

for agricultural internal combustion engines. EDAQMD Rule 233, Stationary Internal 

Combustion Engines, exempts agricultural engines. 

EDAQMD response – The requirements of SB 700 will be addressed when Rule 233 is 

opened for amendment. There are no CTGs or major sources which have stationary 

internal combustion engines so this is not a RACT issue.

Recommendation:

 

14 EPA's list of rules in the SIP can be found at this site:

http://yosemite.epa.gov/r9/r9sips.nsf/Casips?readform&count=100&state=California
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– no action required at this time. We agree this is not a CTG category and there are no 

major sources in EDAQMD at this time.

4.8 EPA’s 11/2006 comment: Future CTGs. EPA promulgated 11 new/amended CTGs in 

2006 – 2008. A separate analysis of whether EDAQMD has sources subject to these 

CTGs was required one year after promulgation. EDAQMD will need to review the 

applicability of the new/updated CTGs and adopt/submit a separate RACT analysis.

Recommendation:

EDAQMD should review the recent CTGs for applicability and submit an updated 

RACT SIP analysis or negative declarations as appropriate.

5. Summary

The District's conclusion that an approved SIP rule fulfills RACT because EPA has evaluated it 

for RACT may generally hold true, but may not always be the case such as when EPA 

approves a rule only as a SIP strengthening action or when the rule amendments involve nonsubstantive changes. This could occur when a rule is strengthened to clarify definitions or 

update test methods but requirements affecting emissions are not changed.

EDAQMD's RACT SIP analysis lacks specific detail on how the District concluded its rules meet

current RACT. Generally the District states its rules meet RACT based on comparing its rules 

to the CTGs, many of which were issued in the 1970s and 1980s. EPA's review of EDAQMD’s 

rules and CARB's emissions inventory identified only a few emission sources in the District. For 

example, CARB's 2007 emissions inventory only lists 6 facilities in the District (not including

gasoline stations, print shops, autobody shops and dry cleaners). Included in the 6 facilities is 

EDAQMD's only major source, Sierra Pacific Industries, which closed operations in 2009 and 

has not reopened. We also concluded that some sources were below the CTG's applicability 

threshold and therefore not required to meet RACT (e.g., Coating of Miscellaneous Metals 

Parts and Products, Graphic Arts, and Solvent Cleaning CTGs). The District should submit 

negative declarations for these CTGs.

There are a few rules, such as architectural coatings and internal combustion engines, which, 

although not required to satisfy RACT, should be updated to more current standards. EDAQMD 

may want to investigate incorporating emission limits used in neighboring air districts with 

similar non-attainment status, such as the Sacramento Metropolitan Air Quality Management 

District.

There are also some outdated rules which predate the formation of EDAQMD that should be 

rescinded from the SIP. EDAQMD should review these rules as time allows.

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.
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2. RACT SIPs, Letter dated March 9, 2006 from EPA Region IX (Andrew Steckel) to CARB 

(Kurt Karperos) describing Region IX’s understanding of what constituted a minimally 

acceptable RACT SIP.

3. RACT SIPs, Letter dated April 4, 2006 from EPA Region IX (Andrew Steckel) to CARB 

(Kurt Karperos) listing EPA’s current CTGs, ACTs, and other documents which may help to 

establish RACT.

4. RACT Qs & As – Reasonably Available Control Technology (RACT): Questions and 

Answers, May 18, 2006 Memorandum from William T. Harnett, Director, Air Quality Policy 

Division, to Regional Air Division Directors. 

http://www.epa.gov/ttn/caaa/t1/memoranda/ractqanda.pdf

5. Sample Language for Negative Declaration, Letter dated May 25, 2006 from EPA Region 

IX (Andrew Steckel) to CARB (Kurt Karperos).

6. EDAQMD Reasonably Available Control Technology (RACT) State Implementation Plan 

(SIP) Update Analysis Staff Report, November 17, 2006.

7. Comment letter dated November 28, 2006 from EPA Region IX (Andrew Steckel) to 

EDAQMD (Marcella McTaggart) 2006 RACT SIP Update Analysis Staff Report, dated 

November 17, 2006.

8. Letter dated December 15, 2006 from EDAQMD (Marcella McTaggart) to EPA Region IX 

(Andrew Steckel) Responses to EPA letter of November 28, 2006 concerning El Dorado 

County Air Quality Management District (EDC AQMD) 2006 RACT SIP Update Analysis Staff 

Report.

9. "Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard – Phase 

2" 70 FR 71612; November 29, 2005). http://www.gpo.gov/fdsys/pkg/FR-2005-11-29/pdf/05-

22698.pdf

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

Regulation Requirements.

11. 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").

12. EPA Region IX’s Guidance Document for Correcting Common VOC and Other Rule 

Deficiencies, August 21, 2001 (the "Little Bluebook").

13. "State Implementation Plans, General Preamble for the Implementation of Title I of the 

Clean Air Act Amendments of 1990" (57 FR 13498; April 16, 1992).
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14. "State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for 

the Implementation of Title I of the Clean Air Act Amendments of 1990" (57 FR 55620, 

November 25, 1992) ("the NOx Supplement").

15. RACT Determination for Michigan-California Lumber Company Technical Support 

Document Final Report, Prepared by Radian Corporation, December 17, 1993; copy filed with 

docket for 60 FR 43718 September 12, 1995 (EPA Region IX docket CA 9535).

16. EPA's CTGs and ACTs http://www.epa.gov/ttn/naaqs/ozone/ctg_act/index.htm.

17. CARB’s emissions inventory database 

http://www.arb.ca.gov/app/emsinv/facinfo/facinfo.php.

18. CARB and EPA Region IX databases of EDAQMD rules

CARB: http://www.arb.ca.gov/rldb/rldb.htm

EPA: http://epa.gov/region09/air/sips/index.html.

19. Perfect Storm Shuts Camino Sawmill, 6-11-2009, KXTV/News10.

20. South Coast Technical Assessment for Rule 1108 – Cutback Asphalt - June 2008.

21. email dated February 22, 2012 from Adam Baughman (El Dorado AQMD) to Stanley Tong 

(EPA Region 9) - Update - El Dorado Disposal and Rack It Truck Racks.

22. El Dorado 2010 population, US Census.

23. Sacramento Rule 466, Solvent Cleaning (amended 10/28/2010).

24. South Cast Rule 1171, Solvent Cleaning Operations (amended 5/1/2009).

25. El Dorado Rule 216, Organic Compounds (amended 3/12/1984).