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 Managemen t District

, R easonably 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- 2

- 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

Im plementation 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 nona ttainment 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 1 ozone nonattainment area for th e 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 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 s ource 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 a nd 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
Sa cramento Metropolitan ozone non attainment area from "serious" to "severe

- 15". Since EDAQMD ’s

s ubmittal 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.- 3

- State for such class or category of source, unl ess 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 technolog y (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 m ay 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 natio nal 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

- h our 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 co ntrol 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 inf ormation 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 re viewing 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, o n March 9, 2006, EPA Region IX sent a letter to the California Air Resources Board (CARB) and local air
districts discuss ing EPA Region IX ’s understanding of what might constitute a minimally acceptable RACT SIP submittal. In that letter we remind ed States that we believe d they must- 4

- 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 follow ing suggest ions 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 D istrict requiring RACT, including CTG sources (i.e., covered by an EPA Control Technique s Guideline s document) and major non

- CTG sources.

• Submit negative declarations where there are no facilities (major or minor) within the District subject to a CTG.

• Fo r 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 Distric ts, 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 achieve d 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, 2 006

. [hereinafter “2006 RACT SIP”]

EDAQMD's submittal included the following documents:

a. EDAQMD Board Letter, dated December 15, 2006- 5

- b. Resolution 016

- 2007, dated February 6, 2007

c. “ Reasonably Available Control Technology (RACT) State Implementation Plan (SI P) Update Analysis Staff Report, ” dated December 15, 2006
d. EPA Comments, d ated 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 CTG s for which the District did not have any sources.

EPA EVALUATION CRITERIA

– EPA evaluated t he following elements of EDAQMD ’s RACT SIP submittal as listed in our M arch 9, 2006 letter to CARB

.

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

• N egative declarations where there are no facilities subject to a CTG

• List of the S tate/local regulations that implement RACT

• T h e base s for concluding that all referenced regulations fulfill RACT

T he 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 g uidance 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 C lean 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) Quest ions 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 (An drew S teckel) 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_ac t/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- 6

- 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 co vered by a CTG document but are “major sources” (i.e., for EDAQMD, “non

- CTG sources” emitting at least 2 5 tons per year of
VOCs or NOx based on an ozone nonattainment classification of “severe” .) 2

El Dorado AQMD action: EDAQMD ’s staff report in dicates "Di strict 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 Ca lifornia 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 w ere compared against adopted District rules and determined whether the adopted rule s me e t or exceed the CTG.

The District's staff report indicate s it has a new non

- major source subject to the
Miscellaneous Metal Parts and Products CTG for which the re is n o District rule.

Also, a s a serious o zone nonattainment area, EDAQMD i s r equired to analyze RACT for all sources that emit or have the potential to emit at least 5 0 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:
T he 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 emissi ons threshold cutoff. However, r ecent 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.- 7

- CTG. Based on this, a new RACT rule is no t required, but EDAQMD should su bmit a negative declaration. Further discussion of this issue is provided in section 4.1 below.

We reviewed CARB's 200 7 emissions inventory t o identify major VOC and NOx emission

sources in EDAQMD. O ther than Sierra Pacific Industries , the re were no stati onary 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 Landfi ll 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 covere d 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 Emissi ons 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

- Cont rol 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 Coat ing 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- 8

- 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 Plan ts
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

- Co ntrol 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 Emiss ions 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 Cleane rs 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, Polypr opylene, and Polystyrene Resins

EPA

- 450/3

- 83

- 006

- Control of VOC Fugitive

Emi ssions from Synthetic Organic Chemical Polymer
and Resin Manufacturing Equipment

Rubber Tires EPA

- 450/2

- 78

- 030

- Control of Volatile Organic
Emissions from Manufacture of Pneum atic Rubber
Tires

EPA evaluation:
EPA 's review of EDAQMD 's emissions inventory did not identify sources that were covered by the above CTGs

.- 9

- Our review identified three potential source categories EDAQMD should consider for

n egative declarations

. Furthe r discussion is provided in Section 4.1 below.

CTG Source Category Negative Declaration

– CTG Reference Document

Metal Parts & Products EPA

- 45 0 / 2

- 78

- 015

– Control of VOC Emissions from Existing Stationary Sources, Volume VI: Surface Coating of Miscellane ous 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 Meta l Cleaning

3. List the S tate/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 A p pendix to the
2006 RACT SIP list s 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 b ecause t he District does not have sources exceeding the applicability t hreshold for the CTG s 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 re quired to demonstrate
RACT:

Rule 225 Organic Solvent Cleaning and Degreasing Operation ; Rule 231 Graphic Arts ; R ule 232 Biomass Boilers ; and
Rule 234 VOC RACT Rule

– Sierra Pacific Industrie s

.

4. The bas e s for concluding that all referenced regulatio ns fulfill RACT EDAQMD action: EDAQMD 's bas es for concluding its rules continue to satisfy RACT for the 8

- hour ozone
standard involved revie wing the SIP status of the rules; the adoption date and date of the
latest amendments ; and comparing the SIP approva l date w ith the adoption/amendment date to determine if any rules were subsequently amended after the y 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 st atement why EDAQMD believe s the rule s continue to satisfy

R ACT. 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,- 10

- 2006, EDAQMD responded to our comments and provided a short statement on why the
District believes the individual rules continue to meet RACT

.

EP A evaluation: Generally, EDAQMD concludes its rules continue to satisfy RACT for the 8

- hour standard based on the following criteria: 1) EPA SIP

- approv ed 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 CTG s 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 non

attainment areas.

Our evalua tion of EDAQMD's responses to our November 28, 2006 comment s is provided
below:

4.1 EPA ’s 11/2006 c omment: 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 ha s 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

– T he 1978 Metal Parts
and Products CTG applies to coating operations with a potential

- to

- emit of 10 t py of
VOC or actual emissions of 15 lbs/day 3

. D iscussion with District staff indicate s that
emissions from the ir metal coating facilities are below the CTG 's applicability
threshold. 4 In December 2012, EDAQMD a dopt ed a negative declaration f or th e 1978 miscellaneous metal parts and products CTG

. The negative declaration should be
submitted to EPA.

T o comply with the 2008 Miscellane ous Metal and Plastic Parts CTG, a RACT r ule must
be submitted i f actual emissions at these facilities ever equa l or exceed 2.7 tpy

.

4.2 EPA ’s 11/2006 c omment: 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 res ponse 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 cove red 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) Up date

– 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.- 11

- Table C of the District’s December 15, 2006 RACT SIP list ed Tanks as a negative
declaration.

4.3 EPA ’s 11/2006 c omment: 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 Indu stries, and were last amended in 2001 and 1995 respectively . EDAQMD indicate d a 1993 RACT determination performed for EPA Region IX by Radian Corporation 5 wa s still appropriate and that Rule 232 wa s identical
to Placer Rule 233 and meets RACT.

Source ceas ed operations

, no action required at this time

– EDAQMD's only major

source covered by Rule s 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 de termined to be a majo r 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 list ed in Enclosure (1) of our comment letter, a short comparison of EDAQMD
controls versus rules in two or three other ai r districts should be conducted. The analysis should clarify if there are any significant changes in technology that might
affect the Dis trict's RACT determination.

Incomplete but does not affect RACT

– recommendations for rule improvement EDAQMD’s response d id not contain further details o f how the District concluded the ir rules still represent current RACT, but primarily assert ed that t he rule s 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 r eview 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 par t of its RACT SIP demonstration . The SCAQMD analysis concluded 7 no 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 Compa ny 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

– C utback Asphalt, June 2008- 12

- – 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 v apor degreasers that are <100 tpy on a facility

- wide basis 8 in rural areas . EDAQMD's population is < 200,000 9 and therefore not subject to the 1977 CTG for Solvent Metal Cleaning (EPA

450/2

- 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
sh ould 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 operations 10

.

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

- emit 11

. CARB's 20 10 emissions inventory does not list any graphic arts facilities in EDAQMD and indicates the largest VOC source in the District i s a landfill emitting 4.2 tpy and the next largest VOC source is an asphalt plant emittin g 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:
Alth ough EDAQMD does not have graphic arts facilities exceed ing 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 w ith actual emissions e xceeding 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 Se e Sacramento Metropolitan AQMD Rule 466 ( http://airquality.org/rules/rule466.pdf ) and South Coast AQMD Rule 1171 ( http://aqmd.gov/rules/reg/reg 11/r1171.pdf ).

11 See http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf page 2

- 25

.- 13

- 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 sa me NOx limits.” As stated above, since the only major source of NOx in EDAQMD ha s 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 averagi ng time as a result of EPA ’s limited disapproval of an earlier version of
PCAPCD Rule 233 12

. 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 RA CT 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 t py 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 c omment: Rule 216, Organic Compounds ; a dopted 3 / 12 /198 4 ; is SIP approved under the Mountain Countie s Air Basin . The rule define s 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 state d 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 webpage 13 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 i s a deficiency pointed out in Issues

12 See 7 7 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.- 14

- 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 un clear how Rule 216 inter faces 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 Countie s Air Basin 14 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 c omment: Rule 244 , Organic Liquid Loading, was approved into the SIP on 7/8/2002, so it does not need to be r e

- submitted for SIP approval by EDAQMD.

– No action required by EDAQMD.

4.6 EPA ’s 11/2006 c omment: 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 th ere are no CTGs or major sources

, this
is not a RACT issue.

Recommendation:
EPA's more stringent national limi ts appl y to manufacturers of architectural coatings used or sold in the United States, w hereas EDAQMD's rule applies to the end user of
architectural coating s

. Since t he national rule allow s manufacturers to continue sell ing

non

- compliant c oatings if they qualify for certain provisions such as a tonnage exemption (40 CFR 59.404) or p ay an exceedance fee (40 CFR 59.403), it is possible
that non

- compliant coatings can still be available. W e therefore encourage EDAQMD to
amend Rule 215 and to consider incorpor at ing CARB’s 2007 architectural coatings suggested control measure as a means to c omply 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 c omment: California State Law SB 700 removed the permit exemption for agricultural internal combustion engines. EDAQMD Rule 233, Stationary Internal Combustion Engines, exempts agricult ural 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- 15

- – no ac tion 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 c omment: Future CTGs. EPA promulgated 11 new/amended CTGs in

2006

– 2008 . A separate analysis of whether EDAQMD has sour ces subject to these
CTGs w as required one year after promulgation. EDAQMD will need to review the applic ability 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 suc h as when EPA approves a rule only as a SIP strengthening action or when the rule amendments involve non

substantive changes. This could occur when a rule is strengthened to clarify definitions or update test methods but requirements affecting emissions a re not changed.

EDAQMD 's RACT SIP analysis lacks specific detail on how the District concluded its rules meet
current RACT. Generally the District states it s 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 200 7 emissions inventory only l ists 6 facilities in the District (not including gasoline stations, print sh ops, aut obody 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
thres hold and therefore not required to meet RACT (e.g., Coating of Miscellaneous Metal s 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 curr ent 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; s ubmitted July 11, 2007

.- 16

- 2. RACT SIPs, Let ter 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, Directo r, 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 M ay 25, 2006 from EPA Region IX (Andrew Steckel) to CARB (Kurt Karperos).

6

. EDAQMD R easonably 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; Nov ember 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 Requi rements.

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 f or 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).- 17

- 1 4. "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

- Cal ifornia 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/facinf o.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/si ps/index.html

.

19. Perfect Storm Shuts Camino Sawmill, 6

- 11

- 2009, KXTV/News10.

20. South Coast T echnical Assessment for Rule 1108

– Cutback Asphalt

- June 2008

.

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

.

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

.