### EL DORADO 

## COUNTY I

—

Environmental Health Division

Air Quality Management District
Solid Waste &

Hazardous Materials Divisions
Vector Control

PLACERVILLE OFFICE 2850 FairlaneCt. Building C lacerville.CA95667
Ph. 530.621.5300 Fax. 530.642.1531 Fax. 530.626.7130

SOUTH LAKE TAHOE OFFICE 368 LakeTahoeBlvd. Ste 303 outhLakeTahoe. CA 96150
Th. 530.573.3450 ax. 530.542.3364 

# COUNTY OF EL DORADO ENVIRONMENTAL MANAGEMENT DEPARTMENT
December 15, 2006
Andrew Steckel Chief, Rulemaking Office United States Environmental Protection Agency Region IX 75 Hawthorne Street San Francisco, CA 94105 Subject: Responses to EPA letter ofNovember 28, 2006 concerning El Dorado County Air Quality ManagementDistrict (EDC AQMD) 2006 RACT SIPUpdate Analysis StaffReport DearMr. Steckel:
Thankyou foryour suggestions on the EDC AQMD 2006 RACT SIP Update Analysis StaffReport in your letter ofNovember 28, 2006. Responses to each ofyour comments follow the comment and updates have been made inthe StaffReport.
Rule Submittals and Comments 1. Page 7 ofthe staffreport states the District has new non-major emission sourëes under the CTG for Metal Parts and Products. hut has rio rule at this time. A RACT nile should be ioped and submitted for SIP approvai as soon as po;sible as EPA annot consider the RACT SIP analysis complete withoui the rt-qwred nile. Response: The RACT rule for Miscellaneous Metal Parts and Products will be promulgated as expeditiously aspossible.
2. EPA cross-matched District rules and the negative declarations in Table C ofthe staffreport against the list ofCTGs. The staffreport does not appear to address the following CTGs. A negative declaration should be submitted if the District has no sources in the following categories. However, ifthe District has sources in these categories, then the staffreport should be clarifiedto identify which Districtrules coverthe CTGs below.

a. Control of Volatile Organic Emissions from Bulk Gasoline Plants EPA-450/2-77-035, 12/77 (AppendixA page 6) b. Control ofVolatile Organic Emissions from Storage ofPetroleum Liquids in Fixed Roof Tanks (EPA-450/2-77-036, 12/77, (Appendix A page 7) c. Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating RoofTanks (EPA-450-2/78-047, 12/78, (Appendix A page 7) Response: These CTGs were originally included in the Natural Gas/Gasoline plant category. Howeverthey will be identjjIedseparately. Item a. is addressedbyRule 244-Organic LiquidLoading and Transport Vessels, andEl Dorado County does not have any sources that meet the applicability ofitems b. andc. 3. The staffreport asserts various District rules meet RACT. Particularly where the last RACT determination for specific source categories occurred many years ago, the report should reflect some analysis that RACT has not subsequently changed. For example, Rules 232 and 234 apply to the District’s only major source, Sierra Pacific Industries, and were last amended MANAGEMENT DEPARTMENT

www.co.el-doraclo.ca.us/emdin 2001 and 1995 respectively. The analysis should include additional discussion on how the District concluded these rules still represent current RACT. For example, is CARB’s 1994 analysis still appropriate for Rule 234: http://www.arb.ca.gov/pm/pmmeasures/ceffect/reports/pcapcd_229_report.pdf Response: The above report isfor a MDFfacilily in Placer County anddoes not address the type of equipment at Sierra Pacific Industries Caminoplant. The analysisperformedby RadianforEPAfor the Michigan-CalforniaLumber Company (SierraPacflc Industriespredecessor) in December 1993 is stillappropriate. Rule 232 is identicalto Placer CountyRule 233 andmeets RACT
At a minimum, we believe a short comparison ofEDAQMD controls versus rules in two or three other similar air districts is appropriate for each rule listed in Enclosure (1). The District should also certify it is not aware ofany significant changes in technology that affect the original RACT determination. Response: Thefollowingtable addresses each ofthe categories listedinEnclosure (1) of yourletter: DistrictRule/Title Date Rule SIP FR ECAQMD Analysis Staff Response Adopted! action ReportPage # Amended 

### Rule 224- 9/16/1991/ 8/21/1995 

### p11; Several Great Rule 224 meets RACT 

### Cutback and Lake States have from the 

### currentCTG. 

### 60 FR Emulsified 9/27/1994 43383 adopted summertime Asphalt Paving restrictions on cutback Material asphalt. SCAQMD

. 

### plans to investigate the feasibility ofthe Great Lake States’ rule. Rule 225- 9/27/1 994 8/21/1 995 p11; Sacramento Rule 225 

### meetsRACT 

### Organic Solvent 60 FR AQMD adopted more from 

### the current CTG 

### Cleaning and 43383 stringent controls in Degreasing 2002 Operations Rule 231- Rule 231 meets RACT 

### 9/27/1994 7/11/1997 p11; EDAQMD rule Graphic Arts applies to facilities from 

### the currentCTG. 62 FR 

### emitting 660 The applicability 37136 

### pounds/month. SM thresholdfrom the new 

### 431 applies to facilities CTG 

### willbe evaluated 

### emitting >60 

### in thefuture. 

### pounds/month. Although not applicable to the current analysis, EPA’s recently issued graphic arts CTG suggests an applicability threshold of>450 pounds/month. Rule 232- 10/18/1994 10/14/2003 p11; Compare against PCAPCDRu1e233 

### has 

### Biomass Boilers

,, 

### other District’s the sameNOx limits. 

### 68 FR biomass/solid fuel 9/25/2001 59121 boiler NOx limits.

### Rule 234-VOC 4/25/1995 9/12/1995 p11; Is 

### CARB’s 1994 The listedanalysis is 

### RACT Rule

— 

### analysis still for aPlacer 

### County 

### Sierra Pacific 60 FR appropriate for Rule MDF

### facility. The 

### Industries 47273 234?: analysisforSPIis http://www.arb.ca.gov/p “RACTDetermination m/pmmeasures/ceffect/re forMichigan ports/pcapcd_229_report. CaliforniaLumber Company Technical SupportDocumentation done byRadianfor EPA Region IXDecember 1993. This analysis is still appropriate. 

### Rule 237-Wood 6/27/1995 7/18/1996 p1 1 EDAQMD rule EDCAQMD

### has no 

### Products Coating 61 FR applies to facilities sources which meet

### the 

### Operations 37390 applying CTG 

### applicability 

### >2OgaIlons/mth. SM thresholdof25 

### 463 applies at >55 tons/yearofpotential 

### gallons/year VOC emissions.
4. Tables D-1 and D-2 list Rule 216, Organic Solvents, amended 1/24/1985 as not requiring a new SIP approval. Rule 216 is SIP approved under the Mountain Counties Air Basin. That version ofRule 216 is titled “Organic Compounds” as opposed to “Organic Solvents” and uses vapor pressure to help define a VOC. The use of vapor pressure to define a VOC conflicts with EPA’s definition of VOCs in 40 CFR 5 1.100(s). IfRule 216 is needed for RACT, it should be updated and adopted for El Dorado AQMD. Response: Rule 216-Organic Compounds is not neededfor RACT and will be deletedfrom the analysis.
5. Table D-3 identified that Rule 244, Organic Liquid Loading and Transport Vessels, was amended but had not been submitted for SIP approval. The September 25, 2001 version of Rule 244 was approved into the SIP on 7/8/2002 (67 FR 45066), 50 it does not need to be submitted again. Response: Thankyoufor updating the SIP approval date on Rule 244-Organic LiquidLoading and Transport Vessels. The RACTSIP StaffReporthas been modifiedaccordingly.
6. Although architectural coatings is not a CTG category, 40 CFR 59 Subpart D contains EPA’s national limits for the VOC content of architectural coatings. El Dorado’s limit for traffic coatings in Rule 215 is 250 g/1. This is less stringent,than the 150 

### gIl limit inthe national rule. Rule 215 should be amended. Response: The change in traffic coatings VOC limit will be addressed when Rule 215-Architectural Coatings is openedfor amendment. There are no CTGs ormajorsources so this is notaRACTissue.
7. California State Law SB 700 removed the permit exemption for agricultural internal combustion engines. El Dorado’s Rule 233, Stationary Internal Combustion Engines, amended June 6, 2006 exempts agricultural engines. Rule 233 should be amended to conform to SB 700.Response: The requirements of SB 700 will be addressed when Rule 233-Stationary Internal Combustion Engines is openedfor amendment. There are no CTGs or major sources which have stationary internalcombustion engines so this is not aRACTissue.
Future CTGs 8. To assist the District with their planning efforts, we note that on October 5, 2006, EPA finalized four new CTGs covering flexible packaging printing materials, lithographic printing materials, letterpress printing materials, industrial cleaning solvents and flat wood paneling coatings. While the current RACT SIP analysis does not need to address these new CTGs, the Notice points out that States (and local air districts) should submit their SIP revisions within one year of the date that the CTGs are finalized. The CTGs are available at: http://www.epa.gov/ttn/naags/ozone/ctgactlindex.htm

. Additional CTGs are expected to be issued in 2007 and 2008 (71 FR 28320 May 16, 2006). Further guidance will be provided once we receive it. Response: Thankyoufor the update on new CTGs. The RACT SIP analysis will be updated after furtherguidance.
Thank you for your assistance on the EDCAQMD RACT SIP. Ifyou have any questions regarding the 2006 RACT SIP analysis, please contact me at (530) 621-5306 or Carolyn Craig at (530) 621- 6649.

MarcellaMcTaggart AirPollution Control Officer El Dorado County Air QualityManagementDistrict Sincerely,