EL DORADO

COUNTY

I —

Environmental

Health Division

Air Quality

Management

District

Solid Waste &

Hazardous

Materials

Divisions

Vector Control

PLACERVILLE

OFFICE

2850 Fairlane Ct.

Building C

lacerville. CA 95667

Ph. 530.621.5300

Fax. 530.642.1531

Fax. 530.626.7130

SOUTH LAKE

TAHOE OFFICE

368 Lake Tahoe Blvd.

Ste 303

outh Lake Tahoe. 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 of November 28, 2006 concerning El Dorado County Air Quality

Management District (EDC AQMD) 2006 RACT SIP Update Analysis Staff Report

Dear Mr. Steckel:

Thank you for your suggestions on the EDC AQMD 2006 RACT SIP Update Analysis Staff Report in

your letter of November 28, 2006. Responses to each of your comments follow the comment and

updates have been made in the Staff Report.

Rule Submittals and Comments

1. Page 7 of the staff report 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 as possible.

2. EPA cross-matched District rules and the negative declarations in Table C of the staff report

against the list of CTGs. The staff report 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, if the District has sources in these categories, then the staff report

should be clarified to identify which District rules cover the CTGs below.

a. Control of Volatile Organic Emissions from Bulk Gasoline Plants EPA-450/2-77-035,

12/77 (Appendix A page 6)

b. Control of Volatile Organic Emissions from Storage of Petroleum 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 Roof Tanks (EPA-450-2/78-047, 12/78, (Appendix A page 7)

Response: These CTGs were originally included in the Natural Gas/Gasoline plant category.

However they will be identjjIed separately. Item a. is addressed by Rule 244-Organic Liquid Loading

and Transport Vessels, and El Dorado County does not have any sources that meet the applicability

ofitems b. and c.

3. The staff report 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/emd
in 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 is for a MDFfacilily in Placer County and does not address the type of

equipment at Sierra Pacific Industries Camino plant. The analysis performed by Radianfor EPA for

the Michigan-Calfornia Lumber Company (Sierra Pacflc Industries predecessor) in December 1993

is still appropriate. Rule 232 is identical to Placer County Rule 233 and meets RACT

At a minimum, we believe a short comparison of EDAQMD 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 of any significant changes in technology that affect

the original RACT determination.

Response: The following table addresses each ofthe categories listed in Enclosure (1) ofyour letter:

District Rule/Title Date Rule SIP FR ECAQMD Analysis Staff Response

Adopted! action Report Page #

Amended

Rule 224- 9/16/1991/ 8/21/1995 p11; Several Great Rule 224 meets RACT

Cutback and Lake States have from the current CTG. 60 FR Emulsified 9/27/1994 43383 adopted summertime

Asphalt Paving restrictions on cutback

Material asphalt. SCAQMD

. plans to investigate the

feasibility of the Great

Lake States’ rule.

Rule 225- 9/27/1 994 8/21/1 995 p11; Sacramento Rule 225 meets RACT

Organic Solvent 60 FR AQMD adopted more from the current CTG

Cleaning and 43383 stringent controls in

Degreasing 2002

Operations

Rule 231- 9/27/1994 Rule 231 meets RACT 7/11/1997 p11; EDAQMD rule Graphic Arts applies to facilities from the current CTG.

62 FR emitting 660 The applicability

37136 pounds/month. SM thresholdfrom the new

431 applies to facilities CTG will be evaluated

emitting >60 in the future.

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 same NOx 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 listed analysis is

RACT Rule — analysis still for a Placer County

Sierra Pacific 60 FR appropriate for Rule MDFfacility. The

Industries 47273 234?: analysisfor SPI is

http://www.arb.ca.gov/p “RACT Determination

m/pmmeasures/ceffect/re for Michigan

ports/pcapcd_229_report. California Lumber

Company Technical

Support Documentation

done by Radian for

EPA Region IXDecember 1993. This

analysis is still

appropriate.

Rule 237-Wood 6/27/1995 7/18/1996 p1 1 EDAQMD rule EDCA QMD has no

Products Coating 61 FR applies to facilities sources which meet the

Operations 37390 applying CTG applicability

>2OgaIlons/mth. SM threshold of25

463 applies at >55 tons/year ofpotential

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 of Rule 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). If Rule 216 is needed for

RACT, it should be updated and adopted for El Dorado AQMD.

Response: Rule 216-Organic Compounds is not needed for RACT and will be deleted from 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: Thank you for updating the SIP approval date on Rule 244-Organic Liquid Loading and

Transport Vessels. The RACTSIP StaffReport has been modified accordingly.

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 in the 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 or major sources so this is not a RACT issue.

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

stationary internal combustion engines so this is not a RACT issue.

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: Thank you for the update on new CTGs. The RACT SIP analysis will be updated after

further guidance.

Thank you for your assistance on the EDCAQMD RACT SIP. If you have any questions regarding

the 2006 RACT SIP analysis, please contact me at (530) 621-5306 or Carolyn Craig at (530) 621-

6649.

Marcella McTaggart

Air Pollution Control Officer

El Dorado County Air Quality Management District

Sincerely,