UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

PLACER COUNTY AIR POLLUTION CONTROL DISTRICT

Rule 229, Fiberboard Manufacturing

Rule 230, Plastic Products and Materials – Paper Treating Operations

Prepared by: Arnold Lazarus

Reviewed by: Andy Steckel

April 2014
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RULE IDENTIFICATION 

Agency: Placer County Air Pollution Control District (PCAPCD)

SIP Approved Rule: Rule 229 - Fiberboard Manufacturing

Adopted - June 28, 1994

Submitted - July 13, 1994

EPA Approved - June 8, 2001 (66 FR 30815)

Rule 230 - Plastic Products and Materials - Paper Treating 

Operations

Adopted - June 28, 1994

Submitted - July 13, 1994

EPA Approved - December 14, 1994 (59 FR 64336)

Subject of this TSD: Rule 229 - Fiberboard Manufacturing

Rescinded - April 12, 2012

Submitted - February 12, 2014

Rule 230 - Plastic Products and Materials - Paper Treating

Operation

Rescinded - April 12, 2012

Submitted - February 12, 2014

BACKGROUND 

Rule 229: Fiberboard Manufacturing

Placer County Air Pollution Control District (PCAPCD or “District”) adopted Rule 229

to satisfy a Federal Clean Air Act (CAA) section 182 requirement that Districts adopt 

regulations for major sources of volatile organic compounds (VOC) using Reasonably 

Available Control Technology (RACT). At the time of adoption, there was only one 

source in the District subject to Rule 229, SierraPine, that manufactured medium density 

fiberboard. The purpose of the rule was to control VOC emissions from the plant and set 

minimum VOC control efficiencies for various operations used in fiberboard manufacture.

Rule 230: Plastic Products and Materials – Paper Treating Operations

PCAPCD similarly adopted Rule 230 to satisfy CAA RACT requirements. At the time of 

adoption, there was only one source in the District subject to Rule 230, Formica, a paper 

treatment operation. The rule applies to paper treating operations involving the application 

of melamine and phenol resins to paper substrates which have a potential to emit 25 tons 

or more of VOC per year. The purpose of the rule was to limit emissions through use of 

low-VOC compounds, or through the use of control equipment to destroy VOC before 

being emitted to the atmosphere.
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PURPOSE OF RULE RESCISSION – PCAPCD rescinded Rule 229 and Rule 230 

because the two major sources, SierraPine Fiberboard and Formica respectively, shut 

down their operations subject to these rules in the following manner as stated in the 

PCAPCD Staff Report, April 12, 2012.

1. SierraPine has shut down the fiberboard manufacturing equipment, surrendered the 

fiberboard manufacturing permits and is selling off the emission reduction credits. 

They do not expect to operate again at this location. There are no current sources 

subject to Rule 229 in Placer County.

2. Formica shut down all operations at the facility in June 2006 and obtained 

Emission Reduction Credits for the shutdown emissions.

EPA EVALUATION – EPA staff have reviewed the District’s staff report associated 

with these rescissions and, on March 31, 2014, discussed the rescissions with PCAPCD 

management. EPA concurs with the District’s determination that: (a) currently there are 

no major sources in Placer County that emit VOCs as Rules 229 and 230 regulate; and (b)

a new facility would have to obtain a new permit that would have more stringent

requirements and that the District would need to write new rules conforming to the current 

RACT and other CAA requirements.1 As a result, we concur with the District that there is 

no further need for these rules at this time. 

EPA ACTION – EPA staff recommends that the rescission of Rules 229 and 230 be 

approved.

REFERENCES

1. PCAPCD Rule 229, Fiberboard Manufacturing, adopted June 28, 1994, 

submitted on July13, 1994.

2. PCAPCD Rule 230, Plastic Products and Materials - Paper Treating Operations,

adopted June 28, 1994, submitted on July13, 1994.

3. PCAPCD Staff Report, April 12, 2012

 

1 Telephone Conference Call, Arnold Lazarus and Nancy Levin, EPA Region 9, and Todd Nishikawa, 

PCAPCD, March 31, 2014.