## EL DORADO COUNTY AIR QUALITY MANAGEMENT DISTRICT



# REASONABLYAVAILABLE CONTROL TECHNOLOGY(RACT)STATE IMPLEMENTATION PLAN (SIP) UPDATE ANALYSIS STAFF REPORT

DECEMBER 15,2006This Page Intentionally Left Blank

### TABLE OF CONTENTS
TITLE PAGE

INTRODUCTION 

### 5

REASON FOR THIS ANALYSIS 

## 5

ACTION REQUESTED BY U.S. EPA 

### 5

ANALYSIS

DISTRICT PLANNING HISTORY 

### 6

PART 1- RACT STANDARDS 

### 6

PART 

## 2- NEGATIVE DECLARATIONS 

### 8

PART 

### 3- SIP APPROVAL STATUS 

### 9

PART 

### 4 - SUMMARY AND CONCLUSIONS 

### 10

APPENDIX: 

### Table A - Rule Categories 

## As Listed in U.S. 

### EPA 11 Letterto CARS, 4/4/06This Page Intentionally Left Blank

### 2006 RACT SIP Update Analysis December 15,2006 

### Page 5

INTRODUCTION 

### El Dorado County is located in northern California, bordering Sacramento County to the west and the State of Nevada on the east. Air quality attainment planning is under thejurisdiction ofthe El Dorado CountyAir Quality Management District (District). Elevations range from 1,000 feet in the western portion of the County to over 9,000 feet in the mountains of the Sierras. El Dorado County is divided into two different air basins: the Mountain Counties Air Basin (MCAB); and the Lake Tahoe Air Basin (LTAB). Each air basin has its own meteorological and geographic conditions. Generally, the Mediterranean climate in the adjacent Sacramento Valley Air Basin (SVAB) and the lower elevations of the MCAB have summers that are hot and dry with temperatures usually in the 90s, which are conducive to ozone formation. Prevailing winds from the west transport ozone from the San Franciso Bay Area and the Sacramento Valley into the foothill and mountain areas. The portions of El Dorado County in the MCAB are included in the Sacramento Federal Ozone Non-Attainment Area (SFNA), which has been designated as "serious" non-attainment for the 8- hour ozone National Ambient Air Quality Standard (NAAQS). Before the U.S. Environmental Protection Agency (U.S. EPA) posted new 8-hour ozone designations and non-attainment classifications in June 2004, the SFNA was a "severe" non-attainment area for the 1-hour ozone NAAQS. Although the U.S. EPA revoked the 1-hour ozone NAAQS, the SFNA still remains subject to control measure commitments that applied under the 1-hourozone NAAQS. Therefore, the District is responsible for implementing emission standards and other requirements mandated bythe Federal Clean AirAct.

REASON FORTHIS ANALYSIS 

### Sections 182(b)(2) and 182(f) ofthe Federal Clean AirAct require ozone non-attainment areas to implement Reasonably Available Control Technology (RACT) for sources that are subject to Control Techniques Guideline (CTG) documents issued by U.S. EPA and for "Major Sources" of Volatile Organic Compounds (VOCs) and Oxides of Nitrogen (NOx), which are ozone precursors. RACT requirements are included in the Clean Air Actio assure that significant source categories at Major Sources are controlled to a "reasonable" extent, but not necessarily to Best Available Control Technology (BACT) or Maximum Achievable Control Technology" (MACT) levels which are expected of new sources. U.S. EPA defines RACT as the lowest emission limitation that a particular source is capable of meeting by the application of technology (i.e., devices, systems, process modification, or other apparatus or techniques that reduce air pollution) that is reasonably available considering technological and economic feasibility. According to the U.S. EPA's 

### Final Rule to Implement the 8-Hour Ozone NAAQS (70 FR 71612, November 29, 2005) areas classified as moderate non-attainment or higher must submil a demonstration that their current rules fulfill 8-hour ozone RACT for all CTG categories and all Major, non-CTG Sources as a revision to their State Implementation Plan (SIP). States can demonstrate that RACT is being met with either a new RACT determination or a certification that previously required RACT controls represent RACT for 8-hour ozone. Areas may rely on previous analyses written for 1-hour ozone plans and U.S. EPA guidance documents. The RACT SIP submittal is in addition to the area's 8-hour Ozone Attainment Demonstration Plan, which will also be a SIP submittal. ACTION REQUESTED BY U.S. EPA 

### On March 9, 2006 and April 4, 2006, Andrew Steckel, U.S. EPA Office Rulemaking Chief, sent request letters to the California Air Resources Board (GARB). The letters concern District2006 RACT SIP Update Analysis December 15, 2006 Page6
requirements and outlined a possible RACT SIP submittal strategy to determine whether RACT requirements have been met. District activities performed asa part ofthis analysis are as follows: Part 1 Identify all District rules subject to the U.S. EPA Control Techniques Guidelines (CTG) source categories within the District and determine ifthey meet RACT standards Part

### 2 Identify all CTG categories for which there are no facilities in the District, and submit Negative Declarations stating thatthere are no such facilities. Part

### 3 List District rules and their SIP approval status for all applicable RACT categories. Part4 Summarize the above processes that the District used to: (1) determine that the District regulations fulfill RACT, (2) determine Negative Declarations needed for certain CTG categories, and (3) determine which District rules need to be submitted to U.S. EPA as revision to the SIP. The District was requested to prepare a complete RACT SIP update analysis, covering Major Sources, non-Major CTG Sources, and non-CTG Major Sources. In addition, the District is required to implement an 8-hour Ozone Demonstration Plan no laterthan the beginning ofthe first ozone season or portion thereof that occurs 30 months afterthe above submittal date. This would be March 15, 2009. Since El Dorado County has a full year ozone season, the required implementation dateforthe District will be Januarv 1, 2009. Note that the implementation date for any source operating under a Title V permit, pursuant to 40 CFR Part 70, would 

### be governed by the requirements of that permit. This staff report relates to the RACT SIP update analysis submittal. ANALYSIS
District Planning History To improve the air quality in El Dorado County and move the region towards attainment of the NAAQS, the District has prepared and adopted several air quality attainment plans since 1991. The District has also adopted over 100 new rules and amendments to meet the commitments in these attainment plans. The air quality in El Dorado County has improved over the past several years as the District has adopted air quality plans and regulations. In a continuation of the District's strategy for achieving the NAAQS, the District is working with other air districts in SFNA to submit an 8-hour ozone attainment demonstration plan to U.S. EPA by June 15, 2007, as specified by federal requirements.
Part 

### 1 - Identify all District rules subJectto the U.S. EPA CTG source cateaories within the District and determine ifthey meet RACT standards. This District analysis compared the current ProhiMory Rules (Regulation 2 in the District Rule Book) to current U.S. EPA guidance standards for emission control measure. The purpose ofthis work was to: (1) determine if the District had an adopted rule for the source category, (2) determine if the rule's control measures satisfied the requirements of the U.S. EPA's control measure standard, and (3) determine if a new rule will need to be adopted for existing emission sources. The standards compared were Control Techniques Guidelines (CTG) and Alternate Control Techniques (ACT) Guidance. The ultimate purpose of this study is the determination by the District ofwhetherthe District has existing adopted rules that meet orexceed the standards in the current CTGs and ACTs. To determine if District rules fulfill RACT requirements, Staff used the following guidelines:

### 2006 RACT SIP 

### Update Analysis December 15, 2006 Page 7

• District rules that have been SIP-approved by U.S. EPA are considered to meet RACT requirements because U.S. EPA evaluated the rules to determine if they fulfill RACT established by CTGs, (ACTs) and U.S. EPA guidelines and policies. Therefore, any EPA SIP-approved District rules are said to have met RACT requirements.

• As a non-attainment area for the California ozone standard, the District is required by California Health and Safety Code (CH&SC) Sections 40914(a)(2) and 40920.6(a) to implement "All Feasible Control Measures· (AFCM) and "Best Available Retrofit Control Technology" (BARCT). In general, AFCM and BARCT requirements are more stringent than those previously established by CTGs and ACTs. Therefore, District rules that implemented AFCM and BARCT are said to fulfill RACT requirements.

• All CTG emission source categories were compared against existing adopted District rules and a finding was made regarding whether the adopted rule met or exceeded the applicable CTG RACT requirements. All ACTs were evaluated to determine whether Major Sources exist in the source category and if so, whether or not a District rule satisfying ACT guidelines has been adopted. Table A, provided as an Appendix to this report lists all U.S. EPA source categories requested, both Major and non-Major, and the corresponding CTGs and ACTs, with details ofeach category. All the adopted rules have been found to satisfactorily meet RACT requirements. Table B contains the major source in the District and that the source meets RACT for all emission units. Table C shows that there are rule categories listed in the April 4, 2006 U.S. EPA letterfor which no sources currently exist in the District. The absence of sources of these categories was determined by Staff, based on a study of the District permit base, public notices, and personal knowledge (See Part 2, below which discusses Negative Declarations) Staff also noted that the District has new non-Major Sources in one CTG category (Metal Parts and Products) that has no rule at this time. The District RACT SIP submittal process will include the requirement that the appropriate rule be written, adopted and approved subsequent to this RACT SIP study, but no later than the El Dorado County RACT implementation date ofJanuary 1, 2009. Table D provides an overview of adopted District Rules and amendments, and Applicable SIP Approval dates. MajorSources: The following Table B lists the Major Source that is currently in the District.
Table B - MajorSources- El DoradoAirQuality**Mana~ement** 

### District Source Source Category Pollutant Rule No. Rule Title Location I 

### Comments Sierra Boilers, Steam Pacific Generators and NOx 232 

### Biomass Boilers Camino Industries (Title Vl Process Heaters Sierra Boilers, Steam VOC RACT Rule- Pacific Generators and 

### voc 234 

### Sierra Pacific Camino Industries (Title V) Process Heaters Industries2006 RACT SIP UpdateAnalysis December 15, 2006 Page 8



### The Major StationarySource, including Major non-CTG Sources have adopted District rules that satisfy RACT requirements.

Part2 • Negative Declaration (Negatiw Declaration!for use with 8-hourOzone Reasonably Available Control TechnologY !RACD State Implementation Plan Certification Background 

### Due to the designation ofportions of El Dorado County as 'moderate" or above non-attainment for ozone, Sections 182(b)(2) and 182(f) of the Federal CAA require the District to submit a revision to the State Implementation Plan (SIP) to implement RACT for each category of Volatile Organic Compound (VOC) or Nitrogen Oxide (NOx) sources covered by a CTG document and for any Major Stationary Source not covered by a CTG document. The Mountain Counties Air Basin portions of the District are part of the Sacramento Federal Ozone Non-Attainment Area (SFNA) which is designated as 'serious" non-attainment for ozone. RACT requires that ail non-attainment areas classified as "moderate" or above have RACT in place for source categories covered by a Control Techniques Guideline (CTG) document and for Major Sources that are not subject to a CTG (i.e. a "Major non-CTG Source"). A "Major Source" ofVOCs or NOx in El Dorado County is defined as an emission source having a potential to emit of 25 tons of the pollutant per year. The District must adopt the control measures for a source category ifit has a source ofemissions located within the non-attainment area that is subject to a CTG. Alternatively, 

### if the finding is made that there are no existing sources that emit 'the designated pollutants in its area subject to a RACT requirement, the District may make a negative declaration to this effect and consequentlythe requirement to adopt a rule for those sources is not applicable. This process is called "Negative Declaration"

. The District is required to submit Negative Declarations for ail CTG categories forwhich there are no sources above the CTG recommended threshold, even 

### if such negative declarations were madefor an earlier SIP. This is necessarysince there may be sources in the non-attainment area that previously did not exist. Also, 

### if the boundaries of the non-attainment area have expanded, there may be sources in the new portion of the non-attainment area which should not be overlooked. The District must also submit a Negative Declaration to certify that there are no Major non-CTG Sources in the non-attainment area. The Negative Declaration must go through the same public review requirements as any other SIP submittal. Negative Declaration Findings and 

### StaffRecommendations 

### The District Staff reviewed permit databases, SIC codes, other source data and the emission inventoryfor its Federal Clean Air Plan, and has determined that there are no sources for the CTG categories listed below in Table C. Staff has determined that there are no existing sources of emissions in these eighteen (18) CTG categories and the Negative Declarations should be submitted to U.S. EPA for approval. Staffwill submit these eighteen (18) Negative Declarations for public comment, and District Board consideration and approval. If approved by the District Board the Negative Declarations will be submitted to CARB for forwarding to U.S. EPA as requested revisions to the State Implementation Plan.2006 RACT SIP Update Analysis December 15, 2006 Page9

Table C District Negative Declaration Submittal Requlnoments**~** 

### I
RuleTHie Pollutant
1 Aerospace Coating VOC 2 Automotive Coating (Assembly Plant) 

# voc 3 Large Appliance Coating 

# voc 4 MagnetWire Coating 

# voc 5 Metal Coil, Containerand Closure Coating 

# voc 6 Metal Furniture Coating 

# voc 7 Paperand Fabric Coating 

# voc 8 Ship Coating 

# voc 9 Wood Coating (Flat Wood Paneling) 

# voc 10 Wood Furniture 

# voc 11 Natural Gas/Gasoline Plants 

# voc 12 Refineries 

# voc 13 Synthetic Organic Chemical Manufacturing 

# voc 14 Tanks 

# voc 15 Petroleum Dry Cleaning 

# voc 16 Pharmaceutical Products 

# voc 17 Polyester Resin Manufacturing 

# voc 18 RubberTires 

# voc

Part

### 3 • SIP Status • Identify all District rules subjectto the U.S. EPA CTG source cateaories within the District and determine

### iftheymeet RACT standards. The current status of each of the District prohibitory rules that previously were adopted for CTG/ACT source categories was reviewed and is displayed in the following table. This SIP status study was necessary in order to determine which rules, if any, needed to be submitted or resubmitted for SIP approval by U.S. EPA. Staff examined the adoption dates ofthe above rules, and the dates of the latest amendments, if any. Then the date ofSIP approval was compared with the rule adoption histories. 

### Table D • District Rule History(VOC and NOx) and SIP Approval Status: Table D lists the adoption history of seven (7) District rules for CTG categories and ACT categories at major sources, and their SIP approval status. They are listed by rule number. The right hand column indicates ifthe District must re-submit any existing rule that was amended after the latest date of SIP approval, in order to ensure that the review will be based upon the most current amendment of that rule. Staff recommends that these SIP submittals be found exempt from the California Environmental Quality Act (CEQA). The proposed submittals are exemptfrom CEQA as per Title 14, Calfornia Code of Regulations, Chapter 3, Article 19, Section 15308, Aclions by ReguiatorvAgencies for the Protection ofthe Environment.

### 2006 RACT SIP Update Analysis 

### December 15, 2006 Page 10

Table D - District Rule History (VOC and NOx) and SIP Approval Status

. .. ... - 

### NewSIP Pollutant CTG SIP Rule RuleTitle Control- Source Date Date Last Approval- Approval No. led 

### ? Adopted Amended FR Citation Required Cutback and B/21/95

- 60 224 Emulsified**Aspha~** 

# voc Yes 9/16/91 6/6/94 Pavina Materials FR 43383 Organic Solvent 225 Cleaning and VOC Yes 9/27/94 Not 8/21/95 -60 Degreasing Amended FR 43383 Operations 231 Graphic Arts 

# voc Yes 9/27/94 Not 7/11/97 62 FR Operations Amended 37136 232 Biomass Boilers NOx No 10/18194 9/25/01 10/14/03 -68 FR 59121 VOC RACT Rule- Not 9/12/95 -60 234 Sierra Pacific 

# voc No 4/25/95 Amended FR 47273 Industries 238 Gasoline Transfer VOC Yes 3/27/01 Not B/27/01 -66 and Dispensing Amended FR44974 Organic Liquid 7/8/02

- 67 FR 244 Loading and VOC Yes 3/27/01 9/25/01 45066 Transport Vessels
Part

### 4- Summaryand Conclusions New RACT Rules to Be Adopted

- Details of 

### the process Staff used to evaluate the Applicable SIP status of the District's rules that satisfy Major Source RACT requirements are described in Part 1, above. The Staff comparison of all current District rules to the standards of applicable CTG's and ACT's found that the District has adopted nules corresponding to RACT source categories and that satisfy RACT requirements. One CTG category, Metal Parts and Products, have non-Major emission source(s), but no District Rule has been adopted. Staff recommends that the Board direct the development and adoption of the rule to limit VOC emissions from the coating of metal parts and products. Although there are no Major Sources in this source category, there are non-Major Sources of VOC that would be subject to the new nule establishing RACT requirements. The rules should be implemented by January 1, 2009, and should be adopted as a revision to the SIP and submitted to U.S. EPA. Negative Declarations

- (Part 2) Based on Staff review 

### of District sources, the Negative Declaration of no existing Major Stationary VOC Sources may be made for eighteen (18) additional VOC RACT source categories. In addition, the Staff analysis found that there were no Major Stationary Sources, including Major non-CTG Sources, for which District nules satisfying RACT had not been adopted. Staff recommends that the District Board make the declaration that no existing Stationary Sources· exist for VOC in El Dorado County in the eighteen (18) specified CTG source categories and that no Major non-CTG Sources exist for which RACT measures have not been adopted

.. Staff further recommends that these SIP submittals be found exempt from the California Environmental QualityAct (CEQA) per Title 14, California Code of Regulations, Chapter 3, Article 19, Section 15308, Actions by Regulatory Agencies for the Protection of the Environment. SIP Status

- (Part 3) Rule adoption, amendment, and SIP approval historyfor District prohibitory rules was reviewed and analyzed. The seven (7) rules are already SIP-approved nules. 

### ? N

N

N
N
N
N

N

## APPENDIX
Table A· Rule Categories as Listed in U.S. EPA Letterto CARB, 4/4/06

### List ofCTGS and RACT Analysis
Category EPADocuments
General 

### CTGs RACT analysis Coating & 

### Solvents Surface Coaling No CTGormajor source Notapplicable Adhesives and No CTGormajor source Notapplicable Sealants Aerospace (P4) Control ofVOC Emissions from Coating No sources whichmeet CTG applicability Operations at AerospaceManufacturing and Rework Operations CTG & MACT (See59 FR 29216, 6/6/1994); CTG (Final), EPA-453/R-97- 004, 12/97). ht!J1://www.el!a.gov/ttn/oamgitl/memorandaictg. 

## !!!If Architectural NoCTG ormajorsource Notapplicable Coatings Automobile (#3) I. Control ofVolatile OrganicEmissions No sources which meet CTG applicability(objects surface Coating from Existing StationarySources- Volume II: coatedin automotive and lightdutytruckassemblyplants) Surface Coating ofCans, Coils, Paper,Fabrics, Automobiles, and Light-DutyTrucks (EPA450/2-77-008,5/77,NTIS PB-272-445), CTG. http://www.epa.gov/ttn/chie£iold/ap42/ch04/s022 7/reference/ref 02c04s0227 Janl995.pdf Graphic Arts (#19) I. Control ofVolatile Organic Emissions Rule 231 Graphic Arts Operationsrequires eitherlowfrom Existing Stationary Sources, Volume VIII: VOC inks oradd-on controls witha control efficiencyof Graphic Arts

- Rotogravure andFlexography 95% and a collectionefficiencyof70%. TheCTG (EPA-450/2-78-033, 12/78, NTISPB 292-490), presents eitherwater-borne orhigh solidsinks, oradd-on CTG. controls. Therulemeets RACT. http://www.epa.gov/ttn/chie£iold/ap42/ch04/s091 /reference/ref 03c04s091 1995.pdf Large (#9) Control ofVolatile Organic Emissions from No sourceswhichmeet CTGapplicability Appliances Existing StationarySources, Volume V: Surface Coating ofLarge Appliances, EPA-450/2-77- 034, NTIS PB-278-259), CTG. http://www.epa.gov/ttn/chie£iold/ap42/ch04/s022 4/reference/ref 02c04s0224 1995.pdf MagnetWire (#8) Control ofVolatile Organic Emissions from No sourceswhich meet CTG applicability Existing Stationary Sources, Volume IV: Surface Coating ofInsulation ofMagnetWire, (EPA450/2-77-033, 12177, NTIS PB-278-258), CTG. http://www.epa.gov/ttn/chie£iold/ap42/ch04/s022 3/reference/ref Olc04s0223 1995.pdf



### -I-Metal Coil, See automobile coating. No sources which meet CTG applicability Container, & Closure Metal Furniture (#7) Control ofVolatile Organic Emissions from No sources whichmeet CTG applicability Existing Stationary Sources, Volume III: Surface Coating ofMetal Furniture (EPA-450/2-77-032, 12177, NTIS PB-278-257), CTG hnp://www.epa.gov/ttn/chie£iold!ap42/ch04/s022 4/reference/ref 0Ic04s0224 1995.pdf. Metal Parts & (#14) Control ofVolatile Organic Emissions Existing Sources meetCTG applicability-RACTrule to be Products from Existing Stationary Sources, Volume VI: promulgated. Surface Coating ofMiscellaneous Metal Parts andProducts (EPA-450/2-78-015, 6/78, NTIS PB-286-157), CTG. http://www.epa.gov/ttn!chie£iold!ap42/ch04/s022 4/reference/ref 03c04s0224 1995.pdf Paper& Fabric See automobile coating. No sources which meet CTG applicability Plastic Parts NoCTG ormajorsource Notapplicable Ships (P3) (AI6) I.ACT Document: Surface Coating No sources whichmeet CTGapplicability Operations at Shipbuilding and Ship Repair Facilities (EPA-453/R-94-032, 4/94,NTIS PB94-181-864). TheACT was supersededbythe Shipbuilding CTG whichwas issued in 1996 htt11:/lwww.e11a.govlttn/oamgitI/memoranda/shill -!.zip htt11:/ /www.epa.gov/ttn/o!!!]1g/t1/memoranda/shi!l -2.zip (P3) 2. CTG, see 61 FR44050, 8/27/96. FR notice: htt!l:llwww.epa.gov/ttn/oamgit1/memoranda/shi!l ctg.zip SolventCleaning (#4) I. Control ofVolatile OrganicEmissions Rule 225-0rganic SolventCleaning andDegreasing from SolventMetal Cleaning, (EPA-450/2-77- requirescovers, draining facilities and workpracticesthat 022, 11177, NTIS PB-274-557), CTG. minimize solvent evaporation or

## aD emissioncontrol http:llwww.epa.gov/ttn/chie£iold!ap42/ch04/s06/r systemwhich has 85%control efficiency. TheCTG eference/ref_02c04s06 _!995.pdf presents similar machinedesign specifications, alternative control devices and workpractices. Therulemeets RACT. Traffic Markings No CTGormajorsource Not applicable Wood Coating: (#IS) Control ofVolatile Organic Emissions No sources whichmeet CTG applicability FactorySurface from Existing Stationary Sources, Volume VII: ofFlat Wood Factory Surface ofFlatWood Paneling (EPAPaneling 450/2-78-032,6178, NTIS PB 286-199), CTG. http://www.epa.gov/ttn!chie£iold!ap42/ch04/s022 5/referencelref Olc04s0225 1995.pdf



### -2-WoodFurniture (P2) Control ofVOC Emissions from Wood No sources which meet CTG applicability(potential Furniture Manufacturing Operations CTG- emissions ofgreater than 25 tons/year) MACTdraftMACT our5-94; Final CTG, EPA453/R-96-007,4/96, NTIS PB-96-178-769), Also see 61 FR25223 and 61 FR 50823, 9/27/96.

. CTG Petroleum GasolinePlants (#10) Control ofVolatile Organic Emissions Rule 244-0rganicLiquid Loading and Transport Vessels from BulkGasoline Plants (EPA-450/2-77-035, requires a CARB certifiedorDistrictapproved vapor 12/77, NTIS PB-276-722), CTG. recovery/disposal system whichhas a recoveryefficiency of99%or0.08 lb ofnon-methane vaporemittedper 1000 gallons transferred. TheCTGpresents submerged filling and vaporbalance system. 

### This rule meets RACT. Natural (#26) Control ofVOCEquipmentLeaks from No sources whichmeet CTG applicability Gas/Gasoline Natural Gas/Gasoline Processing Plants (EPA450/2-83-007, 12/83,NTIS PB-84-161-520), CTG. 

### Refmeries (#5) I. Control ofRefmeryVacuum Producing No sources whichmeetCTG applicability Systems, Wastewater Separators, and Process Unit Turnarounds, (EPA-450/2-77-025, 10/77, NTIS PB-275-662), CTG. (#16) 2. Control ofVOCLeaks from Petroleum RefmeryEquipment(EPA-450/2-78-036, 6/78, NTIS PB-286-158),CTG.

. Service Stations (#1) I.Design Criteriafor Stage I VaporControl Rule 238-Gasoline Transferring and Dispensingrequires a Systems- Gasoline Service Stations, (11/75), CARB certified vaporrecovery systemwith a recovery CTG. efficiencyof95%or0.15lbgasoline vaporemittedper I000 gallons. TheCTG requires 90%control. Thisrule meetsRACT. Synthetic (#28) I.Control ofVOCEmissions from Air No sources whichmeet CTG applicability Organic OxidationProcesses in Synthetic Organic Chemical Chemical Manufacturing Industry(EPA-450/3- 84-015, 12/84, NTIS PB-85-164-275), CTG. (P1) 2. Control ofVOCEmissions from Reactor Processes and DistillationOperationsin SOCMI (EPA-450/4-91-031, 11115/93, NTIS PB-92- 180-009), CTG. Tanks (#ll) I.Control ofVolatile Organic Emissions No sourceswhich meet CTG applicability(vessels larger from Storage ofPetroleum Liquids in Fixed Roof than 150,000 liters) Tanks (EPA-450/2-77-036, 12/77,NTIS PB276-749), CTG. (#20) 2. Control ofVolatile Organic Emissions from Petroleum Liquid Storage in External FloatingRoofTanks (EPA-450-2/78-047, 12/78, NTIS PB-290-579), CTG. www.eQa.gov/clariton/clhtmVIJubtitle.html



### -3-TankTrucks (#6) I. Control ofHydrocarbons from Tank Rule 244-0rganic Liquid Loading and Transport Vessels TruckGasolineLoading Terminals (EPA-450/2- requires a CARB certified orDistrict approved vapor 77-026, 12/77, NTIS PB-275-060), CTG

.. recovery/disposal systemwhichhas a recovery efficiency (#22) 2. Control ofVOCLeaks from Gasoline of99%or0.08 lb ofnon-methane vaporemittedper I000 TankTrucks and VaporCollection Systems gallons transferred. TheCTG presents submerged filling (EPA-450/2-78-051, 12/78, NTIS PB-290-568), and vaporbalance system. This rulemeets RACT. CTG. ACT Combustion Boilers, Steam Major source: SierraPacific Industries Rule 232-Biomass Boilersrequires a NO, limit of 115 ppmvcorrectedto 12% C02 or50% reduction efficiency. Generators, (N3) I. ACTDocument-- NOx Emissions from This limit is identical to PCAPCD Rule 233 for similar Process Heaters Process Heaters (Revised) (EPA-453/R-93-034, type specialized industrial boilers. This rule meets RACT. (NOx) 9/93). htt11://www.e11a.gov/nn!catc/dirl/11rocheat.ru!f (NS) 2. ACT Document-- NOx Emissions from UtilityBoilers (EPA-453/R-94-023, 3/94).**htt!1:i/www.el1a.gov/ttnlchief7old/a~2/ch0**I/sOI/r eference/ret27 cOIsOI 1998.!ldf (N7) 3. ACTDocument-- NOx Emissions from Industriai/Commercialllnstitutional (ICI) Boilers (EPA-453/R-94-022, 3/94). htto://www.eoagov/ttnlcatc/dirl/icboiler.odf Major source: Sierra Pacific Industries Rule 234-VOC RACT Rule-Sierra Pacific Industries Boilers, Steam requires a VOC limit of150 ppmv for boilers exceeding Generators, the calendaryearaverage of50,000 lblhrsteam. This

### was Process Heaters determinedbythe "RACTDeterminationfor Michigan- (VOC) California LumberCompanyTechnical Support Documentation"preparedbyRadian for EPA-Region IX in December 1993. Theanalysis is still appropriate. CementKilns No CTG ormajorsource Not applicable GasTurbines No CTG ormajor source Notapplicable Glass Furnaces No CTG ormajorsource Not applicable Internal No CTGormajor source Not applicable Combustion Engines Iron and Steel No CTG ormajor source Not applicable Municipal Waste No CTG ormajorsource Notapplicable Combustion NOx Rules No CTG ormajor source Notapplicable CTG Other



### -4-CutbackAsphalt (#12) Control ofVOC from Use ofCutback Rule 224-Cutback and Emulsified Asphalt Paving Asphalt (EPA-450/2-77-037, NTIS PB 278- Materials prohibits the use ofrapid cure cutbackasphalt, 185), CTG. mediumcure cutback asphalt, and lowcure cutback http://www.epa.gov/ttn/chie£'old/ap42/ch04/s05/r asphalt which contains more

### than 0.5%organic eference/ref_03c04s05_1995.pdf compounds which evaporate at 500F orlower. Also prohibited is emulsified asphalt that contains more than 3%organic compounds that evaporate at 500F orlower. The CTG as clarifiedbyEPA's"Bluebook" limits solvent contentto 7% for all applications or3-12%depending on application. Therule meets RACT. Bakeries No CTG ormajor source Not applicable DryCleaning (#24) Control ofVOCEmissions from Large No sources whichmeetCTGapplicability(facilitywhich Petroleum DryCleaners, EPA-450/3-82-009 consumes 123,000liters/yearsolvent ormore) 9/82, NTIS PB-83-124-875), CTG Fertilizer No CTG ormajorsource Not applicable Ink and Paint No CTG ormajor source Not applicable Manufacture 

### . LeatherTanning No CTGormajor source Notapplicable Nitric and NoCTGormajor source Notapplicable Adipic Acid Pesticides No CTGormajor source Notapplicable Pharmaceutical (#17) Control ofVolatile Organic Emissions No sources whichmeet CTG applicability Products from Manufacture ofSynthesized PharmaceuticalProducts (EPA-450/2-78-029, 1278,NTIS PB-290-580), CTG. http://www.epa.gov/ttn/chie£'old/ap42/ch06/sI0/r eference/ref Olc06sl0 1995.pdf PolyesterResin (#25) I. Control ofVOCEmissions from No sources whichmeet CTG applicability Manufacture ofHigh-DensityPolyethylene, Polypropylene, and PolystyreneResins (EPA450/3-83-008, 11183, NTIS PB-84-134-600), CTG. httQ://www.!l!a.gov/clariton/clhtmVQubtitle.html (#27) 2. Control ofVOCFugitive Emissions from Synthetic Organic Chemical Polymerand ResinManufacturing Equipment (EPA-450/3- 83-006, 3/84,NTIS PB-84-189-372), CTG. httQ://www.eQa.gov/clariton/clhtmVQubtitle.html RubberTires (#18) Control ofVolatileOrganic Emissions No sources whichmeet CTG applicability from Manufacture ofPneumatic RubberTires (EPA-450/2-78-030, 12/78, NTIS PB-290-557), CTG. www.!l!a.gov/clariton/clhtmi!Qubtitle.html Sulfuric Acid No CTG ormajor source Notapplicable Wastewater No CTG ormajor source Not applicable



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