EL DORADO COUNTY 

AIR QUALITY MANAGEMENT DISTRICT 

REASONABLY AVAILABLE CONTROL 

TECHNOLOGY(RACT)STATE 

IMPLEMENTATION PLAN (SIP) UPDATE 

ANALYSIS STAFF REPORT 

DECEMBER 15,2006 
This 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 

Letter to CARS, 4/4/06 
This 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 the jurisdiction of the El 

Dorado County Air 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 (L TAB). 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-hour ozone NAAQS. Therefore, 

the District is responsible for implementing emission standards and other requirements mandated 

by the Federal Clean Air Act. 

REASON FOR THIS ANALYSIS 

Sections 182(b)(2) and 182(f) of the Federal Clean Air Act 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 

sub mil 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 District 
2006 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 as a part of this 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 if they meet RACT standards 

Part 2 Identify all CTG categories for which there are no facilities in the District, and 

submit Negative Declarations stating that there are no such facilities. 

Part 3 List District rules and their SIP approval status for all applicable RACT categories. 

Part 4 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 later than the beginning of the first 

ozone season or portion thereof that occurs 30 months after the above submittal date. This would 

be March 15, 2009. Since El Dorado County has a full year ozone season, the required 

implementation date for the 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 subJect to the U.S. EPA CTG source cateaories within the District 

and determine if they 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 of this 

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 of whether the District has existing adopted rules that meet or exceed 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 of each 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 letter for 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 of January 1, 2009. 

Table D provides an overview of adopted District Rules and amendments, and Applicable SIP 

Approval dates. 

Major Sources: 

The following Table B lists the Major Source that is currently in the District. 

Table B - Major Sources- El Dorado Air Quality 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 Industries 
2006 RACT SIP Update Analysis 

December 15, 2006 

Page 8 

The Major Stationary Source, including Major non-CTG Sources have adopted District rules that 

satisfy RACT requirements. 

Part 2 • Negative Declaration (Negatiw Declaration! for use with 8-hour Ozone Reasonably 

Available Control TechnologY !RACD State Implementation Plan Certification 

Background 

Due to the designation of portions 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" 

of VOCs 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 if it has a source of emissions 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 consequently the 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 for which there are 

no sources above the CTG recommended threshold, even if such negative declarations were 

made for an earlier SIP. This is necessary since 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 Staff Recommendations 

The District Staff reviewed permit databases, SIC codes, other source data and the emission 

inventory for 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. Staff will 

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 Magnet Wire Coating voc 

5 Metal Coil, Container and Closure Coating voc 

6 Metal Furniture Coating voc 

7 Paper and 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 Rubber Tires voc 

Part 3 • SIP Status • Identify all District rules subject to the U.S. EPA CTG source cateaories within 

the District and determine if they meet 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 of the above rules, and the dates of the latest amendments, if 

any. Then the date of SIP 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 if the 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 exempt from 

CEQA as per Title 14, Calfornia Code of Regulations, Chapter 3, Article 19, Section 15308, 

Aclions by Reguiatorv Agencies for the Protection of the Environment. 
2006 RACT SIP Update Analysis 

December 15, 2006 

Page 10 

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

. .. ... - New SIP Pollutant CTG SIP Rule Rule Title 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- Summary and 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 Quality Act (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 history for 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 Letter to CARB, 4/4/06 
List ofCTGS and RACT Analysis 

Category EPA Documents 

General CTGs RACT analysis 

Coating & 

Solvents 

Surface Coaling No CTG or major source Not applicable 

Adhesives and No CTG or major source Not applicable 

Sealants 

Aerospace (P4) Control of VOC Emissions from Coating No sources which meet CTG applicability 

Operations at Aerospace Manufacturing and 

Rework Operations CTG & MACT (See 59 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 No CTG or major source Not applicable 

Coatings 

Automobile (#3) I. Control of Volatile Organic Emissions No sources which meet CTG applicability (objects surface 

Coating from Existing Stationary Sources- Volume II: coated in automotive and light duty truck assembly plants) 

Surface Coating of Cans, Coils, Paper, Fabrics, 

Automobiles, and Light-Duty Trucks (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 of Volatile Organic Emissions Rule 231 Graphic Arts Operations requires either lowfrom Existing Stationary Sources, Volume VIII: VOC inks or add-on controls with a control efficiency of 

Graphic Arts - Rotogravure and Flexography 95% and a collection efficiency of 70%. The CTG 

(EPA-450/2-78-033, 12/78, NTIS PB 292-490), presents either water-borne or high solids inks, or add-on 

CTG. controls. The rule meets RACT. 

http://www.epa.gov/ttn/chie£iold/ap42/ch04/s091 

/reference/ref 03c04s091 1995.pdf 

Large (#9) Control of Volatile Organic Emissions from No sources which meet CTG applicability 

Appliances Existing Stationary Sources, Volume V: Surface 

Coating of Large 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 

Magnet Wire (#8) Control of Volatile Organic Emissions from No sources which meet CTG applicability 

Existing Stationary Sources, Volume IV: Surface 

Coating of Insulation of Magnet Wire, (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 of Volatile Organic Emissions from No sources which meet CTG applicability 

Existing Stationary Sources, Volume III: Surface 

Coating of Metal 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 0 I c04s0224 1995.pdf. 

Metal Parts & (#14) Control of Volatile Organic Emissions Existing Sources meet CTG applicability-RACT rule to be 

Products from Existing Stationary Sources, Volume VI: promulgated. 

Surface Coating of Miscellaneous Metal Parts 

and Products (EPA-450/2-78-0 15, 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 No CTG or major source Not applicable 

Ships (P3) (AI6) I. ACT Document: Surface Coating No sources which meet CTG applicability 

Operations at Shipbuilding and Ship Repair 

Facilities (EPA-453/R-94-032, 4/94, NTIS PB94-181-864). The ACT was superseded by the 

Shipbuilding CTG which was issued in 1996 

htt11:/ lwww.e11a. govlttn/oamgit I /memoranda/shill 

-!.zip 

htt11:/ /www.epa.gov/ttn/o!!!]1g/t 1/memoranda/shi!l 

-2.zip 

(P3) 2. CTG, see 61 FR44050, 8/27/96. FR 

notice: 

htt!l:llwww.epa.gov/ttn/oamgit 1/memoranda/shi!l 

ctg.zip 

Solvent Cleaning (#4) I. Control of Volatile Organic Emissions Rule 225-0rganic Solvent Cleaning and Degreasing 

from Solvent Metal Cleaning, (EPA-450/2-77- requires covers, draining facilities and work practices that 

022, 11177, NTIS PB-274-557), CTG. minimize solvent evaporation or aD emission control 

http:llwww.epa.gov/ttn/chie£iold!ap42/ch04/s06/r system which has 85% control efficiency. The CTG 

eference/ref_ 02c04s06 _!995.pdf presents similar machine design specifications, alternative 

control devices and work practices. The rule meets 

RACT. 

Traffic Markings No CTG or major source Not applicable 

Wood Coating: (#IS) Control of Volatile Organic Emissions No sources which meet CTG applicability 

Factory Surface from Existing Stationary Sources, Volume VII: 

of Flat Wood Factory Surface of Flat Wood 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-
Wood Furniture (P2) Control ofVOC Emissions from Wood No sources which meet CTG applicability (potential 

Furniture Manufacturing Operations CTG- emissions of greater than 25 tons/year) 

MACT draft MACT our 5-94; Final CTG, EPA453/R-96-007, 4/96, NTIS PB-96-178-769), 

Also see 61 FR 25223 and 61 FR 50823, 

9/27/96. . 

CTG 

Petroleum 

Gasoline Plants (#10) Control of Volatile Organic Emissions Rule 244-0rganic Liquid Loading and Transport Vessels 

from Bulk Gasoline Plants (EPA-450/2-77-035, requires a CARB certified or District approved vapor 

12/77, NTIS PB-276-722), CTG. recovery/disposal system which has a recovery efficiency 

of99% or 0.08 lb of non-methane vapor emitted per 1000 

gallons transferred. The CTG presents submerged filling 

and vapor balance system. This rule meets RACT. 

Natural (#26) Control ofVOC Equipment Leaks from No sources which meet 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 ofRefmery Vacuum Producing No sources which meet CTG applicability 

Systems, Wastewater Separators, and Process 

Unit Turnarounds, (EPA-450/2-77-025, 10/77, 

NTIS PB-275-662), CTG. 

(#16) 2. Control ofVOC Leaks from Petroleum 

Refmery Equipment (EPA-450/2-78-036, 6/78, 

NTIS PB-286-158), CTG. . 

Service Stations (#1) I. Design Criteria for Stage I Vapor Control Rule 238-Gasoline Transferring and Dispensing requires a 

Systems- Gasoline Service Stations, (11/75), CARB certified vapor recovery system with a recovery 

CTG. efficiency of95% or 0.15lb gasoline vapor emitted per 

I 000 gallons. The CTG requires 90% control. This rule 

meetsRACT. 

Synthetic (#28) I. Control ofVOC Emissions from Air No sources which meet CTG applicability 

Organic Oxidation Processes in Synthetic Organic 

Chemical Chemical Manufacturing Industry (EPA-450/3-

84-015, 12/84, NTIS PB-85-164-275), CTG. 

(P1) 2. Control ofVOC Emissions from Reactor 

Processes and Distillation Operations in SOCMI 

(EPA-450/4-91-031, 11115/93, NTIS PB-92-

180-009), CTG. 

Tanks (#ll) I. Control of Volatile Organic Emissions No sources which meet CTG applicability (vessels larger 

from Storage of Petroleum Liquids in Fixed Roof than 150,000 liters) 

Tanks (EPA-450/2-77-036, 12/77, NTIS PB276-749), CTG. 

(#20) 2. Control of Volatile Organic Emissions 

from Petroleum Liquid Storage in External 

Floating RoofTanks (EPA-450-2/78-047, 12/78, 

NTIS PB-290-579), CTG. 

www.eQa.gov/clariton/clhtmVIJubtitle.html 

-3-
Tank Trucks (#6) I. Control of Hydrocarbons from Tank Rule 244-0rganic Liquid Loading and Transport Vessels 

Truck Gasoline Loading Terminals (EPA-450/2- requires a CARB certified or District approved vapor 

77-026, 12/77, NTIS PB-275-060), CTG .. recovery/disposal system which has a recovery efficiency 

(#22) 2. Control ofVOC Leaks from Gasoline of 99% or 0.08 lb of non-methane vapor emitted per I 000 

Tank Trucks and Vapor Collection Systems gallons transferred. The CTG presents submerged filling 

(EPA-450/2-78-051, 12/78, NTIS PB-290-568), and vapor balance system. This rule meets RACT. 

CTG. 

ACT 

Combustion 

Boilers, Steam Major source: Sierra Pacific Industries Rule 232-Biomass Boilers requires a NO, limit of 115 

Generators, ppmv corrected to 12% C02 or 50% reduction efficiency. (N3) I. ACT Document-- NOx Emissions from Process Heaters This limit is identical to PCAPCD Rule 233 for similar 

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 

Utility Boilers (EPA-453/R-94-023, 3/94). 

htt!1:i/www.el1a.gov/ttnlchief7old/a~2/ch0 I /sO I /r 

eference/ret27 cO I sO I 1998.!ldf 

(N7) 3. ACT Document-- 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 Boilers, Rule 234-VOC RACT Rule-Sierra Pacific Industries Steam 

requires a VOC limit of 150 ppmv for boilers exceeding Generators, 

the calendar year average of 50,000 lblhr steam. This was Process Heaters 

determined by the "RACT Determination for Michigan- (VOC) California Lumber Company Technical Support 

Documentation" prepared by Radian for EPA-Region IX 

in December 1993. The analysis is still appropriate. 

Cement Kilns No CTG or major source Not applicable 

Gas Turbines No CTG or major source Not applicable 

Glass Furnaces No CTG or major source Not applicable 

Internal No CTG or major source Not applicable 

Combustion 

Engines 

Iron and Steel No CTG or major source Not applicable 

Municipal Waste No CTG or major source Not applicable 

Combustion 

NOx Rules No CTG or major source Not applicable 

CTG 

Other 

-4-
Cutback Asphalt (#12) Control of VOC from Use of Cutback Rule 224-Cutback and Emulsified Asphalt Paving 

Asphalt (EPA-450/2-77-037, NTIS PB 278- Materials prohibits the use of rapid cure cutback asphalt, 

185), CTG. medium cure cutback asphalt, and low cure 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 or lower. Also 

prohibited is emulsified asphalt that contains more than 

3% organic compounds that evaporate at 500F or lower. 

The CTG as clarified by EPA's "Bluebook" limits solvent 

content to 7% for all applications or 3-12% depending on 

application. The rule meets RACT. 

Bakeries No CTG or major source 

Not applicable 

Dry Cleaning (#24) Control ofVOC Emissions from Large No sources which meet CTG applicability (facility which 

Petroleum Dry Cleaners, EPA-450/3-82-009 consumes 123,000 liters/year solvent or more) 

9/82, NTIS PB-83-124-875), CTG 

Fertilizer No CTG or major source Not applicable 

Ink and Paint No CTG or major source Not applicable 

Manufacture . 

Leather Tanning No CTG or major source Not applicable 

Nitric and No CTG or major source Not applicable 

Adipic Acid 

Pesticides No CTG or major source Not applicable 

Pharmaceutical (#17) Control of Volatile Organic Emissions No sources which meet CTG applicability 

Products from Manufacture of Synthesized 

Pharmaceutical Products (EPA-450/2-78-029, 

1278, NTIS PB-290-580), CTG. 

http://www.epa.gov/ttn/chie£'old/ap42/ch06/s I 0/r 

eference/ref Olc06sl0 1995.pdf 

Polyester Resin (#25) I. Control ofVOC Emissions from No sources which meet CTG applicability 

Manufacture of High-Density Polyethylene, 

Polypropylene, and Polystyrene Resins (EPA450/3-83-008, 11183, NTIS PB-84-134-600), 

CTG. 

httQ://www.!l!a.gov/clariton/clhtmVQubtitle.html 

(#27) 2. Control ofVOC Fugitive Emissions 

from Synthetic Organic Chemical Polymer and 

Resin Manufacturing Equipment (EPA-450/3-

83-006, 3/84,NTIS PB-84-189-372), CTG. 

httQ://www.eQa.gov/clariton/clhtmVQubtitle.html 

Rubber Tires (#18) Control of Volatile Organic Emissions No sources which meet CTG applicability 

from Manufacture of Pneumatic Rubber Tires 

(EPA-450/2-78-030, 12/78, NTIS PB-290-557), 

CTG. www.!l!a.gov/clariton/clhtmi!Qubtitle.html 

Sulfuric Acid No CTG or major source Not applicable 

Wastewater No CTG or major source Not applicable 

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