Ozone State Implementation Plan (SIP) Revision 

Reasonably Available Control Technology (RACT) Update as Applicable to the 

8-Hour Ozone Standard 

Sacramento Metropolitan Air Quality Management District 

October 23, 2008
SMAQMD Ozone SIP Revision 

RACT Update for the 8-Hour Ozone Standard 

October 23, 2008 

Page 2 

Background 

This document constitutes a revision to the Ozone State Implementation Plan (SIP) for the 

Sacramento Air Quality Management District (SMAQMD). The U.S. Environmental Protection 

Agency (EPA) published the final Phase 2 Rule to implement the 8-hour ozone air quality 

standard on November 29, 2005 (70 FR 71611). Among the requirements of the Phase 2 Rule, 

a new section was added to the Code of Federal Regulations (40 CFR 51.912) that requires the 

SMAQMD to submit a revision to the SIP that meets the Reasonably Available Control 

Technology (RACT) requirements for VOC and NOx in accordance with Sections 182(b)(2) and 

182(f) of the federal Clean Air Act for: 

• Each category of VOC sources that is covered by a Control Technique Guideline (CTG) 

document issued by EPA; and 

• All major stationary sources of VOC and/or NOx. 

EPA’s designations and classifications for the 8-hour ozone standard were published on April 

30, 2004 (69 FR 23857) and became effective on June 15, 2004. The Sacramento Metropolitan 

Area was classified as a serious nonattainment area, with a deadline of 2013 to attain the 

standard. The major source emissions threshold for areas classified as serious is 50 tons per 

year of either VOC or NOx. 

On October 26, 2006, the District’s Board of Directors adopted a revision to the SIP that fulfilled 

the aforementioned federal requirements, and this SIP revision was submitted by the California 

Air Resources Board (CARB) to EPA on July 11, 2007. 

Since that time, EPA has promulgated seven new CTGs. In addition, the air districts of the 

Sacramento Federal Nonattainment Area submitted a letter to CARB in February of 2008 to 

request a voluntary “bump-up” to a classification of “severe” nonattainment, as provided by 

Section 181(b)(3) of the federal Clean Air Act. On February 14, 2008, CARB requested that 

EPA reclassify this area to “severe.” It is anticipated the EPA will take action on this request by 

the end of 2008. A reclassification to severe nonattainment will reduce the major source 

emissions threshold from 50 to 25 tons per year of either VOC or NOx, imposing RACT 

requirements on additional sources within the District. 

This SIP revision is based on an analysis performed by SMAQMD staff of the new CTG 

categories, and of sources which will become major sources upon reclassification to severe 

nonattainment. The analysis is presented in the Staff Report for Updated Analysis of 

Reasonably Available Control Technology for the 8-Hour Ozone State Implementation Plan 

(Updated RACT SIP), SMAQMD, September 22, 2008. 

Negative Declarations 

The SMAQMD has reviewed its records for permitted sources, the enforcement program for 

unpermitted sources, telephone yellow pages, and business listings and has determined that 

there are no stationary sources or emitting facilities for the following CTG categories. In 

addition, the SMAQMD does not anticipate these sources in the future. 
SMAQMD Ozone SIP Revision 

RACT Update for the 8-Hour Ozone Standard 

October 23, 2008 

Page 3 

Source Category for 

Negative Declaration CTG Document Title Document Number 

Flat Wood Paneling 

Coatings 

Control Techniques Guidelines for Flat Wood 

Paneling Coatings 

EPA 453/R-06-004 

Paper, Film, and Foil 

Coatings 

Control Techniques Guidelines for Paper, Film, and 

Foil Coatings 

EPA 453/R-07-003 

Large Appliance 

Coatings 

Control Techniques Guidelines for Large Appliance 

Coatings 

EPA 453/R-07-004 

RACT Determination for CTG Categories 

The SMAQMD has performed an analysis of District rules that are applicable to the 2006/2007 

CTG categories for which there are existing sources, as shown in the following table. 

Source 

Category CTG Document Title 

CTG Document 

Number 

SMAQMD 

Rule No. 

(Most Recent 

Amendment) SIP Status 

Offset 

Lithographic and 

Letterpress 

Printing 

Control Techniques 

Guidelines for Offset 

Lithographic and 

Letterpress Printing 

EPA 453/R-06-002 450 (3/23/00) Adopted 12/5/96; 

Approved 11/13/98 

Flexible 

Package 

Printing 

Control Techniques 

Guidelines for 

Flexible Package 

Printing 

EPA 453/R-06-003 450 (3/23/00) Adopted 12/5/96; 

Approved 11/13/98 

Industrial 

Cleaning 

Solvents 

Control Techniques 

Guidelines: Industrial 

Cleaning Solvents 

EPA 453/R-06-001 466 (5/23/02) Not yet submitted 

Metal Furniture 

Coatings 

Control Techniques 

Guidelines for Metal 

Furniture Coatings 

EPA 453/R-07-005 451 (10/2/97) Adopted 11/29/83; 

Approved 1/24/85 

Adopted 9/5/96; No 

EPA Action 

The District finds that the requirements of RACT for the 2006/2007 CTG categories are satisfied 

by the District rules, with the following exceptions: 

• For flexible package printing, Rule 450 does not meet the CTG requirements for 

mandatory control equipment on printing presses with potential to emit, prior to controls, 

of at least 25 tons/year of VOC. The District is committing to correct this RACT 

deficiency by amending Rule 450 to require control equipment on these presses, 

consistent with the CTG recommendations. These amendments are scheduled for a 

public hearing on September 25, 2008. Following adoption, the amended rule will be 

submitted for inclusion in the SIP. 

• For offset lithographic and letterpress printing, Rule 450 does not meet the CTG 

requirements for mandatory control equipment on printing presses with potential to emit, 

prior to controls, of at least 25 tons/year of VOC. In addition, the CTG recommends 

more stringent VOC content limits for fountain solutions used by offset lithographic 
SMAQMD Ozone SIP Revision 

RACT Update for the 8-Hour Ozone Standard 

October 23, 2008 

Page 4 

printing sources with actual emissions of VOC of at least 15 lb/day (equivalent to 450 

lb/month). The District is committing to correct these RACT deficiencies by amending 

Rule 450 to require mandatory control equipment on presses with potential to emit, prior 

to controls, of at least 25 tons/year of VOC and to set more stringent VOC limits, 

consistent with the CTG recommendations, for fountain solutions used by offset 

lithographic printing sources with actual emissions of VOC of at least 450 lb/month. 

These amendments are scheduled for a public hearing on September 25, 2008. 

Following adoption, the amended rule will be submitted for inclusion in the SIP. 

• For metal furniture coating operations, the VOC content limits recommended in the CTG 

for general one-component, extreme high gloss, and extreme performance coatings are 

more stringent than those required by Rule 451. In addition, Rule 451 allows the use of 

an emission control system with an overall efficiency of 85%, whereas the CTG 

recommends 90% overall efficiency. The District is committing to correct these RACT 

deficiencies by amending Rule 451 to include the CTG-recommended VOC content 

limits for metal furniture coatings, applicable to sources with actual VOC emissions of at 

least 3 tons per 12-month rolling period, and to increase the overall efficiency required 

for emissions control equipment to 90%. These amendments are scheduled for a public 

hearing on September 25, 2008. Following adoption, the amended rule will be submitted 

for inclusion in the SIP. 

RACT Determination for Sources of VOC or NOx that will become Major Sources 

The SMAQMD has performed an analysis of sources within the District that will become major 

source of VOC or NOx upon reclassification to severe nonattainment, and has determined that 

the requirements of RACT have been satisfied for these sources. The sources that will become 

major sources are shown in the following table. 

New Major Source Major Pollutant(s) 

Cosumnes Power Plant (SMUD) VOC, NOx* 

Grafil NOx 

Sacramento Power Authority NOx 

Silgan Can Company VOC 

UC Davis Medical Center VOC, NOx* 

* These sources were included in the October 26, 2006 SIP revision as major sources of NOx. A 

bump-up to severe nonattainment will make them major sources of VOC, also.