SACRAMENTO METROPOLITAN 

AIR QUALITY MANAGEMENT DISTRICT 

For Agenda of October 23, 2008

To: Board of Directors 

 Sacramento Metropolitan Air Quality Management District 

From: Larry Greene 

 Executive Director/Air Pollution Control Officer 

Subject: Public Hearing to Adopt a Resolution Approving a Revision to the Ozone State 

Implementation Plan for Reasonably Available Control Technology 

Recommendations 

1. Conduct a public hearing; 

2. Determine that the adoption of the revision to the Ozone State Implementation 

Plan is exempt from the California Environmental Quality Act (CEQA); and 

3. Adopt the attached resolution approving a revision to the Ozone State 

Implementation Plan for Reasonably Available Control Technology. 

Executive Summary 

The federal Clean Air Act requires air districts that are in nonattainment areas for the federal 

ozone standard to implement Reasonably Available Control Technology (RACT) for the emissions 

of ozone precursors – volatile organic compounds (VOC) and oxides of nitrogen (NOx). The 

RACT requirements apply to all source categories for which the U.S. Environmental Protection 

Agency (EPA) has published a Control Techniques Guideline (CTG) document as well as all 

major sources of VOC and NOx. The District must submit to EPA either: 1) District rules that 

meet the RACT requirements, or 2) a negative declaration stating that there are no sources in 

Sacramento County that are subject to the CTG. 

The District was designated by EPA as a serious nonattainment area for the 8-hour ozone 

standard. Federal regulations promulgated by EPA required the District to submit a revision to the 

State Implementation Plan (SIP) that meets the federal Clean Air Act RACT requirements as they 

apply to the 8-hour ozone standard. On October 26, 2006, the Board adopted a revision to the 

SIP that fulfilled the RACT requirements for CTG categories previously established by EPA and 

for major sources of VOC and NOx. Since that time, EPA has promulgated seven new CTGs. 

In addition, it is anticipated that EPA will reclassify the Sacramento Federal Nonattainment Area 

to “severe” nonattainment in response to a request submitted by the local air districts and the 

California Air Resources Board (CARB). 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. Consequently, just as 

the prior RACT analysis determined that sources with potential emissions of 50 tons or more per 

year meet the requirements, this analysis has focused on whether existing sources with 

potential emissions between 25 and 50 tons per year meet the RACT requirements. 

Staff performed an analysis of District rules that implement RACT for the new CTG categories and 

major sources of VOC and NOx. As a result of this analysis, Staff has determined amendments 
Board Memo 

Ozone SIP Revision for RACT 

October 23, 2008, Page 2 

to Rule 450, Graphic Arts Operations, and Rule 451, Surface Coating of Miscellaneous Metal 

Parts and Products, will be needed to meet the new CTG requirements. Staff has also 

determined, however, that the requirements of RACT are already being met for existing sources 

that will become major sources upon reclassification to severe nonattainment. 

Staff has prepared a revision to the Ozone SIP that includes: 1) negative declarations for four 

CTG source categories for which the District has no sources, 2) certification that the District has 

met the RACT requirements for existing sources of VOC and NOx that will become major 

sources upon reclassification to severe nonattainment, and 3) commitments to amend Rules 450 

and 451 to meet to the RACT guidelines established by the new CTGs. 

Attachments 

The table below identifies the attachments to this memo: 

Item Attachment Page # 

Board Resolution for Ozone SIP Revision A 6 

Proposed Ozone SIP Revision B 9 

Staff Report C 14 

Evidence of Public Notice D 50 

Background 

EPA defines RACT (44 FR 53762) as “the lowest emission limitation that a particular source is 

capable of meeting by the application of control technology that is reasonably available 

considering technological and economic feasibility.” Sections 182(b)(2) and 182(f) of the federal 

Clean Air Act require the District to implement RACT for: 

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

document issued by EPA; and 

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

On October 26, 2006, the Board adopted a revision to the SIP that fulfilled the RACT 

requirements for CTG categories previously established by EPA and for major sources of VOC 

and NOx. This SIP revision was submitted by CARB to EPA on July 11, 2007. Since the 

October 26, 2006 RACT SIP, 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 reclassification to “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. 
Board Memo 

Ozone SIP Revision for RACT 

October 23, 2008, Page 3 

RACT Analysis 

Staff’s analysis is presented in the Staff Report (Attachment C). The process Staff used to 

demonstrate compliance with federal RACT requirements consists of the following steps: 

• For new CTG source categories for which the District has no applicable rule, determine 

whether the District has sources in these categories. 

• For new CTG source categories for which the District has an applicable rule, perform a 

detailed comparison of the rule requirements with applicable CTG and other RACT 

guidance documents. 

• For sources that will become major sources upon reclassification to severe 

nonattainment, determine the types of emission units at each source and determine 

which District rules apply to these sources. The RACT requirement is satisfied for a 

major source of VOC or NOx when all units that emit these pollutants are subject to 

District rules that have been determined to satisfy RACT. 

Based on a review of District permitting records, yellow pages, business listings, and the 

District’s enforcement program for permitted and unpermitted sources, Staff has determined that 

the District has no sources in the following CTG categories: 

• Flat Wood Paneling Coatings 

• Paper, Film and Foil Coatings 

• Large Appliance Coatings 

Staff identified four source categories covered by the new CTGs for which the District has 

applicable sources: 

• Offset Lithographic and Letterpress Printing 

• Flexible Package Printing 

• Industrial Cleaning Solvents 

• Metal Furniture Coatings 

Staff finds that the requirements of RACT for these 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. Staff is proposing to correct this RACT deficiency by 

amending Rule 450 to require control equipment on these presses, consistent with the 

CTG recommendations. These rule amendments were proposed at a public hearing on 

September 25, 2008, which was continued until October 23, 2008, for reasons not 

related to these CTG requirements and RACT determinations. 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 
Board Memo 

Ozone SIP Revision for RACT 

October 23, 2008, Page 4 

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

lb/month). Staff is proposing 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 rule 

amendments were proposed at a public hearing on September 25, 2008, which was 

continued until October 23, 2008, for reasons not related to these CTG requirements 

and RACT determinations. 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. Staff is proposing 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 were adopted on 

September 25, 2008. The amended rule will be submitted for inclusion in the SIP. 

A bump-up to severe nonattainment will reduce the major source threshold to a potential-to-emit 

exceeding 25 tons per year of either VOC or NOx. Staff reviewed the permitting records of 

sources within the District to compile a list of five sources that will become major sources of 

VOC or NOx upon reclassification to severe nonattainment. Three of these sources were not 

included in the October 26, 2006 SIP revision, while the two other sources were included as 

major sources of NOx but not VOC. Staff has determined that the RACT requirements have 

been satisfied for the sources that will become major sources upon reclassification to severe 

nonattainment. 

Business Cost Impacts 

Staff has determined that current sources are either below the applicability thresholds of the 

new requirements or already comply with the new requirements. No costs to businesses will be 

incurred as a result of proposed SIP revision. 

District Impacts 

The proposed SIP revision will not result in an additional need for staff resources.

Emission Impacts 

The proposed SIP revision will not have any effect on emissions. 
Board Memo 

Ozone SIP Revision for RACT 

October 23, 2008, Page 5 

Environmental Review and Compliance 

No sources will be required to modify their operations as a result of the commitments proposed 

in this SIP revision. Staff has determined that current sources are either below the applicability 

thresholds of the new requirements or already comply with the new requirements. Therefore, 

Staff has determined that the adoption of these rule commitments is exempt from the California 

Environmental Quality Act (CEQA) under Section 15061(b)(3) of the State CEQA Guidelines 

because it can be seen with certainty that there is no possibility that the activity in question may 

have a significant adverse effect on the environment. 

Public Outreach 

A public notice for the Board hearing to consider the adoption of the proposed SIP revision was 

published in the Sacramento Bee on September 22, 2008. The Staff Report and proposed SIP 

revision were made available on that day. The public notice was also mailed to all major 

sources within the District, sources that will become major sources upon reclassification to 

severe nonattainment, and all parties who have requested public notices for District rulemaking 

activities. 

Conclusion 

The proposed SIP revision will satisfy the requirements of sections 182(b)(2) and 182(f) of the 

federal Clean Air Act. Therefore, staff recommends that the Board determine that the proposed 

SIP revision is exempt from CEQA and adopt the attached resolution approving the SIP 

revision. 

Respectfully Submitted 

______________________ 

Larry Greene 

Executive Director/Air Pollution Control 

Approved as to form: 

_______________________ 

Kathrine Pittard 

District Counsel 

Attachments