UNITEDSTATES ENVIRONMENTAL PROTECTIONAGENCY REGION IX 75 Hawthorne Street San Francisco,CA 94105

November 28,2006

Ms. Marcella McTaggart Air Pollution Control Officer El Dorado County Air Quality Management District 2850 Fairlane Court., Building 'C' Placerville, CA 95667-4100
Re: 2006 RACT SIP Update Analysis StaffReport, dated November 17,2006
Dear Ms. McTaggart:
We greatly appreciate EDAQMD's effortsto develop a RACT SIP submittal to meet the requirements in Clean Air Act Section 182. We have summarized some suggestions below for further improvement. Because RACT SIPSare a new requirement with limited national policy or precedent, we are not yet certain which ofthese commentsreflect approvability issues.
Rule Submittalsand Comments 1. Page 7 ofthe staffreport statesthe District has new non-major emission sources under the CTG for Metal Parts and Products, but has no rule at this time. A RACT rule should be developed and submitted for SIP approval as soon aspossible asEPA cannot consider the RACT SIP analysis completewithout the required rule.
2. EPA cross matched District rules and the negative declarations in Table C ofthe staff report against the list of CTGs. The staffreport does not appear to address the following CTGs. A negative declaration should be submitted ifthe District has no sources in the following categories. However, ifthe District has sources in these categories, then the staffreport should be clarified to identify which District rules cover the CTGs below.

a. Control ofVolatile Organic Emissions from Bulk Gasoline Plants EPA-45012-77-035, 12177(AppendixA page 6) b. Control ofVolatile Organic Emissions from Storage ofPetroleum Liquids in Fixed Roof Tanks (EPA-45012-77-036, 12177,(AppendixApage 7) c. Control ofVolatile Organic Emissions from Petroleum Liquid Storage in External Floating RoofTanks (EPA-450-2178-047, 12178, (Appendix A page 7)
3. The staffreport asserts various District rules meet RACT. Particularly where the last RACT determination for specific source categories occurred many years ago, the report should reflect some analysis that RACT has not subsequently changed. For example,

### Rules 232 and 234 apply to the District's only major source, Sierra Pacific Industries, and were last amended in 2001 and 1995respectively. The analysis should include additional discussion on howthe District concluded these rules stillrepresent current RACT. For example, is CARB's 1994analysis still appropriate for Rule 234: http://www.arb.ca.gov/pm/pmmeasures/ceffect/reports/pcapcd 

### 229 report.pdf
At a minimum, we believe a shortcomparison of EDAQMD controls versus rules intwo or three other similar air districts is appropriate for eachrule listed in Enclosure (1). The District should also certify it is not awareof any significant changes in technology that affect the original RACT determination.
4. TablesD-1 and D-2 list Rule 216, Organic Solvents, amended 1/24/1985 asnot requiring a new SIP approval. Rule 216 is SIP approved under the Mountain Counties Air Basin. That version ofRule 2 16istitled "Organic Compounds" as opposed to "Organic Solvents" and uses vapor pressure to help define a VOC. The use of vapor pressure to define a VOC conflicts with EPA's definition ofVOCs in 40 CFR 51.100(s). IfRule 216 is needed for RACT, it shouldbe updated and adopted for El Dorado AQMD.
5. Table D-3 identified that Rule 244, Organic Liquid Loading and Transport Vessels, was amended but had not been submitted for SIP approval. The September 25,2001 version ofRule 244 was approved into the SIP on 7/8/2002 (67 FR 45066), so it does not need to be submitted again.
6. Although architectural coatings is not a CTG category, 40 CFR 59 SubpartD contains EPA's national limits for the VOC content of architectural coatings. El Dorado's limit for traffic coatings in Rule 215 is 250 g/l. This is less stringent than the 150g/l limit in the national rule. Rule 215should be amended.
7. California State Law SB 700 removed the permit exemption for agricultural internal combustion engines. El Dorado's Rule 233, Stationary Internal Combustion Engines, amended June 6,2006 exemps agricultural engines. Rule 233 should be amended to conform to SB 700.
Future CTGs 8. To assist the District with their planning efforts, we note that on October 5, 2006, EPA finalized four new CTGs covering flexible packaging printing materials, lithographic printing materials, letterpress printing materials, industrial cleaning solventsand flat wood paneling coatings. While the current RACT SIP analysis does not need to address these new CTGs, theNotice points out that States (and local air districts) should submit their SIP revisions within one year ofthe date that the CTGs are finalized. The CTGs are available at: http://www.epa.gov/ttnlnaaqs/ozone/ctg 

### act/index.htm



### . Additional CTGs are expectedto be issued in 2007 and 2008 (71 FR 28320 May 16,2006). Further guidance will be provided once we receive it.Please keep in mind that RACT SIP rules were required to be submitted to EPA by September 15,2006,so any required submittals should be submitted as expeditiously aspossible. Final implementation dates should be no later than the first ozone season that occurs 30 months later. For El Dorado, we believe that isJanuary 1,2009.
Ifyou have any questionsregarding these comments, please feel free to contact me or Stanley Tong at (415)947-4122. Sincerely,

~ndrew Steckel, Chief, Rulemaking Office
Enclosures cc: Carolyn Craig (El Dorado AQMD) Ravi Rarnalingam (CARB)

### Table 1

## - Rules needing further clarification that they still represent RACT if neededfor RACT

District Rulerritle Date Adopted Last Amended Rule SIP FR action EDAQMDAnalysis Page #

Rule 224 Cutback and EmulsifiedAsphalt Paving Material 911611991 8/21/1995 60 FR 43383 912711994 p11; Several Great Lake States have adopted summertime restrictions on cutback asphalt. SCAQMD plansto investigatethe feasibility of the Great Lake States' rule. 

### --- Rule 225 Organic Solvent Cleaning and Degreasing Operations 912711994 8/21/1995 60 FR 43383 plI; Sacramento AQMD adopted more stringent controls in 2002

Rule 231 Graphic Arts plI; EDAQMD rule appliesto facilities emittirlg 1660 poundslmonth. SM 431 appliesto facilities emitting >60 poundslmonth. Although not applicable to the current analysis, EPA's recently issued graphic arts CTG suggests an applicability threshold of >450 poundslmonth. Rule 232 Biomass Boilers 1011811994 9/25/2001 1011412003 68 FR plI;Compare against other District's biomasslsolid fuel boiler 59121 NOx limits. Rule 234 VOC RACT Rule

### - Sierra Pacific Industries 911211995 60 FR 47273 

### p 1 1 ; 

### Is CARB's 

### 1994analysis still appropriate for Rule 

### 234: http:llwww.arb.ca.gov/pmlpmmeasu reslceffect/reportslpcapcd 229 rep ort.pdf Rule 237 Wood Products Coating Operations 711811996 61 FR 37390 p11 EDAQMD rule applies to facilities applying >20gallons/mth. SM 463 applies at >55 gallonslyear

Enclosure (1)