UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


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 95667-4 100 

Re: 	 2006 RACT SIP Update Analysis Staff Report, dated November 17,2006 

Dear Ms. McTaggart: 

We greatly appreciate EDAQMD's efforts to 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 SIPS are a new requirement with limited national policy or 

precedent, we are not yet certain which of these comments reflect approvability issues. 

Rule Submittals and Comments 

1. 	 Page 7 of the staff report states the 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 as possible as EPA cannot consider 

the RACT SIP analysis complete without the required rule. 

2. 	 EPA cross matched District rules and the negative declarations in Table C of the staff 

report against the list of CTGs. The staff report does not appear to address the following 

CTGs. A negative declaration should be submitted if the District has no sources in the 

following categories. However, if the District has sources in these categories, then the 

staff report should be clarified to identify which District rules cover the CTGs below. 

a. 	 Control of Volatile Organic Emissions from Bulk Gasoline Plants EPA-45012-77-035, 

12177 (Appendix A page 6) 

b. 	 Control of Volatile Organic Emissions from Storage of Petroleum Liquids in Fixed 

Roof Tanks (EPA-45012-77-036, 12177, (Appendix A page 7) 

c. 	 Control of Volatile Organic Emissions from Petroleum Liquid Storage in External 

Floating Roof Tanks (EPA-450-2178-047, 12178, (Appendix A page 7) 

3. 	 The staff report 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 1995 respectively. The analysis should include additional 

discussion on how the District concluded these rules still represent current RACT. For 

example, is CARB's 1994 analysis still appropriate for Rule 234: 

http://www.arb.ca.gov/pm/pmmeasures/ceffect/reports/pcapcd 229 report.pdf 

At a minimum, we believe a short comparison of EDAQMD controls versus rules in two 

or three other similar air districts is appropriate for each rule listed in Enclosure (1). The 

District should also certify it is not aware of any significant changes in technology that 

affect the original RACT determination. 

4. 	 Tables D-1 and D-2 list Rule 216, Organic Solvents, amended 1/24/1985 as not requiring 

a new SIP approval. Rule 21 6 is SIP approved under the Mountain Counties Air Basin. 

That version of Rule 2 16 is titled "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 of VOCs in 40 CFR 51.100(s). If Rule 216 

is needed for RACT, it should be 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 

of Rule 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 Subpart D contains 

EPA's national limits for the VOC content of architectural coatings. El Dorado's limit 

for traffic coatings in Rule 21 5 is 250 g/l. This is less stringent than the 150 g/l limit in 

the national rule. Rule 2 15 should 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 solvents and flat 

wood paneling coatings. While the current RACT SIP analysis does not need to address 

these new CTGs, the Notice points out that States (and local air districts) should submit 

their SIP revisions within one year of the date that the CTGs are finalized. The CTGs are 

available at: http://www.epa.gov/ttnlnaaqs/ozone/ctg act/index.htm . Additional CTGs 

are expected to 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 as possible. 

Final implementation dates should be no later than the first ozone season that occurs 30 months 

later. For El Dorado, we believe that is January 1, 2009. 

If you have any questions regarding these comments, please feel free to contact me or 

Stanley Tong at (4 15) 947-4 122. 

Sincerely, 

~ndrewSteckel, 

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 needed for RACT 

District Rulerritle Date 

Adopted 

Last 

Amended 

Rule SIP 

FR action 

EDAQMD Analysis Page # 

Rule 224 Cutback and 

Emulsified Asphalt 

Paving Material 

911 611 991 8/21/1995 

60 FR 

43383 

912711 994 p11; Several Great Lake States 

have adopted summertime 

restrictions on cutback asphalt. 

SCAQMD plans to investigate the 

feasibility of the Great Lake States' 

--- rule. 

Rule 225 Organic Solvent 

Cleaning and 

Degreasing 

Operations 

912711 994 8/21/1995 

60 FR 

43383 

pl I; Sacramento AQMD adopted 

more stringent controls in 2002 

Rule 231 Graphic Arts pl I; EDAQMD rule applies to 

facilities emittirlg 1660 

poundslmonth. SM 431 applies to 

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 1011 811 994 9/25/2001 1011 412003 

68 FR 

pl I; Compare against other 

District's biomasslsolid fuel boiler 

59121 NOx limits. 

Rule 234 VOC RACT Rule - Sierra Pacific 

Industries 

911 211 995 

60 FR 

47273 

p11;Is CARB's 1994 analysis still 

appropriate for Rule 234: 

http:llwww.arb.ca.gov/pmlpmmeasu 

reslceffect/re portslpca pcd 229 rep 

ort. pdf 

Rule 237 Wood Products 

Coating Operations 

711 811996 

61 FR 

37390 

p11 EDAQMD rule applies to 

facilities applying >20gallons/mth. 

SM 463 applies at >55 gallonslyear 

Enclosure (1 )