UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Notice of Proposed Rulemaking

for the

California State Implementation Plan

EPA’s Evaluation of

Sacramento Metropolitan Air Quality Management District, 

Ozone State Implementation Plan (SIP) Revision

Updated Analysis of Reasonably Available Control Technology for the 

8-Hour Ozone State Implementation Plan (Updated RACT SIP)

Dated September 22, 2008

Adopted October 23, 2008

“RACT SIP Update TSD”

Prepared by: Stanley Tong

November 2015
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RULE IDENTIFICATION -

Agency: Sacramento Metropolitan Air Quality Management District 

(SMAQMD)

SIP Approved Version: There is no previous version of this document in the SIP

Subject of this TSD: SMAQMD Updated Analysis of Reasonably Available Control 

Technology for the 8-Hour Ozone State Implementation Plan 

(“Updated RACT SIP”) – dated September 22, 2008

Adopted – October 23, 2008

Submitted – January 21, 2009

SMAQMD Updated Analysis of Reasonably Available Control 

Technology for the 8-Hour Ozone State Implementation Plan –

September 22, 2008 Staff Report

(“Updated RACT SIP staff report”)

Note: the submitted 2008 SMAQMD Ozone State Implementation Plan (SIP) Revision 

documents update Reasonably Available Control Technology (RACT) as Applicable to 

and supplement these the 8-Hour Ozone Standard (“2006 RACT SIP”)

2006 documents: Adopted – October 26, 2006

Submitted – July 11, 2007

SMAQMD Analysis of Reasonably Available Control Technology for 

the 8-Hour Ozone State Implementation Plan – September 6, 2006 

Staff Report (“2006 RACT SIP Staff Report”)

BACKGROUND -

Volatile organic compounds (VOC) and nitrogen oxides (NOx) in the presence of sunlight can 

lead to the formation of ground-level ozone or “smog” which can result in significant impacts to 

human health and the environment. Section 182 of the Clean Air Act (CAA) requires areas that 

are classified as moderate or above for ozone nonattainment to implement reasonably 

available control technology (RACT) for specific types of sources. The Sacramento 

Metropolitan Air Quality Management District (SMAQMD or the District) falls under this 

requirement as it is classified as a severe1 ozone non-attainment area under the 1997 8-hour 

national ambient air quality standard (NAAQS) for ozone (40 CFR 81.305).

 1 On February 14, 2008, the California Air Resources Board (CARB) requested EPA reclassify the 8-

hour ozone non-attainment classification for Ventura County, Sacramento Metro, and Western Mojave 

Desert (see 74 FR 43654, August 27, 2009). On May 5, 2010 (75 FR 24409), EPA granted the State of 

California’s request. As a result, the Sacramento Metropolitan ozone non-attainment area was 

reclassified from “serious” to “severe-15”.
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Under CAA § 182(b)(2) and (f), SMAQMD must, at a minimum, adopt RACT level controls for 

sources covered by a Control Techniques Guidelines (CTG) document and for any major 

stationary source of VOC or NOx.

2

Between 2006 and 2008, EPA issued 11 new or revised CTGs. States are required to submit 

a SIP revision in response to the CTGs within a year of the date the CTGs were finalized.3

SUBMITTAL SUMMARY -

The District adopted its Updated RACT SIP on October 23, 2008 and the California Air 

Resources Board (CARB) submitted it to EPA on January 21, 2009. SMAQMD performed its

Updated RACT SIP analysis based on an ozone non-attainment classification of “severe”. This 

classification defines a major source as those facilities that emit or have the potential to emit 

at least 25 tons per year (tpy) of VOC or NOx.

SMAQMD’s submittal included the following documents:

a. “Staff Report – Updated Analysis of Reasonably Available Control Technology for the 8-

Hour Ozone State Implementation Plan,” September 22, 2008.

b. Resolution 2008-064, “Ozone State Implementation Plan Revision: Reasonably 

Available Control Technology as Applicable to the 8-Hour Ozone Standard,” adopted on 

October 23, 2008.

c. “Ozone State Implementation Plan (SIP) Revision, Reasonably Available Control 

Technology (RACT) as Applicable to the 8-Hour Ozone Standard,” October 23, 2008.

SMAQMD’s analysis evaluated the following areas. Further discussion is provided below.

• seven new CTGs EPA issued in 2006 and 2007

• negative declarations

• additional major sources identified after reclassification to “severe” nonattainment for 

the 8-hour ozone standard

1. Seven New CTGs

Industrial Cleaning Solvents

Offset Lithographic Printing and Letterpress Printing

Flexible Package Printing

Metal Furniture Coatings

Flat Wood Paneling Coatings

Paper, Film, and Foil Coatings

 

2On July 11, 2007, Sacramento Metropolitan Air Quality Management District submitted its 2006 RACT SIP 

certifying its rules implemented RACT for the 1997 8-hour ozone standard. Our evaluation of the 2006 

RACT SIP submittal is contained in a separate TSD.

3 See 71 FR 58745 (October 5, 2006) http://www.gpo.gov/fdsys/pkg/FR-2006-10-05/pdf/E6-1648h5.pdf; 

72 FR 57215 (October 9, 2007) http://www.gpo.gov/fdsys/pkg/FR-2007-10-09/pdf/E7-19627.pdf; and 

73 FR 58481 (October 7, 2008) http://www.gpo.gov/fdsys/pkg/FR-2008-10-07/pdf/E8-23750.pdf.
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Large Appliance Coatings

SMAQMD reviewed the above CTGs and determined it only had sources covered by the 

following four CTGs.

CTG Category SMAQMD Rule 

(version cited in 

9/22/08 staff report)

Current rule SIP Status

Industrial Cleaning

Solvents

EPA 453/R-06-001

466 (5/23/02) 10/28/10 Rule 466 was amended 10/28/10

Approved 9/29/11 (76 FR 60376)

Offset Lithographic

and Letterpress

Printing 

EPA 453/R-06-002

450 (3/23/00) 10/23/08 Rule 450 was amended 10/23/08

Approved 4/9/10 (75 FR 18068)

Flexible Package

Printing

EPA 453/R-06-003

450 (3/23/00) 10/23/08 Rule 450 was amended 10/23/08

Approved 4/9/10 (75 FR 18068)

Metal Furniture Coatings

EPA 453/R-07-005

451 (10/2/97) 10/28/10 Rule 451 was amended 10/28/10

Approved 11/21/11 (76 FR 71886)

RACT Evaluation:

1a. Industrial Cleaning Solvents

On May 23, 2002, SMAQMD adopted Rule 466, Solvent Cleaning. This rule was submitted 

to EPA on September 15, 2009, and was approved into the SIP on May 5, 2010 (75 FR 

24406) as meeting RACT. Our approval concluded that Rule 466 conformed to the 

recommendations in the 2006 Industrial Cleaning Solvents CTG.

SMAQMD adopted additional amendments to Rule 466 on September 25, 2008 and 

amended the rule again on October 28, 2010. The September 25, 2008 amendments 

reduced the VOC content limit for several solvent cleaning operations and established a 

new VOC limit of 200 grams/liter for solvent cleaners used in sterilizing food manufacturing 

processing equipment. The September 25, 2008 amendments were not submitted to EPA 

for SIP approval. Two years later, on October 28, 2010, SMAQMD amended Rule 466 to 

exempt solvents used on food-contact surfaces that are not rinsed prior to contact with 

food. SMAQMD’s staff report4 estimates this exemption would result in forgoing 0.005 tons 

per day of VOC reductions, but that VOC reductions of 0.711 tons per day from 

amendments in other rules involving solvent cleaning would more than offset this loss. 

EPA Evaluation

On September 29, 2011 (76 FR 60376), EPA approved the October 28, 2010 amendments 

to Rule 466 as meeting RACT. We are not aware of any information that would alter our 

prior determination that Rule 466 fulfills RACT for this source category.

1b. Offset Lithographic and Letterpress Printing

SMAQMD’s Updated RACT SIP concluded that Rule 450, Graphic Arts Operations 

(amended 3/23/00), did not meet the 2006 Offset Lithographic and Letterpress Printing 

 4 Sacramento Metropolitan Air Quality Management District Staff Report – Rule 466 – Solvent Cleaning, 

August 19, 2010.
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CTG and committed to amending the rule. The CTG contained recommendations for 

mandatory emissions control equipment on printing presses that had a potential to emit, 

prior to controls, of at least 25 tpy of VOCs. The CTG also recommended more stringent 

VOC content limits for fountain solutions used by offset lithographic printing presses with 

actual emissions of at least 15 lb/day of VOC.

On October 23, 2008, SMAQMD amended Rule 450 to satisfy the 2006 Offset Lithographic 

and Letterpress Printing CTG.

EPA Evaluation

On April 9, 2010 (75 FR 18068), EPA approved the amendments to Rule 450 as meeting 

RACT. We are not aware of any information that would alter our prior determination that 

Rule 450 fulfills RACT for this source category.

1c. Flexible Package Printing

SMAQMD’s Updated RACT SIP staff report concluded that Rule 450, Graphic Arts 

Operations (amended 3/23/00), did not meet the 2006 Flexible Package Printing CTG and 

committed to amending the rule. The CTG contained recommendations for mandatory 

emissions control equipment on flexible package printing processes that had a potential to 

emit, prior to controls, of at least 25 tpy of VOCs.

On October 23, 2008, SMAQMD amended Rule 450 to satisfy the 2006 Flexible Package 

Printing CTG. 

EPA Evaluation

On April 9, 2010 (75 FR 18068), EPA approved the amendments to Rule 450 as meeting 

RACT. We are not aware of any information that would alter our prior determination that 

Rule 450 fulfills RACT for this source category.

1d. Metal Furniture Coatings

SMAQMD’s Updated RACT SIP staff report concluded that Rule 451 Surface Coating of 

Miscellaneous Metal Parts and Products (amended 10/2/97), did not met the Metal 

Furniture Coatings CTG and committed to amending the rule. The CTG contained more

stringent VOC content limits for general one-component, extreme high gloss, and extreme 

performance coatings than Rule 451. The CTG also recommended an overall control 

efficiency of 90% which is more stringent than the 85% control efficiency in Rule 451.

On September 25, 2008 SMAQMD amended Rule 451 to conform to the 2007 CTG for 

Metal Furniture Coatings. The amendments also lowered the VOC limit for surface 

preparation and cleanup materials to 25 g/l, lowered the VOC limit for various metal 

furniture coatings to as low as 275 g/l, and increased the emissions control equipment 

efficiency requirement to 90%.

SMAQMD concluded that no emissions reductions would result from the September 2008 

amendments because, based on District permits, only one source currently conducts metal 

furniture coating operations and that source uses powder coatings. Powder coatings do not 
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use a solvent and typically cures at 140 to 210oC5, which is beyond the 110oC specified in 

EPA Method 24 for determining the VOC content of inks and coatings.

Rule 451 was further amended on October 28, 2010 to satisfy the 2008 Miscellaneous 

Metal and Plastic Parts CTG.

EPA Evaluation

On November 21, 2011 (76 FR 71886), EPA approved the October 28, 2010 version of 

Rule 451 as meeting RACT. We are not aware of any information that would alter our prior 

determination that Rule 450 fulfills RACT for this source category.

2. Negative Declarations

The District reviewed its permit records, enforcement program, telephone yellow pages, and 

business listings and determined there were no stationary sources covered by the following 

CTGs and does not anticipate these sources in the future:

CTG Source 

Category

CTG Document Title

Flat Wood 

Paneling Coatings 

EPA-453/R06-004 Control Techniques Guidelines for Flat 

Wood Paneling Coatings

Paper, Film and 

Foil Coatings

EPA-453/R-07-003 Control Techniques Guidelines for 

Paper, Film, and Foil Coatings 

Large Appliances EPA-453/R-07-004 Control Techniques Guidelines for 

Large Appliance Coatings 

EPA Evaluation

EPA-453/R06-004 Control Techniques Guidelines for Flat Wood Paneling Coatings.

A review of CARB’s 2008 emissions inventory did not reveal any flat wood paneling coating 

facilities in SMAQMD emitting greater than the CTG applicability threshold of 2.7 tpy. The 

largest source identified under SIC code 2431, Millwork, emitted 0.2 tpy of VOC.

EPA-453/R-07-003 Control Techniques Guidelines for Paper, Film, and Foil Coatings.

Appendix B of the CTG contains an estimate of the total number of facilities in each 

nonattainment area that is covered by the CTG. There are no facilities listed in Appendix B 

for the Sacramento Metropolitan area. A SIC code search identified one facility that might 

be covered by the CTG, Huhtamaki Foodservice Inc (formerly Chinet), with emissions of 8.5 

tpy of VOC (SIC code 2679, Converted Paper and Paper Board). Discussion with SMAQMD 

indicated VOC emissions from Huhtamaki Foodservice Inc are associated with pulping and 

molding machines and not with coating operations covered by the Paper, Film, and Foil 

Coatings CTG6.

 5 See http://www.ferro-sa.co.za/default.php?start=27&sid=57

6 Email dated April 18, 2012 from Kevin Williams (SMAQMD) to Stanley Tong (EPA Region IX) RE: 

Huhtamaki Foodservice Inc.
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EPA-453/R-07-004 Control Techniques Guidelines for Large Appliance Coatings. 

The CTG lists the following SIC codes that may be covered by the CTG: 3631, 3632, 3633, 

3639, 3582, 3585, and 3589. We reviewed CARB’s emissions inventory and did not find 

any facilities in the SMAQMD associated with these SIC codes.

In summary, EPA reviewed CARB’s 2008 emissions inventory and did not find any facilities 

that were covered by the above CTGs for which SMAQMD is claiming a negative 

declaration.

3. Additional Major Sources after Reclassification to “severe” Ozone nonattainment

SMAQMD reviewed its emission inventory for new sources that emit or had the potential to 

emit at least 25 tpy of VOC or NOx as a result of its reclassification from “serious” to 

“severe” nonattainment for the 1997 8-hour ozone standard. As a result, the District 

determined that five additional stationary sources would now be classified as major 

sources. Two (Cosumnes Power Plant and UC Davis Medical Center) of the five sources 

were previously identified in the District’s October 26, 2006 RACT SIP analysis and the 

remaining three sources were determined to be already covered by rules that met RACT.

EPA Evaluation

Table 2 of SMAQMD’s Updated RACT SIP staff report lists Cosumnes Power Plant and 

UC Davis Medical Center as two sources previously identified as major sources of NOx in 

the District’s 2006 RACT SIP. The bump-up to severe nonattainment for ozone will also 

classify these two facilities as major sources of VOC. We agree the remaining three newly 

designated major sources are already covered by RACT rules. The following is a summary 

of SMAQMD’s RACT review for the five new major sources and EPA’s evaluation of that 

review.

Cosumnes Power Plant

The Cosumnes Power Plant is a 500 megawatt combined cycle power plant. NOx

emissions from its turbines are limited to 9 ppm at 15% O2 by SMAQMD Rule 413 (SIP 

approved January 10, 2008 73 FR 1819). SMAQMD’s Updated RACT SIP staff report 

states District staff is not aware of any cost effective controls that can be applied to VOC 

emissions from natural gas combustion sources such as gas turbines and that the District 

was unaware of any federal guidance for such controls. The Updated RACT SIP staff 

report further points out that the combustion process is inherently efficient in destroying 

VOCs and concluded that there are no applicable RACT requirements to control secondary 

VOC emissions from gas-fired turbines

EPA searched the RACT/BACT/LAER clearinghouse and did not uncover any VOC control 

devices for gas turbines and we are not aware of any air districts or States that regulate

VOC emissions from gas turbines. We agree with SMAQMD’s conclusion that there do not 

appear to be any reasonably available VOC controls for gas turbines.

UC Davis Medical Center
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SMAQMD’s Updated RACT SIP staff report indicates the UC Davis medical center is a 

major source of NOx (91 tpy) and VOC (29 tpy) and operates a gas turbine, four large and 

nine small natural gas fired boilers, and ten diesel engines. UC Davis also has a gasoline 

dispensing station consisting of two 10,000 gallon underground gasoline tanks and one 

10,000 gallon underground diesel tank. SMAQMD indicates the dispensing facility is 

equipped with both Phase I and Phase II vapor recovery controls.

SMAQMD’s Updated RACT SIP staff report states the gas turbine is covered by Rule 413, 

Stationary Gas Turbines, which has been approved as meeting RACT (73 FR 1819). The 

large boilers are covered by Rule 411, NOx From Boilers, Process Heaters and Steam 

Generators, which EPA has approved as meeting RACT (74 FR 20880). The smaller 

boilers are exempt from NOx emission limits in Rule 411 due to a permit condition limiting 

their use to no more than 40,000 therms of fuel. SMAQMD’s Updated RACT SIP staff 

report also states the eight smaller boilers, which are rated at 0.4 million British thermal 

units per hour (MMBtu/hr), are exempt from Rule 411 due to their small size7. The District, 

however, pointed out that it plans to adopt requirements for small boilers similar to South 

Coast 1146.2, Ventura County APCD 74.11.1 and San Joaquin 4308 into SMAQMD Rule 

414 in 2009. On November 1, 2011, (see 76 FR 67366) EPA approved SMAQMD’s March 

25, 2010 amendments to Rule 414, Water Heaters, Boilers and Process Heaters Rated 

Less than 1,000,000 BTU per hour. We noted that the rule was not subject to RACT 

requirements because these sources are too small to exceed the major source threshold, 

but we found that the rule requires controls that appear to be "reasonably available" 

considering technological and economic feasibility. Accordingly, we propose to find that 

Rule 414 implements RACT for the eight 0.4 lb/MMBtu boilers. 

SMAQMD’s Updated RACT SIP staff report states the remaining sources at UC Davis are 

covered by rules that EPA has determined to fulfill RACT. Specifically, the emergency 

standby engines are covered by Rule 412, Stationary Internal Combustion Engines at 

Major Stationary Sources of NOx (61 FR 18959), and the gasoline dispensing facility is 

covered by Rule 448, Gasoline Transfer into Stationary Storage Containers (78 FR 897)

and Rule 449, Transfer of Gasoline into Vehicle Fuel Tanks (78 FR 897).8

While Rule 412 was adopted and approved into the SIP a number of years ago, we believe 

it still satisfies RACT. Rule 412 contains both NOx RACT limits and more stringent Best 

Available Retrofit Control Technology (BARCT) limits. The Rule defines BARCT as "an 

emission limitation that is based on the maximum degree of reduction achievable, taking 

into account environmental, energy, and economic impacts by each class or category of 

sources." Existing internal combustion engines in SMAQMD are required to meet Rule 

412’s more stringent BARCT limits. The table below shows Rule 412’s BARCT limits are 

comparable to limits in other districts at the time SMAQMD adopted its Updated RACT SIP 

in 2008. We believe the BARCT limits satisfy RACT. We are not aware of any information 

that would alter our prior determinations that Rules 412, 448 and 449 fulfill RACT.

 7 Rule 411, NOx from Boilers, Process Heaters and Steam Generators, applies to units greater than 1 

MMBtu/hr.

8 Rules 448 and 449 were amended in 2009, after SMAQMD adopted its Updated RACT SIP, and were 

approved by EPA as meeting RACT.
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IC Engine NOx limits at 15% O2

Sacramento 

Rule 412 

BARCT(6/1/95)

Ventura 

Rule 74.9 (11/8/05)

San Joaquin

Rule 4702 (1/18/07)*

Spark Ignited Rich 

burn

25 25 25

Spark Ignited Lean 

Burn

65 45 65

Compression 80 80 80**

* The current version of Rule 4702 is 11/14/13

** Greater than 500 bhp and greater than or equal to 1000 annual operating hours

Grafil, Inc

Grafil, Inc manufactures carbon fibers from polyacrylic fiber. Grafil is considered a major 

source of NOx (26.1 tpy) due to the operation of six thermal oxidizers, two natural gas 

boilers, an emergency backup spark ignited internal combustion engine, and an emergency 

backup diesel engine. The thermal oxidizers, while controlling VOC emissions, also 

produce a secondary pollutant, NOx. 

SMAQMD’s conclusion is RACT is satisfied for the boilers and internal combustion engines

because the rules associated with these source categories have been determined by EPA 

to satisfy RACT. (Rule 411, NOx from Boilers, Process Heaters and Steam Generators (74 

FR 20880; Rule 412, Stationary IC Engines at Major Stationary Sources of NOx (61 FR 

189599)) The District notes, however, that there is no EPA guidance on what type of RACT 

controls may be applicable to NOx emissions produced by VOC control devices such as 

thermal oxidizers. SMAQMD also points out that there are no New Source Performance 

Standards (NSPS) or rules from other air districts that apply to NOx emissions from thermal 

oxidizers. EPA agrees with SMAQMD’s conclusion and is also unaware of any NSPS, 

RACT rules, or guidance documents applicable to controlling secondary NOx emissions 

from VOC control devices such as thermal oxidizers.

Sacramento Power Authority

SMAQMD’s Updated RACT SIP staff report states this facility has a gas turbine which 

generates approximately 103 MW of power and a heat recovery steam generator with a 

200 MMBtu/hr duct burner. A selective catalytic reduction (SCR) system controls NOx 

emissions from the turbine and duct burner to meet the permit limit of 3 ppmvd at 15% O2. 

SMAQMD’s Updated RACT SIP staff report further points out that the duct burners fire into 

the hot turbine exhaust and emissions from the duct burner and turbine are combined 

upstream of the SCR. The Updated RACT SIP staff report states that because it is not 

 

9 See discussion regarding Rule 412 under UC Davis Medical Center above.
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feasible to operate the duct burner separately from the gas turbine, the duct burner is 

essentially subject to Rule 413 NOx limits.

EPA previously approved Rule 413 as meeting RACT (73 FR 1819) and we are not aware 

of any information that would alter our prior determination that it fulfills RACT.

Silgan Can Company

SMAQMD’s Updated RACT SIP staff report states Silgan Can Company manufactures 

steel cans for the food industry. VOC emissions from the facility are 36.3 tpy primarily from 

coatings applied to the cans during the manufacturing process. VOC emissions are 

controlled by a thermal oxidizer with at least 90% capture and 95% destruction efficiency. 

The facility is subject to Rule 452, Can Coating.

EPA approved Rule 452 as meeting RACT on April 9, 2010 (75 FR 18068) and we are not 

aware of any information that would alter our prior determination that it fulfills RACT.

4. Summary of Evaluation of SMAQMD Updated RACT SIP

SMAQMD’s Updated RACT SIP staff report identified Rules 450 (Graphic Arts Operations)

and 451 (Surface Coating of Miscellaneous Metal Parts and Products) needed updating to 

satisfy the 2006 and 2007 CTGs. SMAQMD updated these rules and EPA approved them 

into the SIP in 2010 and 2011.

EPA reviewed SMAQMD’s negative declarations and we agree with the conclusion that 

there are no sources in the District covered by the following CTGs: Flat Wood Paneling 

Coatings; Paper, Film and Foil Coatings; and Large Appliance Coatings. 

SMAQMD’s analysis also identified five additional major sources as a result of their 

reclassification from serious to severe ozone nonattainment for the 1997 8-hour ozone 

standard. The District satisfactorily demonstrated that emissions from these facilities are 

covered by RACT rules.

EPA believes the Updated RACT SIP analysis performed by the SMAQMD adequately 

demonstrates its rules are consistent with EPA recommendations in the 2006 and 2007 

CTGs.

5. Recommendations

1. EPA issued four new CTGs in 2008. SMAQMD amended, and EPA approved10, Rule 

451, Surface Coating of Miscellaneous Metal Parts and Products, as meeting RACT for 

the Miscellaneous Metal and Plastic Parts CTG. EPA also approved11 SMAQMD’s 

negative declarations for the CTG categories of Fiberglass Boat Manufacturing Materials 

 10 See 76 FR 71886, November 21, 2011 http://www.gpo.gov/fdsys/pkg/FR-2011-11-21/pdf/2011-

29906.pdf

11 See 77 FR 63743, October 17, 2012 http://www.gpo.gov/fdsys/pkg/FR-2012-10-17/pdf/2012-25383.pdf
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and Automobile and Light Duty Truck Assembly Coatings.12 SMAQMD should review the 

remaining CTG, Miscellaneous Industrial Adhesives, issued in 2008 and submit a RACT 

SIP certification or negative declaration for the category13.

2. Rule 412, Stationary Internal Combustion Engines, was last amended in 1995. 

SMAQMD should review the rule and update as appropriate the NOx limits and remove 

the exemption for agricultural operations. 

6. Public Comments

SMAQMD’s Updated RACT SIP staff report was made available for public comment. No 

public comments were received by the SMAQMD.

7. REFERENCES

1. SMAQMD Ozone State Implementation Plan (SIP) Revision, Reasonably Available 

Control Technology (RACT) as Applicable to the 8-Hour Ozone Standard – Adopted –

October 26, 2006; Submitted – July 11, 2007.

2. SMAQMD Updated Analysis of Reasonably Available Control Technology for the 8-

Hour Ozone State Implementation Plan (Updated RACT SIP) – Adopted – October 23, 

2008; Submitted January 21, 2009.

3. SMAQMD Updated Analysis of Reasonably Available Control Technology for the 8-

Hour Ozone State Implementation Plan – September 22, 2008 – Updated RACT SIP 

staff report.

4. “State Implementation Plans, General Preamble for the Implementation of Title I of the 

Clean Air Act Amendments of 1990” (57 FR 13498; April 16, 1992).

5. “State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for 

the Implementation of Title I of the Clean Air Act Amendments of 1990” (57 FR 55620, 

November 25, 1992) (“the NOx Supplement”).

6. CARB’s emissions inventory database 

http://www.arb.ca.gov/app/emsinv/facinfo/facinfo.php

7. EPA’s CTGs and ACTs 

http://www3.epa.gov/airquality/ozonepollution/SIPToolkit/ctgs.html

 

12 While aerospace coating operations is not one of the new CTGs issued by EPA between 2006-2008, 

SMAQMD nonetheless adopted a negative declaration for this category on October 27, 2011, and 

CARB submitted it to EPA on January 12, 2012. EPA approved the negative declaration on April 18, 

2012 75 FR 23130. 

13 See 73 FR 58481, October 7, 2008 http://www.gpo.gov/fdsys/pkg/FR-2008-10-07/pdf/E8-23750.pdf . 

Discussion with SMAQMD indicates it plans to adopt a negative declaration for the Industrial Adhesives 

CTG.
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8. SMAQMD, CARB, and EPA Region IX databases of SMAQMD rules

SMAQMD: http://www.airquality.org/rules/index.shtml

CARB: http://www.arb.ca.gov/rldb/rldb.htm

EPA: http://www2.epa.gov/approved-sips/approved-sips-region-9

9. Email dated April 18, 2012 from Kevin Williams (SMAQMD) to Stanley Tong (EPA 

Region IX) RE: Huhtamaki Foodservice Inc.