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 Qualit y 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 2 3 , 200 8

“ RA CT SIP Update TSD ”

Prepared by: Stanley Tong

November 2015- 2

- RULE IDENTIFICATION

-

Agency: Sacramento Metropolitan Air Quality Management District (S M AQMD)

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

Subject of this TSD: S M AQMD Updated Analysis of Reasonably Available Control Technology for the 8

- Hour Ozone St ate Implementation Plan ( “ Updated RACT SIP ” )

– dated September 22, 2008 Adopted

– October 2 3 , 200 8
Submitted

– J anuary 2 1 , 200 9

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 Pla n (SIP) Revision

document s update Reasonably Available Control Technology (RACT) as Applicable to and supplement the s e the 8

- Hour Ozone Standard ( “ 2006 RACT SIP ” )

2006 document s : Adopted

– October 26, 2006
Submitted

– July 11, 2007

SMAQMD Analy sis 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 nonatta inment to implement reasonably available control technology (RACT) for specific types of sources. The Sacramento Metropolitan Air Quality Management District (S M AQMD or the District ) falls under this requirement as it is classified as a se vere 1 ozone non

- a ttainment 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 re quest. As a result, the Sacramento Metropolitan ozone non

- attainment area was
reclassified from “ serious ” to “ severe

- 15 ”

.- 3

- Under CAA § 182(b)(2) and (f), S MAQMD 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 CTG s within a year of the date the CTGs were finalized. 3

SUBMITTAL SU MMARY

-

The District adopted its Updated RACT SIP on October 2 3 , 200 8 and the California Air Resources Board ( CARB ) subm itted it to EPA on J anuary 21, 2009

. SMAQMD performed its Updated R ACT SIP analysis based on an ozone non

- attainment classification of “ se vere ” . 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 A nalysis of Reas onably Available Control Technology for the 8

- Hour O zone State Implementation Plan

, ” September 22 , 200 8

. b. Resolution 2008

- 0 64

, “ Ozone State Implementation Plan Revision : Reasonably Available Control Technology as Applicable to the 8

- H our Ozone Standard, ” ad opted on October 2 3 , 200 8

. c. “ Ozone State Implementation Plan (SIP) Revision, Reasonably Available Control Technology (RACT) as Applicable to the 8

- Hour Ozone Standard, ” October 2 3 , 200 8

.

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

• seven new CT Gs EPA issued in 2006 and 2007

• negative declaration s

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

the 8

- h ou r ozone standard

1. Seven N ew CTGs

Industrial Cleaning Solvents
Offset Li thographic Printing and Letterpress Printing

Fle xible Package Printing Metal Furniture Coatings

Flat Wood Paneling Coatings Paper, Film, and Foil Coatings

2 On July 11, 200 7 , Sacramento Metropolitan Air Quality Management District submitted its 2006 RACT SIP certifying its rules impleme nted 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/f dsys/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

.- 4

- 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 r ule SIP Status

Industrial Cleaning
Solvents

EPA 453/R

- 06

- 001 466 (5/23/02) 10/28/10 Rule 466 was a mended 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 a mended 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 a mended 10/23/08 Approved 4/9/10 ( 75 FR 18068 )

Metal Fu rniture Coatings

EPA 453/R

- 07

- 005 451 (10/2/97) 10/28/10 Rule 451 was a mended 10/28/10 Approved 11/21/11 ( 76 FR 71886 )

RACT Evaluation : 1 a

. 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

reduc ed 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 amendment s were not submitted to EPA for SIP approval. Two years later, o n 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 report 4 estimates this exemption wou ld 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 fu lfill s RACT fo r 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 S acramento Metropolitan Air Quality Management District Staff Report

– Rule 466

– Solvent Cleaning, August 19, 2010.- 5

- CTG and committed to amending the rule. The CTG contained re commendation s 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 f ountain solutions used by offset lithographic printing presses with

actual em issions of at least 15 l b/day of VOC.

On October 23, 2008, SMAQMD amended Rule 450 to satisfy the 200 6 Offset Lithographic and Letterpress Printing CTG

.

EPA Evaluation
O n 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 fu lfil ls 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 r ule. The CTG contained re commendation s for mandatory emissions control equipment on flexible package printing pr ocesses 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 t he 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 informati on that would alter our prior determination that

Rule 450 fu lfills RACT for this source category

.

1 d

. Metal Furniture Coatings
SMAQMD ’ s Updated RACT SIP staff report concluded that Rule 451 Surface Coating of

Miscellaneous Metal Parts and Products (amende d 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 rec ommended 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 amendment s also lower ed the VOC l imit for surface preparation and cleanup materials to 25 g/l, lower ed the VOC limit for various metal
furniture coatings to as low as 275 g/l, and increase d the emissions control equipment efficiency requirement to 90%.

SMAQMD concluded that n o emissions reductions w ould 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 coating s

. Powder coatings do not- 6

- use a solvent and typically cu res at 140 to 210 o C 5

, which is beyond the 110 o C 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 Miscellaneo us Metal and Plastic Parts CTG.

EPA Evaluati on On November 21, 2011 ( 76 FR 71886 )

, EPA approved t he October 28, 2010 version of Rule 451 as meeting RACT. We are not aware of any information that would alter our prior

dete rmination that Rule 450 fu lfills 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 d id not reveal any flat wood paneling coating
facilities in S M AQMD emitting greater than the CTG applicability threshold of 2.7 tpy. Th e largest source identified under SIC code 2431, M illwork

, emitted 0.2 tpy o f VOC.

E PA

- 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 f acilities 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 a nd 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 CTG 6

.

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.- 7

- EPA

- 453 /R

- 07

- 004 Control T echniques 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 ass ociated with the se SIC codes

.

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

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

declaration.

3. Additional Major Sources after R e classifica tion to “ s evere ” O zone nonattainment

SMAQMD review ed 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

- ho ur ozone standard

. As a result, t he 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 fi ve sources were previously i dentified 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 the se two facilities a s major source s of VOC. We agree the remaining three newly designated major s o urces are already covered by RACT rule s

. 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 i ts turbines are limited to 9 ppm at 15% O 2 by SMAQMD Rule 413 (SIP approved January 10, 2008 73 FR 1819 )

. SMAQMD ’ s Updated RACT SIP staff report

states District sta ff 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

w as unaware of any federal guidance for such controls. The Updated RACT SIP staff report furt her points out that the combustion process is inherent ly efficient in destroying
VOCs and concluded that there are no applicable RACT requirements to control secondary VOC emissions from gas

- fired turbines

EP A search ed 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 regulat e VOC emissions from gas turbines. W e agree with SMAQMD ’ s conclusion that there do not appear to be any reasonably available VOC contr ols for gas turbines.

UC Davis Medical Center- 8

- 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 engine s . 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 t he dispensing facility is equipped with both Phas e I and Pha se II vapor recovery controls.

SMAQMD ’ s Updated RACT SIP staff report states t he 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, NO x From Boilers, Process Heaters and Steam Generators, which EPA has approved as meeting RACT ( 74 FR 20880 ) . The smalle r 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 Briti sh thermal units per hour ( MM B tu /hr )

, are exempt from Rule 411 due to their small size 7 . T he District

, however, pointed out that it plan s to adopt requirements for small boilers similar to South Coast 1146.2, Ventura County APCD 74.11.1 and San Joaquin 430 8 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

, W ater Heaters, Boilers and Process Heaters Ra ted Less than 1, 000,000 BTU per hour

. We not ed 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 bo i lers.

SMAQMD ’ s Updated RACT SIP staff report states t he remaining sources at UC Davis are covered by rules t hat 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 S torage Containers ( 78 FR 897 ) and Rule 449, Transfer of Gasoli ne 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 a s "an emission limitation that is based on the maximum degree of reduction achievable, taking into account environmental, energy, and eco nomic impacts by each class or category of

sources." E xisting internal combustion engines in SMAQMD are required to meet Rule 412’s more stringent BARCT limit s

. The table below shows Rule 412’s BARCT limits are comparable to limits in other districts at th e time SMAQMD adopted its Updated RACT SIP

in 2008

. We believe the BARCT limits satisfy RACT. W e are not aware of any information

that would alter our prior determinations that Rules 412, 448 and 449 fu lfill RACT

.

7 Rule 411 , NO x 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.- 9

- IC Engine NOx limits at 15% O 2

Sacr amento
Rule 412
BARCT ( 6/1/ 95) Ventura Rule 74.9 ( 11/8/05 ) San Joaquin

Rule 4702 ( 1/18/ 0 7 ) *

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 11/14/1 3

** Greater than 500 bh p 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) d ue to the operation of s ix t hermal oxidizers, two natural gas

boil ers, 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 b oilers 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

18959 9 ) ) The District notes, h owever, that there is no EPA gui dance 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 district s that apply to NOx emissions from th ermal

oxidizers

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

, or guidance documents applicable to controlling s econdary NOx emissions
from VOC control devices such as thermal oxidizers.

Sacrament o 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 MMB tu /hr duct burner. A selective catalytic reduction (SCR) system control s NOx

emissions f rom the turbine a nd duct burner to meet the permit limi t of 3 ppmv d at 15% O 2

. 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 b ecause it is not

9 See discussion regarding Rule 4 12 under UC Davis Medical Center above.- 10

- feasible to operate the duct burner separately from the gas turbine, the duct burner is essentially subject to Rule 413 NOx limits.

EPA previously ap proved Rule 413 as meeting RACT ( 73 FR 1819 ) and w e are not aware
of any information that would alter our prior determination that it fu lfills RACT

.

Silgan Can Company
SMAQMD ’ s U pdated 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

coat ing s 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 w e are not
aware of any information that would alter our prior determination that it fu lfills RACT

.

4

. Summary of Evaluation of SMAQMD Updated RACT SIP

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

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 source s as a resu lt of their
reclassification from serious to severe ozone nonattainment for the 1997 8

- hour ozone standard. The District satisfactorily demonstrated that emissions from t hese facilities are covered by RACT rule s

.

EPA believes the Updated RACT S IP 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 approved 10

, Rule 451, Surface Coating of Miscellaneous Metal Parts and Products, as meeting RACT for
the Miscellaneous Metal and Plastic Parts CTG. EPA also approved 11 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- 11

- 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 category 13

.

2. Rule 412, Stationary Internal Combustion Engines, was l ast 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

SM AQMD ’ s Updated RACT SIP staff report was made available for public comment

. N o public comments were received by the SMAQMD

.

7

. REFERENCES

1. SM AQMD 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 Technol ogy for the 8

- Hour Ozone State Implementation Plan

– September 22, 2008

– Updated RACT SIP

s taff r eport.

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/ozo nepollution/SIPToolkit/ctgs.html

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

- 2008,
S MAQMD nonetheless a dopted 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.- 12

- 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 Ton g (EPA Region IX) RE: Huhtamaki Foodservice Inc.