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From: SACRAMENTO METROPOLITAN AIR QUALITY MANAGEMENT DISTRICT ForAgenda ofOctober23, 2008 Board ofDirectors Sacramento MetropolitanAirQuality Management District LarryGreene Executive Director/Air Pollution Control Officer Subject: Public Hearing to Adopt a Resolution Approving a Revision to the Ozone State Implementation Plan for ReasonablyAvailable Control Technology
Recommendations 1. Conduct a public hearing; 2. Determine that the adoption ofthe revision to the Ozone State Implementation Plan is exemptfrom the California Environmental QualityAct (CEQA); and 3. Adopt the attached resolution approving a revision to the Ozone State Implementation Planfor ReasonablyAvailable Control Technology.

Executive Summary The federal Clean Air Act requires air districts that are in nonattainment areas for the federal ozone standard to implement ReasonablyAvailable Control Technology (RACT)forthe 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 Countythatare subjecttothe 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 Districtto submita revisiontothe State Implementation Plan (SIP) that meetsthe federal Clean AirAct RACT requirements as they applyto the 8-hour ozone standard. On October 26, 2006, the Board adopted a revision to the SIP thatfulfilled the RACT requirements for CTG categories previously established by EPA and for majorsources ofVOC and NOx. Since thattime, EPA has promulgated seven new CTGs. In addition, it is anticipated that EPA will reclassifythe Sacramento Federal NonattainmentArea to "severe" nonattainment in response to a request submitted by the local air districts and the California Air Resources Board (GARB). A reclassification to severe nonattainmentwill 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 determinedthat sourceswith potential emissions of50tons ormore per year meet the requirements, this analysis has focused on whether existing sources with potential emissions between 25 and 50 tons peryear meetthe RACT requirements. Staffperformed an analysis ofDistrict rules that implement RACTforthe newCTG categories and majorsources ofVOC and NOx. As a result ofthis analysis, Staff has determined amendments 

# 000001Board Memo Ozone SIP Revisionfor RACT October23, 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 metfor existing sources thatwill become majorsources upon reclassification to severe nonattainment. Staff has prepared a revision to the Ozone SIP that includes: 1) negative declarations for four CTG source categories forwhich the District has no sources, 2) certification that the District has met the RACT requirements for existing sources of 

## voe and NOx that will become major sources upon reclassification to severe nonattainment, and 3) commitmentsto amend Rules 450 and 451 to meettothe RACT guidelinesestablished bythe newCTGs.

Attachments Thetable below identifiesthe attachmentstothis memo: Item Attachment Paae# Board ResolutionforOzone SIP Revision A 6 Prooosed Ozone SIP Revision B 

### 9 StaffReport 

# 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) ofthe federal CleanAirAct requirethe Districtto implement RACTfor:

• Each category of

## voe sources that is covered by a Control Techniques Guideline (CTG) document issued by EPA; and • All majorstationarysources of

## voe 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 ofVOC and NOx. This SIP revision was submitted by GARB to EPA on July 11, 2007. Since the October 26, 2006 RACT SIP, EPA has promulgated seven new CTGs. In addition, the air districtsofthe Sacramento Federal NonattainmentArea submitted a letterto GARB in February of2008to request avoluntary reclassification to "severe" nonattainment, as provided by Section 181(b)(3) of the federal Clean Air Act. On February 14, 2008, GARB requested that EPA reclassify this area to "severe." It is anticipated the EPA will take action on this request by the end of2008. A reclassification to severe nonattainmentwill reduce the majorsource emissions threshold from 50 to 25 tons per year ofeither VOC or NOx, imposing RACT requirements on additional sourceswithin the District.



# 000002

### Board Memo Ozone SIP Revision for RACT October23, 2008, Page 3 RACTAnalysis 

### Staff's analysis is presented in the Staff Report (Attachment C). The process Staff used to demonstrate compliancewith federal RACT requirements consists ofthefollowing steps:
• For new CTG source categories forwhich the District has no applicable rule, determine whetherthe District hassources 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 rulesthat have been determinedto 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, Staffhas determinedthat the District has no sources in thefollowing CTG categories:
• FlatWood Paneling Coatings • Paper, Film and Foil Coatings • LargeAppliance Coatings Staff identified four source categories covered by the new CTGs for which the District has applicable sources:
• Offset Lithographicand Letterpress Printing • Flexible Package Printing • Industrial Cleaning Solvents • Metal Furniture Coatings Stafffinds that the requirements of RACT forthese CTG categories are satisfied by the District rules, withthefollowing exceptions:
• For flexible package printing, Rule 450 does not meet the CTG requirements for mandatory control equipment on printing presses with potentialto emit, priorto controls, of at least 25 tons/year of

## voe. 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 rulewill be submittedfor inclusion inthe 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

## voe. In addition, the CTG recommends more stringent 

## voe content limits for fountain solutions used by offset lithographic 

## 000003

### Board Memo Ozone SIP Revisionfor RAeT October23, 2008, Page4 printing sources with actual emissions ofvoe of at least 15 lb/day (equivalent to 450 lb/month). Staff is proposing to correct these RAeTdeficiencies by amending Rule 450 to require mandatory control equipment on presses with potential to emit, prior to controls, ofat least 25 tons/yearofvoeand to set more stringentvoe limits, consistent with the eTG recommendations, for fountain solutions used by offset lithographic printing sources with actual emissions of voe 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 eTG requirements and RAeT determinations. Following adoption, the amended rule will be submitted for inclusion in the SIP.
• For metal furniture coating operations, thevoe content limits recommended in the eTG for general one-component, extreme high gloss, and extreme performance coatings are more stringentthan 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 eTG recommends 90% overall efficiency. Staff is proposing to correct these RAeT deficiencies by amending Rule 451 to include the eTG-recommended voe content limitsfor metalfurniture coatings, applicableto sources with actualvoe 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 September25, 2008. The amended rule will be submittedfor inclusion inthe SIP. A bump-upto severe nonattainmentwill reducethe majorsourcethresholdto a potential-to-emit exceeding 25 tons per year of either voe 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 voe or NOx upon reclassification to severe nonattainment. Three ofthese 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 voe. Staff has determined that the RAeT requirements have been satisfied for the sources that will become major sources upon reclassification to severe nonattainment.

Business CostImpacts 

### Staff has determined that current sources are either below the applicability thresholds of the new requirements or already complywith the new requirements. No coststo businesseswill be incurred as a result ofproposed SIP revision.

DistrictImpacts 

### The proposed SIP revision will not result in an additional need for staffresources.
Emission Impacts 

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



## 000004Board Memo Ozone SIP Revision for RACT October23, 2008, Page 5 Environmental Reviewand Compliance No sourceswill be required to modifytheir operations as a result ofthe commitments proposed in this SIP revision. Staff has determined that current sources are either belowthe applicability thresholds ofthe new requirements or already comply with the new requirements. Therefore, Staff has determinedthatthe adoption ofthese rule commitments is exemptfrom the California Environmental Quality Act (CEQA) under Section 15061(b)(3) ofthe State CEQA Guidelines because it can be seen with certainty thatthere is no possibilitythatthe activity in question may have a significant adverse effecton the environment.

Public Outreach A public noticeforthe Board hearing to considerthe adoption ofthe proposed SIP revision was published in the Sacramento Bee on September22, 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 partieswho have requested public noticesfor District rulemaking activities.

Conclusion The proposed SIP revision will satisfy the requirements of sections 182(b)(2) and 182(f) of the federal Clean AirAct. Therefore, staff recommends thatthe 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 toform:



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Attachments



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