United States Environmental Protection Agency, Region 9 

Air Division 

Technical Support Document 

for 

EPA’s Notice of Rulemaking 

for the 

California State Implementation Plan 

Placer County Air Pollution Control District’s 

Rule 242, Stationary Internal Combustion Engines 

Prepared by: Idalia Pérez 

September 2011 
1 

Placer County Air Pollution Control District (PCAPCD) 

Submitted Rule 

PCAPCD Rule 242, Stationary Internal Combustion Engines: 

§ Adopted: April 10, 2003 

§ Submitted: December 7, 2010 

§ Determined complete: January 13, 2011 

Previous Rule Submittals 

There are no outstanding submittals of Rule 242. 

SIP-Approved Rule 

There is no SIP-approved version of Rule 242. 

Rule Summary 

PCAPCD Rule 242 regulates emissions of nitrogen oxides (NOx) and carbon monoxide (CO) 

from IC engines with a rated brake horse power of 50 or greater. 

The emission limits are (Section 301.1): 

Engine Type NOx (ppmv) CO (ppmv) 

Rich-Burn 90 2000 

Lean-Burn, rated HP > 100 150 2000 

Lean-Burn, rated HP < 100 300 2000 

Diesel fired 600 2000 

The rule language includes exemptions (Section 103), definitions (Section 200), and 

requirements for an inspection plan (Section 302). Monitoring and recordkeeping requirements 

are contained in various provisions in Section 400 and 500. 

Effects on Emissions 

The staff report does not specify the expected emission reductions due to the implementation of 

this rule but states that there is a 0.1 tons per day emission reduction commitment in the SIP for 

the Control Measure. 

Rule Evaluation 

Generally, SIP rules must be enforceable (see section 110(a) of the Act), must require 

Reasonably Available Control Technology (RACT) for major sources in nonattainment areas 

(see sections 182(b)(2) and 182(f)), and must not relax existing requirements (see sections 110(l) 

and 193). In addition, Section 172(c)(1) of the Clean Air Act (CAA) requires nonattainment 

areas to implement all reasonably available control measures (RACM), including such reductions 

in emissions from existing sources in the area as may be obtained through the adoption, at a 

minimum, of reasonably available control technology (RACT), as expeditiously as practicable. 
2 

The PCAPCD regulates ozone nonattainment areas (40 CFR 81), thus, submitted Rule 242 must 

fulfill RACT and RACM requirements1. 

Guidance and policy documents that we used to define specific RACT, RACM and 

enforceability requirements include the following: 

• Issues Relating to VOC Regulation, Cutpoints, Deficiencies, and Deviations (the "Blue 

Book"), US EPA, OAQPS (May 25, 1988). 

• EPA Region IX’s Guidance Document for Correcting Common VOC and Other Rule 

Deficiencies (August 21, 2001, the “Little Bluebook”). 

• 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); 57 FR 18070 (April 

28, 1992). 

• State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for 

the Implementation of Title I of the Clean Air Act Amendments of 1990 (the "NOX

Supplement to the General Preamble"), US EPA, 57 FR 55620 (November 25, 1992). 

• Clean Air Fine Particle Implementation Rule, 72 FR 20586 (April 25, 2007) 

• U.S. EPA. Alternative Control Techniques Document – NOx Emissions from Stationary 

Reciprocating Internal Combustion Engines. EPA-453/R-93-032, July 1993 

http://www.epa.gov/ttnnaaqs/ozone/ctg_act/199307_nox_epa453_r-93-

032_internal_combustion_engines.pdf

• California Air Resources Board. Determination of Reasonably Available Control 

Technology and Best Available Retrofit Control Technology for Stationary Spark-Ignited 

Internal Combustion Engines. November 2001 

http://www.arb.ca.gov/ractbarc/rb-iceall.pdf. 

The 2006 RACT SIP Update Analysis Staff Report submitted to EPA on July 11, 2007 states that 

there are no major sources subject to this Rule. On a phone call with John Finnell from the 

PCAPCD on March 21, 2011, we confirmed that there are no sources subject to this rule that 

exceed the major source threshold (25 tpy). Thus, Rule 242 is not required to meet RACT for 

NOx and at this time we are not making a determination of its ability to implement RACT. 

Nonetheless, we note that there are multiple rules for air districts in California that have more 

stringent emissions limits, including El Dorado County AQMD Rule 233, Sacramento 

Metropolitan AQMD Rule 412 and San Joaquin Valley APCD Rule 4702. Additionally, the 

ARB RACT and BARCT Determination (November 2001) suggests more stringent limits as 

RACT. 

CAA §172(c)(1) requires nonattainment areas to implement all reasonably available control 

measures, including such reductions in emissions from existing sources in the area as may be 

obtained through the adoption, at a minimum, of RACT, as expeditiously as practicable. IC 

engines can emit direct PM2.5, as well as SOx, which is a precursor to PM2.5, and NOx, which is 

 

1

PCAPCD also regulates a nonattainment area under the 2006 24-Hour PM2.5 National Ambient Air Quality 

Standard (NAAQS). 40 C.F.R. § 81.305 (2010). By December 14, 2012, California must submit a revision to the 

State Implementation Plan (SIP) for this nonattainment area that provides for, among other things, implementation 

of all RACM as expeditiously as practicable (including RACT for existing sources). CAA § 172(a)(2)(A), (b) & 

(c)(1), 74 FR 58689 (Nov. 13, 2009). EPA will take action on this RACM demonstration in a separate rulemaking. 
3 

a precursor to both PM2.5 and ozone. Therefore, PCAPCD must implement RACM for boilers if 

those measures will advance attainment of the National Ambient Air Quality Standard (NAAQS) 

for PM2.5 or ozone, when considered collectively with other reasonable measures. Additional 

control measures may be required pursuant to CAA §172(c)(1) if both: (1) additional measures 

are reasonably available; and (2) these additional reasonably available measures will advance 

attainment in the area when considered collectively. In separate rulemakings, EPA will take 

action on the State’s RACM demonstration for PM2.5 and ozone based on an evaluation of the 

control measures submitted as a whole and their overall potential to advance the applicable 

attainment dates in the District. See 40 CFR §§ 51.1010, 51.912(d). Nonetheless, we note that the 

current version of Rule 242 does not require certain control measures for IC engines in the 

PCAPCD that appear to be "reasonably available" considering technological and economic 

feasibility, for the reasons cited above. 

Recordkeeping and other compliance provisions in the rule ensure that the requirements are 

adequately enforceable. Lastly, since there is currently no rule in the SIP that regulates this 

source category for PCAPCD, the emission limitations in the submitted rule strengthen the SIP. 

We propose to determine that our approval of the submittal would comply with CAA sections 

110(l) and 193, because the proposed SIP revision would not interfere with the on-going process 

for ensuring that requirements for RFP and attainment of the NAAQS are met, and the submittal 

strengthens the SIP as there is no rule for this category currently in the SIP and would insure 

equivalent or greater emission reductions of NOx. 

Suggested Rule Improvements 

Although not currently basis for rule disapproval, EPA recommends that the PCAPCD lower 

emission limits in Rule 242 to be consistent with South Coast Rule 1110.2 (amended July 9, 

2010) ) and analogous rules in other areas. 

Recommendation 

EPA staff recommends approval of PCAPCD Submitted Rule 242 for incorporation into the 

California Applicable SIP. 

Other References 

1. Submitted Rule 242 

2. Rule 242 Staff Report, dated April 10, 2003 

3. 2006 RACT SIP Update Analysis Staff Report 
PLACER COUNTY 

AIR POLLUTION CONTROL DISTRICT

2006 RACT SIP UPDATE ANALYSIS 

STAFF REPORT

AN ANALYSIS OF REASONABLY 

AVAILABLE CONTROL TECHNOLOGY TO 

UPDATE THE 8-HOUR OZONE STATE 

IMPLEMENTATION PLAN FOR PLACER 

COUNTY

August 10, 2006
This Page Intentionally Left Blank 
TABLE OF CONTENTS 

TITLE PAGE

INTRODUCTION 5 

REASON FOR THIS ANALYSIS 5 

ACTION REQUESTED BY U.S. EPA 6 

ANALYSIS 

DISTRICT PLANNING HISTORY 6 

PART 1 – RACT STANDARDS 7 

PART 2 – NEGATIVE DECLARATIONS 9 

PART 3 – SIP APPROVAL STATUS 11 

PART 4 – SUMMARY AND CONCLUSIONS 17 

APPENDIX: 

Table A - CTG Rule Analysis Table with Rule 19 

Categories As Listed in U.S. EPA Letter to

CARB, 4/4/06 
This Page Intentionally Left Blank 
2006 RACT SIP Update Analysis Staff Report 

August 10, 2006 

Page 5 

INTRODUCTION

Placer County is located in northern California, bordering Sacramento County to the west and the 

State of Nevada on the east. Air quality attainment planning is under the jurisdiction of the Placer 

County Air Pollution Control District (District). Elevations range from near sea level in the 

western portion of the County to 9,000 feet in the mountains of the Sierras. Placer County is the 

only county in the state that is divided into three different air basins: the Sacramento Valley Air 

Basin (SVAB); the Mountain Counties Air Basin (MCAB); and the Lake Tahoe Air Basin (LTAB). 

Each air basin has its own meteorological and geographic conditions. Generally, the 

Mediterranean climate in SVAB has summers that are hot and dry with temperatures usually in 

the 90s. These hot and dry summers are conducive to ozone formation. Prevailing winds from 

the west transport ozone from the San Francisco Bay Area and the Sacramento Valley into the 

foothill and mountain areas.

The portions of Placer County in SVAB and MCAB are included in the Sacramento Federal 

Ozone Non-Attainment Area (SFONA), which has been designated as “serious” non-attainment 

for the 8-hour ozone National Ambient Air Quality Standard (NAAQS). Before the U.S. 

Environmental Protection Agency (U.S. EPA) posted new 8-hour ozone designations and nonattainment classifications in June 2004, the SFONA was a “severe” non-attainment area for the 

1-hour ozone NAAQS. Although the U.S. EPA revoked the 1-hour ozone NAAQS, the SFONA 

still remains subject to control measure commitments that applied under the 1-hour ozone 

NAAQS. Therefore, the District is responsible for implementing emission standards and other 

requirements mandated by the Federal Clean Air Act. 

REASON FOR THIS ANALYSIS

Sections 182(b)(2) and 182(f) of the Federal Clean Air Act require ozone non-attainment areas 

to implement Reasonably Available Control Technology (RACT) for sources that are subject to 

Control Techniques Guideline (CTG) documents issued by U.S. EPA and for “Major Sources” of 

Volatile Organic Compounds (VOCs) and Oxides of Nitrogen (NOx), which are ozone 

precursors. RACT requirements are included in the Clean Air Act to assure that significant 

source categories at Major Sources are controlled to a “reasonable” extent, but not necessarily 

to Best Available Control Technology (BACT) or Maximum Achievable Control Technology” 

(MACT) levels which are expected of new sources. 

U.S. EPA defines RACT as the lowest emission limitation that a particular source is capable of 

meeting by the application of technology (i.e., devices, systems, process modification, or other 

apparatus or techniques that reduce air pollution) that is reasonably available considering 

technological and economic feasibility. 

According to the U.S. EPA’s Final Rule to Implement the 8-Hour Ozone NAAQS (70

FR 71612, November 29, 2005) areas classified as moderate non-attainment or higher must 

submit a demonstration that their current rules fulfill 8-hour ozone RACT for all CTG categories 

and all Major, non-CTG Sources as a revision to their State Implementation Plan (SIP). States 

can demonstrate that RACT is being met with either a new RACT determination or a certification 

that previously required RACT controls represent RACT for 8-hour ozone. Areas may rely on 

previous analyses written for 1-hour ozone plans and U.S. EPA guidance documents. The RACT 

SIP submittal is in addition to the area’s 8-hour Ozone Attainment Demonstration Plan, which 

will also be a SIP submittal. The RACT SIP analysis must be submitted to U.S. EPA by 

September 15, 2006. The last RACT SIP update by the District was completed in 1997. 
2006 RACT SIP Update Analysis Staff Report 

August 10, 2006 

Page 6 

ACTION REQUESTED BY U.S. EPA

On March 9, 2006 and April 4, 2006, Andrew Steckel, U.S. EPA Office Rulemaking Chief, sent 

request letters to the California Air Resources Board (CARB). The letters concern District 

requirements and outlined a possible RACT SIP submittal strategy to determine whether RACT 

requirements have been met. District activities performed as a part of this analysis are as 

follows: 

Part 1 RACT Standards - Identify all District rules subject to the U.S. EPA Control 

Techniques Guidelines (CTG) source categories within the District and determine if they 

meet RACT standards. 

Part 2 Negative Declarations - Identify all CTG categories for which there are no 

facilities in the District, and submit Negative Declarations stating that there are no such 

facilities.

Part 3 SIP Approval Status – Identify all District rules subject to the U.S. EPA CTG 

source categories within the District and determine if they meet RACT standards. 

Part 4 Summary and Conclusions - Summarize the above processes that the District 

used to: (1) determine that the District regulations fulfill RACT, (2) determine Negative 

Declarations needed for certain CTG categories, and (3) determine which District rules 

need to be submitted to U.S. EPA as revision to the SIP. 

The District was requested to prepare a complete RACT SIP update analysis, covering Major 

Sources, non-Major Sources, and non-CTG Major Sources. U.S. EPA requires the District’s 

submittal by September 15, 2006. In addition, the District is required to implement an 8-hour 

Ozone Demonstration Plan no later than the beginning of the first ozone season or portion 

thereof that occurs 30 months after the above submittal date. This would be March 15, 2009. 

Since Placer County has a full year ozone season, the required implementation date for the 

District will be January 1, 2009. Note that the implementation date for any source operating under 

a Title V permit, pursuant to 40 CFR Part 70, would be governed by the requirements of that 

permit. This staff report relates to the September 15, 2006 submittal.

ANALYSIS

District Planning History

To improve the air quality in Placer County and move the region towards attainment of the 

NAAQS, the District has prepared and adopted several air quality attainment plans since 1991. 

The following table summarizes the District’s attainment plans. The District has also adopted 

over 100 new rules and amendments to meet the commitments in these attainment plans. The 

air quality in Placer County has greatly improved over the past several years as the District has 

adopted air quality plans and regulations. In a continuation of the District’s strategy for achieving 

the NAAQS, the District is working with other air districts in SFONA to submit an 8-hour ozone 

attainment demonstration plan to U.S. EPA by June 15, 2007, as specified by federal 

requirements.

The planning history is provided to show that District rules and regulations have been continually 

under review and have been updated on an ongoing basis since 1992 to incorporate new 

regulatory measures for emission sources or to amend existing rules to increase the stringency of 

the control measures, in keeping with technology improvements. These reviews and updates 

have been mandated by State and Federal air quality planning requirements. Since the previous 

RACT SIP analysis was completed in 1997, a number of rules were adopted or updated. 
2006 RACT SIP Update Analysis Staff Report 

August 10, 2006 

Page 7 

District Ozone Planning History

Title Board Adoption

1991 Placer County Air Quality Attainment Plan March 1992 

1994 Ozone Attainment Demonstration Plan December 1994 

1997 Triennial Progress Report July 1998 

1999 Sacramento Area Regional Milestone Report* April 2000 

2000 Triennial Progress Report April 2001 

2002 Sacramento Area Regional Milestone Report* May 2003 

2003 Triennial Progress Report October 2005 

Sacramento Regional Non-attainment Area 8-Hour Ozone 

Rate-of-Progress Plan 

February 2006 

* A regional progress report that does not require Board adoption 

Part 1 – RACT Standards: Identify all District rules subject to the U.S. EPA CTG source 

categories within the District and determine if they meet RACT standards.

This District analysis compared the current Prohibitory Rules (Regulation 2 in the District Rule 

Book) to current U.S. EPA guidance standards for emission control measure. The purpose of 

this work was to: (1) determine if the District had an adopted rule for the source category, (2) 

determine if the rule’s control measures satisfied the requirements of the U.S. EPA’s control 

measure standard, and (3) determine if a new rule will need to be adopted for existing emission 

sources. The standards compared were Control Techniques Guidelines (CTG) and Alternate 

Control Techniques (ACT) Guidance. CARB’s All Feasible Measures (AFM) have also been 

included by Staff, since a number of the rule categories do not have CTGs and or ACTs. The 

ultimate purpose of this study is the determination by the District of whether the District has 

existing adopted rules that meet or exceed the standards in the current CTGs, ACTs, and AFMs.

To determine if District rules fulfill RACT requirements, Staff used the following guidelines: 

District rules that have been SIP-approved by U.S. EPA are considered to meet RACT 

requirements because U.S. EPA evaluated the rules to determine if they fulfill RACT 

established by CTGs, (ACTs) and U.S. EPA guidelines and policies. Therefore, any EPA 

SIP-approved District rules are said to have met RACT requirements. 

As a non-attainment area for the California ozone standard, the District is required by 

California Health and Safety Code (CH&SC) Sections 40914(a)(2) and 40920.6(a) to 

implement “All Feasible Control Measures” (AFCM) and “Best Available Retrofit Control 

Technology” (BARCT). In general, AFCM and BARCT requirements are more stringent 

than those previously established by CTGs and ACTs. Therefore, District rules that 

implemented AFCM and BARCT are said to fulfill RACT requirements. 

All CTG emission source categories were compared against existing adopted District 

rules and a finding was made regarding whether the adopted rule met or exceeded the 

applicable CTG RACT requirements or AFM requirements. All ACTs were evaluated to 
2006 RACT SIP Update Analysis Staff Report 

August 10, 2006 

Page 8 

determine whether Major Sources exist in the source category and if so, whether or not 

a District rule satisfying ACT guidelines has been adopted. 

Table A, provided as an Appendix to this report, lists all U.S. EPA source categories requested, 

both Major and non-Major, and the corresponding CTG, ACT, and AFM with details of each rule 

or category. For each listed rule, Table A shows the Staff’s determination if that rule meets 

current RACT requirements. All the adopted rules have been found to satisfactorily meet RACT 

requirements.

Table A shows that there are rule categories listed in the April 4, 2006 U.S. EPA letter for which 

no sources currently exist in the District. The absence of sources of these categories was 

determined by Staff, based on a study of the District permit base, classified phone listings, public 

notices, new business license requests and personal knowledge (See Part 2, below which 

discusses Negative Declarations) Staff also noted that the District has one new non-Major 

Source in a CTG category (Metal Parts and Products) that has no rule at this time. The District 

RACT SIP submittal process will include the requirement that an appropriate rule be written, 

adopted and approved subsequent to this RACT SIP study, but no later than the Placer County 

RACT implementation date of January 1, 2009. 

Table A provides an overview of the relationship between source categories, U.S. EPA CTGS 

and ATCs, CARB AFMs, existing District sources, District Title V sources, and adopted District 

Rules and amendment, and Applicable SIP Approval dates. Individual findings from Table A are 

grouped topically and shown in Tables “B” through “D”.

For Table A, see the Appendix to this report. 

Major Sources: 

The following Table B lists the Major Sources that are currently in the District.

Table B - Major Sources - Placer Air Pollution and Control District

Source Source Category Pollutant Rule No. Rule Title Location / 

Comments

Fiberboard 

Manufacturing VOC 229 Fiberboard 

Manufacturing SierraPine

Ltd.

(Title V) 

Boilers, Steam 

Generators and 

Process Heaters 

NOx 232 Biomass Suspension 

Boilers

Rocklin (Source 

was Major in 

VOC, before 

recent installation

of new controls.) 

Paper and 

Fabrics VOC 230

Plastic Products and 

Materials - Paper 

Treating Operations Formica

Corp. (Title 

V) Boilers, Steam 

Generators and 

Process Heaters 

NOX 241

Boilers at Plastic 

Laminating Mfg. 

Facilities

Rocklin ( Source 

plans to close 

permanently in 

near future) 

Sierra

Pacific

Industries

(Title V) 

Boilers, Steam 

Generators and 

Process Heaters 

NOX 233 Biomass Boilers Lincoln

Rio Bravo 

(Title V) 

Boilers, Steam 

Generators and 

Process Heaters 

NOX 233 Biomass Boilers Lincoln
2006 RACT SIP Update Analysis Staff Report 

August 10, 2006 

Page 9 

Table B - Major Sources - Placer Air Pollution and Control District

Source Source Category Pollutant Rule No. Rule Title Location / 

Comments

Pacific

MDF

Products

(Pending

Title V) 

Factory Coating 

of Flatwood 

Paneling

VOC 238 Factory Coating of 

Flatwood Paneling Rocklin

Pabco dba 

Gladding

MacBean

(Pending

Title V) 

Surface Coating VOC 240 Surface Preparation 

and Cleanup 

Lincoln

All Major Stationary Sources, including Major non-CTG Sources have adopted District rules that 

satisfy RACT requirements. 

Part 2 - Negative Declarations: Identify all CTG categories for which there are no facilities 

in the District, and submit Negative Declarations stating that there are no such 

facilities.

Background

Due to the designation of portions of Placer County as “moderate” or above non-attainment for 

ozone, Sections 182(b)(2) and 182(f) of the Federal CAA require the District to submit a revision 

to the State Implementation Plan (SIP) to implement RACT for each category of Volatile Organic 

Compound (VOC) or Nitrogen Oxide (NOx) sources covered by a CTG document and for any 

Major Stationary Source not covered by a CTG document. The Sacramento Valley Air Basin and 

the Mountain Counties Air Basin portions of the District are part of the Sacramento Federal 

Ozone Non-Attainment Area (SFONA) which is designated as “severe” non-attainment for ozone. 

RACT requires that all non-attainment areas classified as “moderate” or above have RACT in 

place for source categories covered by a Control Techniques Guideline (CTG) document and for 

Major Sources that are not subject to a CTG (i.e. a “Major non-CTG Source”). A “Major Source” 

of VOCs or NOx in Placer County is defined as an emission source having a potential to emit of 

25 tons of the pollutant per year. The Air District must adopt the control measures for a source 

category if it has a source of emissions located within the non-attainment area that is subject to a 

CTG. Alternatively, if the finding is made that there are no existing sources that emit the 

designated pollutants in its area subject to a RACT requirement, the District may make a 

negative declaration to this effect and consequently the requirement to adopt a rule for those 

sources is not applicable. This process is called “Negative Declaration” . 

The District is required to submit Negative Declarations for all CTG categories for which there are 

no sources above the CTG recommended threshold, even if such negative declarations were 

made for an earlier SIP. This is necessary since there may be sources in the non-attainment 

area that previously did not exist. Also, if the boundaries of the non-attainment area have 

expanded, there may be sources in the new portion of the non-attainment area which should not 

be overlooked.

The District must also submit a Negative Declaration to certify that there are no Major non-CTG 

Sources in the non-attainment area. 

The Negative Declaration must go through the same public review requirements as any other SIP 

submittal.
2006 RACT SIP Update Analysis Staff Report 

August 10, 2006 

Page 10 

Negative Declaration Findings and Staff Recommendations 

The District Staff reviewed permit databases, SIC codes, business license applications, 

telephone listings, other source data and the emission inventory for its Federal Clean Air Plan, 

and has determined that there are no Major Stationary sources or emitting facilities for the CTG 

categories listed below in Table C.

Placer County Air District Board Resolutions #97-33 and #97-34 stated that there were no Major 

Sources to regulate for VOC or NOx in a total of twelve source categories (7 VOC source 

categories, 5 NOx source categories). The negative findings were made as part of a RACT SIP 

analysis following the issuance by U.S. EPA of deficiency findings in 1994 for all of California’s 

15% Rate-of-Progress Plans, including that of Placer County. The Negative Declarations for 

these twelve rule categories were later approved by the U.S. EPA in Federal Register Notice FR 

50766, September 23, 1998. The U.S. EPA commented that a thirteenth Negative Declaration 

category (Synthetic Organic Chemical Manufacturing Industry - Distillation) needed to be adopted 

by the District Board.

Staff has reaffirmed that there are no existing Major Sources of emissions in these twelve (12) 

rule categories and the Negative Declarations for both new and affirmed rule categories should 

be submitted to U.S. EPA for approval. The twelve Negative Declaration rule categories, 

including dates approved, are listed in the following Table C. Seventeen (17) other rule 

categories, including the “Synthetic Organic Chemical Manufacturing Industry – Distillation” 

category noted by U.S. EPA, were found to have no existing Major Sources in the District. The 

District does not anticipate Major Sources in these rule categories in the future. Staff will submit 

these twenty-nine (29) Negative Declarations for public comment, and District Board 

consideration and approval. If approved by the District Board the Negative Declarations will be 

submitted to CARB for forwarding to U.S. EPA as requested revisions to the State 

Implementation Plan.

 Table C - District Negative Declaration Submittal Requirements 

Rule Title Date

Submitted 

Board

Resolution Pollutant

 U.S. EPA Source Categories That Need to Have Previous Negative Declarations Affirmed 

1 Aerospace 10/9/97 97-33 VOC

2

Plastic Parts Coating - Business 

Machines 10/9/97 97-33 VOC

3 Plastic Parts Coating - Other 10/9/97 97-33 VOC

4 Ships 10/9/97 97-33 VOC

5

Synthetic Organic Chemical 

Manufacturing - Batch Plants 10/9/97 97-33 VOC

6

Synthetic Organic Chemical 

Manufacturing - Reactors 10/9/97 97-33 VOC

7 Utility Boilers 10/9/97 97-34 NOx

8 Cement Kilns 10/9/97 97-34 NOx

9 Glass Treatment 10/9/97 97-34 NOx

10 Iron and Steel Manufacturing 10/9/97 97-34 NOx

11 Nitric and Adipic Acid 

Manufacturing 10/9/97 97-34 NOx
2006 RACT SIP Update Analysis Staff Report 

August 10, 2006 

Page 11 

 Table C - District Negative Declaration Submittal Requirements 

Rule Title Date

Submitted 

Board

Resolution Pollutant

12 Industrial Waste Water Treatment 10/9/97 97-33 VOC

Other U.S. EPA Source Categories That Need to Have First-Time Negative Declarations 

1

Synthetic Organic Chemical 

Manufacturing, Distillation N/A N/A VOC

2 Large Appliances N/A N/A VOC

3 Magnet Wire N/A N/A VOC

4 Metal Furniture N/A N/A VOC

5 Traffic Marking N/A N/A VOC

6 Natural Gas/Gasoline Plants N/A N/A VOC

7 Refineries N/A N/A VOC

8 Bakeries N/A N/A VOC

9 Ethylene Oxide N/A N/A VOC

10 Fertilizer N/A N/A VOC

11 Ink and Paint Manufacturing N/A N/A VOC

12 Leather Tanning N/A N/A VOC

13 Pesticides N/A N/A VOC

14 Pharmaceutical Products N/A N/A VOC

15 Polyester Resin (Manufacturing) N/A N/A VOC

16 Rubber Tires N/A N/A VOC

17 Sulfuric Acid N/A N/A VOC

Part 3 - SIP Approval Status: Identify all District rules subject to the U.S. EPA CTG source 

categories within the District and determine if they meet RACT standards.

The current status of each of the thirty-two (32) District prohibitory rules that previously were 

adopted for CTG/ACT/AFM source categories was reviewed and is displayed in the following 

tables. This SIP status study was necessary in order to determine which rules, if any, needed to 

be submitted or re-submitted for SIP approval by U.S. EPA. The following lists the SIP status 

categories that were examined: 

a. Rules that were submitted and approved for SIP. 

b. Rules that were submitted and approved for SIP and that must be re-submitted 

for approval because of amendments that post-dated the SIP approval. 

c. Rules that have not yet been submitted for SIP approval. 

d. Rules that were submitted for SIP approval and which are awaiting approval. 

(None were in this category).

Staff examined the adoption dates of the above rules, and the dates of the latest amendments, if 

any. Then the date of SIP approval was compared with the rule adoption histories. Any rule that 

was last amended six months to a year before the Federal Register SIP approval date was 

considered to not need SIP resubmittal. In some cases the dates were close and Staff 

researched the SIP approval records to determine if the rule, as currently amended was the one 

that was examined and approved by U.S. EPA. 
2006 RACT SIP Update Analysis Staff Report 

August 10, 2006 

Page 12 

Table D-1 - District Rule History (VOC and NOx) and SIP Approval Status:

Table D-1 lists the adoption history of the District rules (VOC and NOx) and their SIP approval 

status. They are listed by rule number. Rule 227 (Petroleum Dry Cleaning Operations) is omitted 

since there are no sources in the District. Dry Cleaners in the District now use Perchloroethylene 

(PERC) solvent, which is exempted from the VOC classification. PERC regulations are included 

in a MACT standard. The right hand column indicates if the District must re-submit any existing 

rule that was amended after the latest date of SIP approval, in order to ensure that the review will 

be based upon the most current amendment of that rule. Staff recommends that these SIP 

submittals be found exempt from the California Environmental Quality Act (CEQA). The 

proposed submittals are exempt from CEQA as per Title 14, Calfornia Code of Regulations, 

Chapter 3, Article 19, Section 15308, Actions by Regulatory Agencies for the Protection of the 

Environment.

Table D-1 - District Rule History (VOC and NOx) and SIP Approval Status

Rule

No.

Rule Title 

Pollutant

Controlled

CTG

Source

?

Date

Adopted

Date Last 

Amended

SIP

Approval - 

FR Citation 

New SIP 

Approva

l

Require

d?

206 Incinerator

Burning NOx No 11/12/74 11/3/94 11/15/78 43 

FR 53035 Y

209 Fossil Fuel-Steam 

Facility 

NOx No 11/12/74 5/24/77 6/14/78 - 43 

FR 25684 N

212 Storage of 

Organic Liquids VOC No 5/24/77 6/19/97 5/6/96 - 61

FR 20145 Y

213

Gasoline Transfer 

into Stationary 

Storage

Containers

VOC Yes 6/19/79 10/19/93 4/30/97 - 62 

FR 23365 N

214

Transfer of 

Gasoline into 

Vehicle Fuel 

Tanks 

VOC Yes 6/19/79 4/21/81 4/30/97 - 62 

FR 23365 N

215

Transfer of 

Gasoline into 

Tank Trucks, 

Trailers and 

Railroad Tank 

Cars at Loading 

Facilities

VOC Yes 6/19/79 Not

amended

5/6/96 - 61 FR 

20145 Y

216

Organic Solvent 

Cleaning and 

Degreasing

Operations

VOC Yes 6/19/79 12/11/03 4/30/96 - 61 

FR 18962 Y

217

Cutback and 

Emulsified Asphalt 

Paving Materials 

VOC Yes 6/19/79 9/25/90 4/30/97 - 62 

FR 23365 N

218 Architectural

Coatings VOC No 6/19/79 12/13/01 7/18/96 - 61 FR 37390 Y

219 Organic Solvents VOC Yes 6/19/79 5/20/85 4/30/97 - 62 

FR 23365 N
2006 RACT SIP Update Analysis Staff Report 

August 10, 2006 

Page 13 

Table D-1 - District Rule History (VOC and NOx) and SIP Approval Status

Rule

No.

Rule Title 

Pollutant

Controlled

CTG

Source

?

Date

Adopted

Date Last 

Amended

SIP

Approval - 

FR Citation 

New SIP 

Approva

l

Require

d?

222 Reduction of 

Animal Matter N/A N/A 6/19/79 Not

amended

4/30/97 - 62 

FR 23365 N

223 Metal Can Coating VOC Yes 9/25/90 10/6/94 3/23/95 - 60 

FR 15241 N

225 Wood Fired 

Appliances N/A N/A 6/17/86 Not

amended

4/30/97 - 62 

FR 23365 N

226

Sulfur Content of 

Fuels (Tahoe 

Only) 

N/A N/A 6/19/79 10/19/93 4/30/97 - 62 

FR 23365 N

229 Fiberboard 

Manufacturing VOC No 6/28/94 Not

amended

6/8/01 - 66 FR 

30815 N

230

Plastic Products 

and Materials - 

Paper Treating 

Operation

VOC Yes 6/28/94 Not

amended

12/14/94 - 59 

FR 64336 N

231

Industrial,

Institutional, and 

Commercial

Boilers, Steam 

Generators, and 

Process Heaters 

NOx No 10/17/94 10/9/97 Not Submitted Y

232

Biomass

Suspension

Boilers

NOx No 10/6/94 12/9/99 Not Submitted Y

233 Biomass Boilers NOx No 10/6/94 Not

amended

4/30/96 - 61 

FR 18959 N

234

Automotive

Refinishing

Operations

VOC Yes 11/3/94 4/9/98 Not submitted Y

235 Adhesives VOC No 6/8/95 4/8/04 7/18/96 - 61 

FR 37390 Y

236

Wood Products 

Coating

Operations

VOC Yes 11/3/94 8/14/97 4/30/96 - 61 

FR 18962 Y

237 Municipal Landfills VOC No 11/3/94 10/9/03 Not submitted Y

238 Factory Coating of 

Flatwood Paneling VOC Yes 11/3/94 2/18/04 2/12/96 - 61 

FR 5288 Y

239 Graphic Arts 

Operations VOC Yes 11/3/94 4/8/04 11/13/98 63 

FR 63410 Y

240

Surface

Preparation and 

Cleanup

VOC No 6/8/95 12/11/03 Not submitted Y

241

Boilers at Plastic 

Laminate

Manufacturing

Facilities

NOx No 4/8/99 Not

Amended Not submitted Y

242

Stationary Internal 

Combustion

Engines

NOx No 4/10/03 Not

Amended Not submitted Y
2006 RACT SIP Update Analysis Staff Report 

August 10, 2006 

Page 14 

Table D-1 - District Rule History (VOC and NOx) and SIP Approval Status

Rule

No.

Rule Title 

Pollutant

Controlled

CTG

Source

?

Date

Adopted

Date Last 

Amended

SIP

Approval - 

FR Citation 

New SIP 

Approva

l

Require

d?

243 Polyester Resin 

Operations VOC Yes 4/10/03 Not

Amended Not submitted Y

244 Semiconductor

Operations VOC No 2/9/95 Not

Amended

7/25/96 - 61 

FR 38571 N

246 Natural Gas-Fired 

Water Heaters NOx No 6/19/97 Not

Amended Not submitted Y

250 Stationary Gas 

Turbines NOx No 10/17/94 Not

Amended

8/23/95 - 60 

FR 43713 N

District Rules Which Were SIP- Approved and Do Not Require Re-Submittal: 

Table D-2 lists rules that were submitted for SIP after their latest amendment date and approved. 

These fourteen (14) rules have been incorporated into the SIP and will not require resubmittal for 

SIP at this time. 

Table D-2 - District Rules Which Were SIP- Approved and Do Not Require ReSubmittal

Rule

No.

Rule Title 

Pollutant

Controlled

CTG

Source

?

Date

Adopted

Date Last 

Amended

SIP

Approval 

- FR 

Citation

New SIP 

Approval 

Required

?

209 Fossil Fuel-Steam 

Facility 

NOx No 11/12/74 5/24/77

6/14/78 -

43 FR 

25684

N

213

Gasoline Transfer 

into Stationary 

Storage

Containers

VOC Yes 6/19/79 10/19/93

4/30/97 - 

62 FR 

23365

N

214

Transfer of 

Gasoline into 

Vehicle Fuel 

Tanks 

VOC Yes 6/19/79 4/21/81

4/30/97 - 

62 FR 

23365

N

217

Cutback and 

Emulsified Asphalt 

Paving Materials 

VOC Yes 6/19/79 9/25/90

4/30/97 - 

62 FR 

23365

N

219 Organic Solvents VOC Yes 6/19/79 5/20/85

4/30/97 - 

62 FR 

23365

N

222 Reduction of 

Animal Matter N/A N/A 6/19/79 Not

Amended

4/30/97 - 

62 FR 

23365

N

223 Metal Can 

Coating VOC Yes 9/25/90 10/6/94

3/23/95 - 

60 FR 

15241

N

225 Wood Fired 

Appliances N/A N/A 6/17/86 NotAmended

4/30/97 - 

62 FR N
2006 RACT SIP Update Analysis Staff Report 

August 10, 2006 

Page 15 

Table D-2 - District Rules Which Were SIP- Approved and Do Not Require ReSubmittal

Rule

No.

Rule Title 

Pollutant

Controlled

CTG

Source

?

Date

Adopted

Date Last 

Amended

SIP

Approval 

- FR 

Citation

New SIP 

Approval 

Required

?

23365

226

Sulfur Content of 

Fuels (Tahoe 

Only) 

N/A N/A 6/19/79 10/19/93

4/30/97 - 

62 FR 

23365

N

229 Fiberboard 

Manufacturing VOC No 6/28/94 Not

Amended

6/8/01 - 

66 FR 

30815

N

230

Plastic Products 

and Materials - 

Paper Treating 

Operation

VOC Yes 6/28/94 Not

Amended

12/14/94 - 

59 FR 

64336

N

233 Biomass Boilers NOx No 10/6/94 Not

Amended

4/30/96 - 

61 FR 

18959

N

244 Semiconductor

Operations VOC No 2/9/95 Not

Amended

7/25/96 - 

61 FR 

38571

N

250 Stationary Gas 

Turbines NOx No 10/17/94 Not

Amended

8/23/95 - 

60 FR 

43713

N

District Rules Which Were SIP-Approved and Now Require Re-Submittal Because 

of Amendments:

Table D-3 lists the nine (9) adopted District rules that were approved for SIP previously, and that 

must now be re-submitted for SIP because of amendments that post-dated the U.S. EPA’s SIP 

approval.

Table D-3 - District Rules Which Were SIP-Approved and Require Re-Submittal 

Because of Recent Amendments

Rule

No.

Rule Title 

Pollutant

Controlled

CTG

Source?

Date

Adopted

Date Last 

Amended

SIP

Approval - 

FR

Citation

New SIP 

Approval 

Required

?

206 Incinerator Burning NOx No 11/12/74 11/3/94 11/15/78 43 

FR 53035 Y

212 Storage of Organic 

Liquids VOC No 5/24/77 6/19/97 5/6/96 - 61

FR 20145 Y

215

Transfer of 

Gasoline into Tank 

Trucks, Trailers 

and Railroad Tank 

Cars at Loading 

Facilities

VOC Yes 6/19/79 Not

Amended

5/6/96 - 61 

FR 20145 Y

216 Organic Solvent 

Cleaning and VOC Yes 6/19/79 12/11/03 4/30/96 - 61 FR 18962 Y
2006 RACT SIP Update Analysis Staff Report 

August 10, 2006 

Page 16 

Table D-3 - District Rules Which Were SIP-Approved and Require Re-Submittal 

Because of Recent Amendments

Rule

No.

Rule Title 

Pollutant

Controlled

CTG

Source?

Date

Adopted

Date Last 

Amended

SIP

Approval - 

FR

Citation

New SIP 

Approval 

Required

?

Degreasing

Operations

218 Architectural

Coatings VOC No 6/19/79 12/13/01 7/18/96 - 61 

FR 37390 Y

235 Adhesives VOC No 6/8/95 4/8/04 7/18/96 - 61 

FR 37390 Y

236 Wood Products 

Coating Operations VOC Yes 11/3/94 8/14/97 4/30/96 - 61 

FR 18962 Y

238 Factory Coating of 

Flatwood Paneling VOC Yes 11/3/94 2/18/04 2/12/96 - 61 

FR 5288 Y

239 Graphic Arts 

Operations VOC Yes 11/3/94 4/8/04 11/13/98 63 

FR 63410 Y

District Rules Which Need to be Submitted for SIP Approval: 

Table D-4 lists nine (9) newer rules which need to be submitted to the U.S. EPA for first-time SIP 

approval.

Table D-4 – District Rules Which Need to be Submitted for SIP Approval 

Rule

No.

Rule Title 

Pollutant

Controlled

CTG

Source

?

Date

Adopted

Date Last 

Amended

SIP

Approval 

- FR 

Citation

SIP

Approval 

Required

?

231

Industrial,

Institutional, and 

Commercial Boilers, 

Steam Generators, 

and Process 

Heaters

NOx No 10/17/94 10/9/97 None Y

232 Biomass

Suspension Boilers NOx No 10/6/94 12/9/99 None Y

234

Automotive

Refinishing

Operations

VOC Yes 11/3/94 4/9/98 None Y

237 Municipal Landfills VOC No 11/3/94 10/9/03 None Y

240 Surface Preparation 

and Cleanup 

VOC No 6/8/95 12/11/03 None Y

241

Boilers at Plastic 

Laminate

Manufacturing

Facilities

NOx No 4/8/99 Not

Amended None Y

242 Stationary Internal 

Combustion Engines NOx No 4/10/03 NotAmended None Y
2006 RACT SIP Update Analysis Staff Report 

August 10, 2006 

Page 17 

Table D-4 – District Rules Which Need to be Submitted for SIP Approval 

Rule

No.

Rule Title 

Pollutant

Controlled

CTG

Source

?

Date

Adopted

Date Last 

Amended

SIP

Approval 

- FR 

Citation

SIP

Approval 

Required

?

243 Polyester Resin 

Operations VOC Yes 4/10/03 Not

Amended None Y

246 Natural Gas-Fired 

Water Heaters NOx No 6/19/97 Not

Amended None Y

Part 4 – Summary and Conclusions 

New RACT Rules to Be Adopted - Details of the process Staff used to evaluate the Applicable 

SIP status of the District’s rules that satisfy Major Source RACT requirements are described in 

Part 1, above. The Staff comparison of all current District rules to the standards of applicable 

CTGs, ACTs, and AFMs found that the District has adopted rules corresponding to RACT source 

categories and that satisfy RACT requirements. Details of the comparison are presented in Table 

A, of the Appendix. One RACT category, Metal Parts and Products, has non-Major emission 

source(s), but no District Rule has been adopted. Staff recommends that the Board direct the 

development and adoption of a rule to limit VOC emissions from the coating of metal parts and 

products. Although there are no Major Sources in this source category, there are non-Major 

Sources of VOC that would be subject to a new rule establishing RACT requirements. The rule 

should be implemented by January 1, 2009, and should be adopted as a revision to the SIP and 

submitted to U.S. EPA. 

Negative Declarations - (Part 2) Based on Staff review of District sources, twelve (12) RACT 

source categories were identified where previous Negative Declarations (7 VOC, 5 NOx) of no 

existing Major Stationary Sources to regulate may be reaffirmed. The Negative Declaration of no 

existing Major Stationary VOC Sources may be made for seventeen (17) additional VOC RACT 

source categories. In addition, the Staff analysis found that there were no Major Stationary 

Sources, including Major non-CTG Sources, for which District rules satisfying RACT had not 

been adopted. Staff recommends that the District Board make the declaration that no existing 

Major Stationary Sources exist for VOC or NOx in Placer County in the twenty-nine (29) specified 

RACT source categories and that no Major non-CTG Sources exist for which RACT measures 

have not been adopted.. Staff further recommends that these SIP submittals be found exempt 

from the California Environmental Quality Act (CEQA) per Title 14, California Code of 

Regulations, Chapter 3, Article 19, Section 15308, Actions by Regulatory Agencies for the 

Protection of the Environment.

SIP Status – (Part 3) Rule adoption, amendment, and SIP approval history for thirty-two (32) 

District prohibitory rules was reviewed and analyzed. Fourteen (14) SIP-approved rules do not 

require re-submittal for SIP status. Nine (9) previously SIP approved rules must be re-submitted 

because of amendments that post-dated the original approvals. Nine (9) newer District rules 

were adopted and need to be submitted for first-time approval and revision of the SIP. Staff 

recommends that the District Board direct and approve the submittal of the specified rules, 

previously adopted by the District Board of Directors, to the U.S. EPA as revisions to the SIP. 

Appendix: Table A – CTG Rule Analysis Table with Rule Categories as Listed in U.S. EPA Letter to 

CARB, 4/4/06 
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APPENDIX

Table A - CTG Rule Analysis Table 

with Rule Categories as Listed in U.S. EPA Letter to CARB, 4/4/06 
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