SACRAMENTO METROPOLITAN 

AIR QUALITY MANAGEMENT DISTRICT 

STAFF REPORT 

Updated Analysis of Reasonably Available Control Technology for the 

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

September 22, 2008 

Prepared by: David Yang 

 Assistant Air Quality Engineer 

 Kevin J. Williams, Ph.D. 

 Program Coordinator 

Reviewed by: Aleta Kennard 

 Program Supervisor 

Approved by: Brigette Tollstrup 

 Division Manager
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 2 

BACKGROUND 

The U.S. Environmental Protection Agency (EPA) published the final Phase 2 Rule to implement 

the 8-hour ozone air quality standard on November 29, 2005 (70 FR 71611). Among the 

requirements of the Phase 2 Rule, a new section was added to the Code of Federal Regulations 

(40 CFR 51.912) that requires the District to submit a revision to the State Implementation Plan 

(SIP) that meets the Reasonably Available Control Technology (RACT) requirements for VOC and 

NOx in accordance with Sections 182(b)(2) and 182(f) of the federal Clean Air Act. This 

requirement is known as the RACT SIP. 

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) of the Clean Air Act require 

the District to implement RACT for: 

• Each category of VOC sources that is covered by a Control Technique Guideline (CTG) 

document issued by EPA; and 

• All major stationary sources of VOC and/or NOx. 

EPA’s designations and classifications for the 8-hour ozone standard were published on April 30, 

2004 (69 FR 23857) and became effective on June 15, 2004. The Sacramento Metropolitan Area 

was classified as a serious nonattainment area, with a deadline of 2013 to attain the standard. The 

major source emissions threshold for areas classified as serious is 50 tons per year of either VOC 

or NOx. 

EPA Region 9 provided guidance for the RACT SIP submittal in a letter from Andrew Steckel dated 

March 9, 2006. The following elements were included in the recommended strategy: 

• Describe efforts to identify all source categories within the District requiring RACT, including 

CTG sources (i.e., covered by an EPA Control Technique Guideline document) and major 

non-CTG sources. 

• Submit negative declarations where there are no facilities (major or minor) within the District 

subject to a CTG. 

• For all categories needing RACT, list the state/local regulation that implements RACT. It 

may also be helpful to list the date EPA approved these regulations as fulfilling RACT. 

• Describe the basis for concluding that the regulations fulfill RACT. Documents useful in 

establishing RACT include CTGs, Alternative Control Technique guidance (ACTs) , 

Maximum Achievable Control Technology (MACT) standards, New Source Performance 

Standards (NSPS), California Suggested Control Measures (SCM) and RACT/Best 

Available Retrofit Control Technology (BARCT) determinations, regulations adopted in other 

Districts, and guidance and rules developed by other state and local agencies. 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 3 

On October 26, 2006, the District’s Board of Directors adopted a revision to the SIP that fulfilled the 

aforementioned federal requirements, and this SIP revision was submitted by the California Air 

Resources Board (CARB) to EPA on July 11, 2007. 

Since that time, EPA has promulgated seven new CTGs. In addition, the air districts of the 

Sacramento Federal Nonattainment Area submitted a letter to CARB in February of 2008 to request 

a voluntary “bump-up” to a classification of “severe” nonattainment, as provided by Section 

181(b)(3) of the federal Clean Air Act. On February 14, 2008, CARB requested that EPA reclassify 

this area to “severe.” It is anticipated the EPA will take action on this request by the end of 2008. A 

reclassification to severe nonattainment will 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. 

The purpose of this staff report is to provide sufficient analysis of the new CTG categories, and of 

sources which will become major sources upon reclassification to severe nonattainment, to 

determine whether the District meets the requirements of RACT. 

RACT ANALYSIS 

The process Staff used to demonstrate compliance with federal RACT requirements consists of the 

following steps: 

• For new CTG source categories for which the District has no applicable rule, determine 

whether the District has sources 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. Appendix A contains the analyses for these CTG source categories. 

• For sources which 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 and/or NOx when all units that emit these pollutants are subject to District rules that 

have been determined to satisfy RACT. Appendix B contains the analyses for these 

sources. 

Staff reviewed the seven new CTGs that have been promulgated by EPA, and determined which 

District rules are applicable to the CTG categories. RACT analyses for the four CTG categories for 

which the District has an applicable rule are included in Appendix A. For the three CTG categories 

for which the District has no applicable rule, Staff reviewed the database of permitted sources, the 

yellow pages, and business listings to determine whether there are any sources in these categories 

in Sacramento County. Staff determined that there are no CTG categories for which the District has 

sources but no applicable rule. Table 1 lists the new CTG categories, the applicable District rules, 

and the SIP status of the rules. 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 4 

Table 1 – New CTG Source Categories 

CTG Category CTG Date 

SMAQMD 

Rule No. 

(Most Recent 

Amendment) SIP Status 

Offset Lithographic and 

Letterpress Printing 

EPA 453/R-06-002 

Sept. 2006 450 (3/23/00) Adopted 12/5/96; Approved 11/13/98 

Flexible Package 

Printing 

EPA 453/R-06-003 

Sept. 2006 450 (3/23/00) Adopted 12/5/96; Approved 11/13/98 

Flat Wood Paneling 

Coatings 

EPA 453/R-06-004 

Sept. 2006 No Sources Not applicable 

Industrial Cleaning 

Solvents 

EPA 453/R-06-001 

Sept. 2006 466 (5/23/02) Adopted 5/23/02; Not yet submitted 

Paper, Film, and Foil 

Coatings 

EPA 453/R-07-003 

Sept. 2007 No Sources Not applicable 

Large Appliance 

Coatings 

EPA 453/R-07-004 

Sept. 2007 No Sources Not applicable 

Metal Furniture Coatings 

EPA 453/R-07-005 

Sept. 2007 451 (10/2/97) Adopted 11/29/83; Approved 1/24/85 

Adopted 9/5/96; No EPA Action 

Staff reviewed the permitting records of sources within the District to compile a list of sources which 

will become major sources of VOC and/or NOx upon reclassification to severe nonattainment. 

These sources were not included in the October 26, 2006 SIP revision, except for Cosumnes Power 

Plant and UC Davis Medical Center, which were included as major sources of NOx but not VOC. A 

bump-up to severe nonattainment will reduce the major source threshold to a potential-to-emit 

exceeding 25 tons per year of either VOC or NOx. Table 2 lists the sources that were not included 

in the October 26, 2006 SIP revision but will become major sources under a bump-up. RACT 

analyses of these sources are included in Appendix B. 

Table 2 – New Major Sources of VOC and NOx within SMAQMD Based on a Threshold of 

25 Tons per Year 

Major Source Major Pollutant(s) 

Cosumnes Power Plant (SMUD) VOC, NOx* 

Grafil NOx 

Sacramento Power Authority NOx 

Silgan Can Company VOC 

UC Davis Medical Center VOC, NOx* 

* These sources were included in the October 26, 2006 SIP revision as major sources of NOx. A 

bump-up to severe nonattainment will make them major sources of VOC, also. 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 5 

Major sources are required to meet RACT for all emission units that emit the pollutant(s) exceeding 

major source thresholds. Staff reviewed the emission units at each of the new major sources and 

determined that all applicable source categories, including those not covered by a CTG, were 

analyzed previously in the October 26, 2006 SIP revision. 

CONCLUSION 

Based on the RACT analyses performed in Appendices A and B, and the previous analyses 

performed for the October 26, 2006 SIP revision, Staff finds that the District has fulfilled the 

requirements of RACT, as applicable to the 8-hour ozone standard, for all CTG source categories 

and for all major sources of VOC and NOx, with the following exceptions: 

• For flexible package 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 VOC. 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 amendments are scheduled for a public hearing on September 25, 2008. Following 

adoption, the amended rule will be submitted for inclusion in the 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 VOC. In addition, the CTG recommends more 

stringent VOC content limits for fountain solutions used by offset lithographic printing 

sources with actual emissions of VOC of at least 15 lb/day (equivalent to 450 lb/month). 

Staff is proposing to correct these RACT deficiencies by amending Rule 450 to require 

mandatory control equipment on presses with potential to emit, prior to controls, of at least 

25 tons/year of VOC and to set more stringent VOC limits, consistent with the CTG 

recommendations, for fountain solutions used by offset lithographic printing sources with 

actual emissions of VOC of at least 450 lb/month. These amendments are scheduled for a 

public hearing on September 25, 2008. Following adoption, the amended rule will be 

submitted for inclusion in the SIP. 

• For metal furniture coating operations, the VOC content limits recommended in the CTG for 

general one-component, extreme high gloss, and extreme performance coatings are more 

stringent than 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 CTG recommends 

90% overall efficiency. Staff is proposing to correct these RACT deficiencies by amending 

Rule 451 to include the CTG-recommended VOC content limits for metal furniture coatings, 

applicable to sources with actual VOC 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 are scheduled for a public hearing on September 25, 2008. 

Following adoption, the amended rule will be submitted for inclusion in the SIP. 

As noted above, the current versions of Rules 450 and 451 do not contain requirements as 

stringent as the CTG recommendations in some instances. However, Staff has determined that no 

sources will be required to modify their operations if the CTG-recommended requirements are 

adopted. Current sources are either below the applicability thresholds or already comply with the 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 6 

CTG requirements. 

The District has no sources in the following CTG categories, based on a review of District permitting 

records, yellow pages, business listings, and the District’s enforcement program for unpermitted 

sources: 

• Flat Wood Paneling Coatings 

• Paper, Film and Foil Coatings 

• Large Appliance Coatings 

ENVIRONMENTAL REVIEW AND COMPLIANCE 

No sources will be required to modify their operations as a result of the commitments proposed in 

this SIP revision. Staff has determined that current sources are either below the applicability 

thresholds of the new requirements or already comply with the new requirements. Therefore, Staff 

has determined that the adoption of these rule commitments is exempt from the California 

Environmental Quality Act (CEQA) under Section 15061(b)(3) of the State CEQA Guidelines 

because it can be seen with certainty that there is no possibility that the activity in question may 

have a significant adverse effect on the environment. 

APPENDICES 

Appendix A: RACT Analysis of New CTG Source Categories 

Appendix B: RACT Analysis of New Major Sources under a Bump-Up to Severe Nonattainment 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 7 

Appendix A 

RACT Analysis of New CTG Source Categories 

CTG Category 

Page 

Number 

Flexible Package Printing 8 

Industrial Cleaning Solvents 11 

Metal Furniture Coatings 15 

Offset Lithographic and Letterpress Printing 19 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 8 

Category: Flexible Package Printing 

EPA RACT Guidance

Control Techniques Guidelines for Flexible Package Printing, EPA 453/R-06-003, September 2006. 

Applicability

The CTG applies to flexible package printing operations, which includes printing on items such as 

bags, pouches, liners, and wraps utilizing paper, plastic, film, aluminum foil, metalized or coated 

paper or film, or any combination of these materials. The CTG provides control recommendations 

for reducing VOC emissions from inks, coatings, adhesives and cleaning materials. The control 

recommendations for inks, coatings, and adhesives apply to printing presses with potential to emit, 

prior to controls, of at least 25 tons/year of VOC. The control recommendations for cleaning 

materials apply to facilities with actual emissions, prior to controls, of at least 15 lb/day of VOC from 

all flexible package printing and cleaning operations. 

RACT Requirements

The CTG recommends two options for reducing emissions from coatings, inks, and adhesives: 

emissions control equipment, and low VOC materials. 

For emissions control equipment, the recommended control levels in the CTG include the following: 

• 65% overall control for a press that was first installed prior to March 14, 1995 and that is 

controlled by an add-on air pollution control device whose first installation date was prior to 

the effective date of the State RACT rule. 

• 70% overall control for a press that was first installed prior to March 14, 1995 and that is 

controlled by an add-on air pollution control device whose first installation date was on or 

after the effective date of the State RACT rule. 

• 75% overall control for a press that was first installed on or after March 14, 1995 and that is 

controlled by an add-on air pollution control device whose first installation date was prior to 

the effective date of the State RACT rule. 

• 80% overall control for a press that was first installed on or after March 14, 1995 and that is 

controlled by an add-on air pollution control device whose first installation date was on or 

after the effective date of the State RACT rule. 

As an alternative to using emission control equipment, the CTG also recommends limits on the 

VOC content of materials that are consistent with an 80% reduction in emissions. The 

recommended VOC content limits are 0.8 kg VOC/kg solids applied or 0.16 kg VOC/kg material 

applied. 

The CTG also recommends work practices to reduce emissions from cleaning materials. These 

recommendations are to: 

• Keep cleaning materials and used shop towels in closed containers, 

• Convey cleaning materials from one location to another in closed containers or pipes. 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 9 

Other Federal Requirements

Subpart FFF of 40 CFR part 60, Standards of Performance for Flexible Vinyl and Urethane Coating 

and Printing (NSPS) specifies either VOC limitations or VOC percent reductions for rotogravure 

printing lines used to print or coat flexible vinyl or urethane products. The NSPS requires either of 

the following: 1) Use inks with VOC content of less than 1.0 kg VOC per kg of ink solids; or 2) 

reduce VOC emissions with a combined capture and control efficiency of 85 percent. 

Subpart KK of 40 CFR part 63 (National Emissions Standards for Hazardous Air Pollutant 

Emissions from the Printing and Publishing Industry) limits hazardous air pollutant (HAP) emissions 

as follows: 

Graphic Arts Operation type: HAP Emissions standard: 

Publication rotogravure printing Limits organic HAP emissions to 8% of 

total volatile matter used; or combined 

capture and control efficiency of at least 

92% of organic HAP used. 

Packaging rotogravure and flexographic 

printing 

Limit emissions to: 

- No more than 5% of the organic 

HAP applied; or 

- No more than 4% of the mass of 

materials applied; or 

- No more than 20% of the mass of 

solids applied; or 

- No more than a calculated 

equivalent allowable mass. 

SMAQMD Requirements

District Rule 450 (Graphics Arts Operations) applies to graphic arts operations, including screening 

printing, flexographic printing, lithographic printing and letterpress printing, and any coating or 

laminating operation associated with flexible packaging material. As noted in the 2006 CTG, 

flexible package printing is almost entirely conducted by gravure and flexographic printing methods. 

 Although gravure printing is exempt from the requirements of Rule 450, there are no gravure 

printing operations in the District and the October 26, 2006 SIP revision included a negative 

declaration for gravure printing. 

For flexographic printing, Rule 450 limits the VOC content of inks, adhesives, coatings, and 

cleaning materials to the following: 

• Printing ink: 300 g/l 

• Adhesives: 150 g/l 

• Coatings: 300 g/l 

• Cleaning materials 

• General Maintenance/Repair: 72 g/l 

• Press Components: 100 g/l and VOC partial pressure of 3 mm Hg at 20 °C 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 10 

As an alternative to the VOC content limits, emissions control equipment may be used provided that 

the control device efficiency is 95% or more on a mass basis, and the collection efficiency is at least 

70%. 

Rule 450 also requires that all VOC materials and VOC-containing cloth, sponges, and other 

materials used for solvent cleaning be stored in closed containers when not in use. 

SMAQMD Exemptions

Rule 450 does not apply to gravure printing, business and personal printers, and graphic arts 

sources that have actual emissions of 60 pounds VOC or less per quarter. The VOC limitations do 

not apply to aerosol adhesives used by 1) screen printing operations, provided the adhesive 

complies with the VOC limits specified under Section 300 of District Rule 460 – ADHESIVES AND 

SEALANTS; or 2) graphic arts operations that have facility VOC emissions less than 660 pounds 

per month. 

Conclusion

Rule 450 is not as stringent as the 2006 CTG for Flexible Package Printing for presses with 

potential to emit, prior to controls, of at least 25 tons/year of VOC. The VOC limits for inks, 

adhesives, and coatings in Rule 450 are higher than the CTG-recommended limit of 0.16 lb VOC/kg 

material, and Rule 450 does not require control equipment for these sources. Staff is proposing to 

correct the RACT deficiency by amending Rule 450 to include the following control device 

requirements for presses used in flexible package printing with potential to emit, prior to controls, of 

at least 25 tons/year of VOC: 

• 70% overall efficiency for a press that was first installed prior to March 14, 1995. 

• 80% overall efficiency for a press that was first installed on or after March 14, 1995. 

The CTG-recommended control efficiencies for control devices installed prior to the date of 

adoption are not applicable because there are currently no flexible package printing presses within 

the District that have installed control devices. 

In addition, Staff is proposing to include the recommended work practice requirements to keep 

cleaning materials and used shop towels in closed containers, and to convey cleaning materials 

from one location to another in closed containers or pipes. 

Staff has proposed the amendment of Rule 450 at a public hearing scheduled for September 25, 

2008. Staff has determined that these amendments will not affect any existing sources within the 

District because current sources are either below the applicability thresholds of the new 

requirements or already comply with the new requirements. 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 11 

Category: Industrial Cleaning Solvents 

EPA RACT Guidance

Control Techniques Guidelines: Industrial Cleaning Solvents, EPA 453/R-06-001, September 2006. 

Alternative Control Technique (ACT) Document – Industrial Cleaning Solvents, EPA 453/R-94-015, 

February 1994. 

Applicability

The CTG and ACT apply to industries that use organic solvents for cleaning units operations, such 

as mixing vessels (tanks), spray booths, and parts cleaners. The CTG applies to facilities that emit 

at least 15 lb/day of VOC before considering controls. The cleaning activities for removal of foreign 

material from substrate being cleaned include activities such as wiping, flushing, or spraying. 

However, the CTG does not apply to specific industries with solvent cleaning operations that are 

covered by other source specific EPA RACT guidance (e.g., aerospace coating, 

lithographic/letterpress printing, etc.). In addition, the CTG does not apply to janitorial supplies 

used for cleaning offices, bathrooms, and other similar areas. 

RACT Requirements

The CTG recommends adopting measures to control emissions of VOC from the use, storage, and 

disposal of industrial solvents. These measures include 1) work practice standards, 2) limitation of 

VOC content on the cleaning material, and 3) an optional alternative limit on the composite vapor 

pressure of the cleaning materials. 

1. Work Practices Standards: 

• Covering open containers and used applicators; 

• Minimizing air circulation around cleaning operations; 

• Properly disposing of used solvent and shop towels; and 

• Implementing equipment practices that minimize emissions (e.g., keeping parts cleaner 

covered, maintaining cleaning equipment to repair solvent leaks, etc.) 

2. VOC Content Limit: 

Generally applicable VOC content limit of 50 grams VOC per liter (0.42 lb/gal) of cleaning 

material for each of the cleaning unit operation listed below, unless the emissions are 

controlled by an emission control system with an overall efficiency of at least 85 percent: 

• Spray gun cleaning 

• Spray booth cleaning 

• Large manufactured components cleaning 

• Parts cleaning 

• Equipment cleaning 

• Line cleaning 

• Floor cleaning 

• Tank cleaning 

• Small manufacture components cleaning 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 12 

3. Alternative Composite Vapor Pressure Limit: 

• 8 mm Hg at 20 °C (as a replacement for the 50 g/l VOC content limit) 

4. Recommended Exclusions (Covered by Other CTGs): 

• Aerospace coatings; 

• Wood furniture coatings; 

• Shipbuilding and repair coatings; 

• Flexible packaging printing materials; 

• Lithographic printing materials; 

• Letterpress printing materials; 

• Flat wood paneling coatings; 

• Large appliance coatings; 

• Metal furniture coatings; 

• Paper film and foil coating; 

• Plastic parts coatings; 

• Miscellaneous metals parts coatings; 

• Fiberglass boat manufacturing materials; 

• Miscellaneous industrial adhesives; and 

• Auto and light-duty truck assembly coatings. 

5. Recommended Exclusions (Based on Bay Area AQMD Rule 8-4 Exemptions) 

• Electrical and electronic components; 

• Precision optics; 

• Numismatic dies; 

• Stripping of cured inks, coatings, and adhesives; 

• Cleaning of resin, coating, ink, and adhesive mixing, molding, and application 

equipment; 

• Research and development laboratories; 

• Medical device or pharmaceutical manufacturing; and 

• Performance or quality assurance testing of coatings, inks, or adhesives. 

6. Recommended Exclusions (Based on inclusion in other Bay Area AQMD Rules) 

• Architectural coating; 

• Metal container, closure, and coil coating; 

• Paper, fabric, and film coating; 

• Light and medium duty motor vehicle assembly plants; 

• Surface coating of metal furniture and large appliances; 

• Surface coating of miscellaneous metal parts and products; 

• Graphic arts printing and coating operations; 

• Coating of flat wood paneling and wood flat stock; 

• Magnet wire coating operations; 

• Aerospace assembly and component coating operations; 

• Semiconductor wafer fabrication operations; 

• Surface coating of plastic parts and products; 

• Wood products coating; 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 13 

• Coating, ink, and adhesive manufacturing; 

• Flexible and rigid disc manufacturing; 

• Marine vessel coating; 

• Motor vehicle and mobile equipment coating operations; and 

• Polyester resin operations. 

The ACT does not evaluate or recommend specific work practice standards or emissions limits. 

The ACT document specifies an environmental management program for reducing VOC emissions 

from industrial cleaning solvents. The program consists of solvent accounting and plant 

management actions. The accounting practices raise awareness of solvent use practices by 

measuring and recording the use and cost of all cleaning solvents used at a facility. The knowledge 

gained from the solvent accounting practices would be used by facility managers to develop 

techniques for reducing emissions (e.g., alternative cleaning solutions, work practice standards and 

equipment changes to reduce solvent use, and use of control devices). 

Other Federal Requirements

No other Federal requirements have been established for this category. 

SMAQMD Requirements

District Rule 466 (Solvent Cleaning) implements the recommendations of the CTG by specifying 

work practices standards and limiting VOC content for cleaning solvents. Rule 466 applies to users 

and sellers of VOC cleaning materials and to persons that store and dispose of VOC-containing 

materials used in solvent cleaning. 

Rule 466 requires operators performing cleaning operations to follow specific work practices 

standards to minimize the evaporation of solvents. Some work practice standards include cleaning 

within closed containers, keeping container closed during non-operation, keeping solvents stored in 

a closed containers, and properly disposing spent solvents. Rule 466 also specifies a VOC content 

limit of 50 g/liter of solvent (including water and exempt solvents) for general purposes, such as 

wipe cleaning and maintenance cleaning. In addition, Rule 466 includes requirements to limit VOC 

content for cleaning solvents used on specific substrates that are recommended for exclusion by 

the CTG (e.g., electrical/electronic components, medical devices and pharmaceuticals). 

As an alternative to meeting the VOC content, cleaning device, and cleaning method standards, 

Rule 466 allows the use of a vent system that collects at least 90 percent of the mass emissions 

generated by the solvent cleaning operations and a control device that meets either a 95-percent 

control efficiency or achieves and outlet concentration less than 50 parts per million as carbon. 

SMAQMD Exemptions

District Rule 466 exempts solvent cleaning operations that that are covered under the following 

District rules: 

• Rule 444 (Petroleum Solvent Dry Cleaning); 

• Rule 450 (Graphic Arts Operations); 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 14 

• Rule 451 (Surface Coating Of Miscellaneous Metal Parts and Products); 

• Rule 452 (Can Coating); 

• Rule 454 (Degreasing Operations); 

• Rule 456 (Aerospace Assembly and Component Coating Operations); 

• Rule 459 (Automotive, Truck and Heavy Equipment Refinishing Operations); 

• Rule 460 (Adhesives and Sealants); 

• Rule 463 (Wood Products Coating); 

• Rule 464 (Organic Chemicals Manufacturing Operations); and 

• Rule 465 (Polyester Resin Operations). 

Rule 466 also exempts the following solvent cleaning operations: 

• Cleaning of solar cells, laser hardware, scientific instruments, and high-precision optics; 

• Cleaning of cotton swabs to remove cottonseed oil before cleaning of high-precision optics; 

• Cleaning of paper-based gaskets and clutch assemblies where rubber is bonded to metal by 

means of an adhesive; 

• Cleaning of application equipment used to apply coatings on satellites and radiation effect 

coatings; 

• Cleaning of electrostatic coating application equipment; and 

• Janitorial cleaning, including graffiti removal. 

• Cleaning of sterilization ink indicating equipment if the solvent usage is less than 1.5 gallons 

per day; and 

• Cleaning with aerosol if 160 fluid ounces or less of aerosol product are used per day, per 

stationary source. 

Conclusion

District Rule 466 establishes VOC content limits and work practice standards that are equivalent to 

or more stringent than the CTG guidance for RACT, and the exemptions in Rule 466 are consistent 

with the CTG recommendations. Rule 466 also establishes VOC content limits and work practice 

standards that conform to the types of management practices identified in the ACT document. 

Therefore, Rule 466 satisfies the RACT requirement for this source category. 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 15 

Category: Metal Furniture Coatings 

EPA RACT Guidance

Control Techniques Guidelines for Metal Furniture Coatings, EPA 453/R-07-005, September 2007. 

Applicability

The CTG applies to each metal furniture surface coating unit at a facility where the total actual VOC 

emissions from all such operations, including related cleaning activities, are at least 15 lb/day (or an 

equivalent level such as 3 tons per 12-month rolling period) before consideration of controls. 

RACT Requirements

The CTG specifies three alternative methods to reduce VOC emissions from metal furniture 

coatings: lower VOC limits, add-on controls, or a combination of lower VOC limits and add-on 

controls. The CTG also recommends work practices and application methods. Various exemptions 

are also recommended. Specific CTG requirements are detailed below. 

Metal furniture coatings VOC content limits

 VOC CONTENT: Grams/Liter 

(Lbs/Gal) 

excluding water and exempt 

compounds 

COATING TYPE AIR DRIED BAKED 

General, One-Component 275 (2.3) 275 (2.3) 

General, Multi-Component 340 (2.8) 275 (2.3) 

Extreme High Gloss 340 (2.8) 360 (3.0) 

Extreme Performance 420 (3.5) 360 (3.0) 

Heat Resistant 420 (3.5) 360 (3.0) 

Metallic 420 (3.5) 420 (3.5) 

Pretreatment Coatings 420 (3.5) 420 (3.5) 

Solar Absorbent 420 (3.5) 360 (3.0) 

Add-On Control Requirements

The CTG recommends an overall control efficiency of 90% for metal furniture coating operations. 

Work Practices

• Store all VOC-containing materials and used shop towels in closed containers 

• Ensure that mixing and storage containers used for VOC-containing materials are kept 

closed at all times except when depositing or removing these materials 

• Minimize spills of VOC-containing materials 

• Convey VOC-containing materials from one location to another in closed containers or pipes 

• Minimize VOC emission from cleaning of storage, mixing, and conveying equipment 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 16 

Application Methods

The following application methods are recommended: 

• Electrostatic application 

• HVLP spray 

• Flow coat 

• Roller coat 

• Dip coat, including electrodeposition 

• Other coating application methods capable of achieving a transfer efficiency equivalent or 

better than that achieved by HVLP spraying 

Recommended exemptions

The CTG recommends the following types of coatings and coating operations be exempt from the 

recommended VOC content limits: 

• Stencil coatings 

• Safety-indicating coatings 

• Solid-film lubricants 

• Electric-insulating and thermal-conducting coatings 

• Touch-up and repair coatings 

• Coating application utilizing hand-held aerosol cans 

SMAQMD Requirements

District Rule 451, Surface Coating of Miscellaneous Metal Parts and Products, sets VOC content 

limits for metal parts and products coatings, including metal furniture coatings, as shown in the table 

below: 

VOC Limits 

g/liter, 

less water and exempt compounds 

(lbs/gallon) 

Coating Air Dried {CTG} Baked {CTG} 

Aluminum coating for window frames and 

door frames 

420 (3.5) 420 (3.5) 

Camouflage 420 (3.5) 360 (3.0) 

Electrical Insulating 340 (2.8) 275 (2.3) 

Extreme High Gloss 420 (3.5) {340 (2.8)} 360 (3.0) {360 (3.0)}

Extreme Performance 420 (3.5) {420 (3.5)} 420 (3.5) {360 (3.0)}

Heat Resistant 420 (3.5) {420 (3.5)} 360 (3.0) {360 (3.0)}

Metallic Iridescent 420 (3.5) {420 (3.5)} 420 (3.5) {420 (3.5)}

Non-skid 420 (3.5) 360 (3.0) 

Prefabricated Architectural Component 420 (3.5) 275 (2.3) 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 17 

VOC Limits 

g/liter, 

less water and exempt compounds 

(lbs/gallon) 

Coating Air Dried {CTG} Baked {CTG} 

Pretreatment wash primer 420 (3.5) {420 (3.5)} 420 (3.5) {420 (3.5)}

Silicone release coating 420 (3.5) 420 (3.5) 

Solar Absorbent 420 (3.5) {420 (3.5)} 360 (3.0) {360 (3.0)}

All other coatings 340 (2.8) 

{1-comp. 275 (2.3), 

2-comp. 340 (2.8)} 

275 (2.3) {275 (2.3)}

• Coating removers (strippers): no more than 200 g VOC/liter of material (1.7 lb/gal). 

• High efficiency applications equipment (e.g., HVLP, roll coater, dip coater, flow coater, 

electrodeposition). 

• Work practices for material storage and equipment cleaning. 

• Product cleaning or surface prep solvents: no more than 72 g VOC/liter of material (0.6 

lb/gal). 

SMAQMD Exemptions

Rule 451 exempts facilities that use 55 gallons of coatings per year, consistent with the EPA Region 

IX “Little Bluebook” (Guidance Document for Correcting Common VOC & Other Rule Deficiencies, 

April 1, 1991, revised August 21, 2001). Rule 451 also exempts 200 gallons per year, per 

stationary source, of coating applied to aluminum window and door frames, and 200 gallons per 

year, per stationary source, of pretreatment wash primer. 

Conclusion

In the October 26, 2006 SIP Revision, Rule 451 was compared to the 1977 CTG for Surface 

Coating of Metal Furniture, and Staff concluded that the RACT requirements were satisfied at that 

time. However, Rule 451 is not as stringent as the 2007 CTG. In particular, the VOC content limits 

recommended in the CTG for general one-component, extreme high gloss, and extreme 

performance coatings are more stringent than 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 CTG 

recommends 90% overall efficiency. 

Staff is proposing to correct these RACT deficiencies by amending Rule 451 to include the following 

VOC content limits for metal furniture coatings, applicable to sources with actual VOC emissions of 

at least 3 tons per 12-month rolling period): 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 18 

 VOC CONTENT: 

Grams/Liter (Lbs/Gal) less 

water and exempt 

compounds 

COATING 

CATEGORY 

AIR DRIED BAKED 

General, MultiComponent 340 (2.8) 275 (2.3) 

Extreme High Gloss 340 (2.8) 360 (3.0) 

Extreme 

Performance 

420 (3.5) 360 (3.0) 

Heat Resistant 420 (3.5) 360 (3.0) 

Metallic/Iridescent 420 (3.5) 420 (3.5) 

Pretreatment Wash 

Primer 

420 (3.5) 420 (3.5) 

Solar Absorbent 420 (3.5) 360 (3.0) 

All Other Coatings 275 (2.3) 275 (2.3) 

Staff also is proposing to increase the overall efficiency requirement for control devices to 90%, 

consistent with the 2007 CTG, and to eliminate the 200 gallon/year exemptions for pretreatment 

wash coatings and aluminum window and door frame coatings. The proposed amendment of Rule 

451 is scheduled for a public hearing on September 25, 2008. Staff has determined that these 

amendments will not affect any existing sources within the District because current sources are 

either below the applicability thresholds of the new requirements or already comply with the new 

requirements. 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 19 

Category: Offset Lithographic and Letterpress Printing 

EPA RACT Guidance

Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing, EPA 

453/R-06-002, September 2006. 

Applicability

The CTG applies to offset lithographic printing and letterpress printing. The CTG provides control 

recommendations for reducing VOC emissions stemming from the use of fountain solutions, 

cleaning materials, and inks in offset lithographic printing and cleaning materials and inks in 

letterpress printing. The requirements for fountain solutions do not apply to offset lithographic 

printing operations with less than or equal to 15 pounds per day of actual VOC emissions. The 

requirements for control equipment do not apply to presses with potential to emit less than 25 tons 

of VOC per year, prior to controls. 

RACT Requirements

Emissions Control Equipment for Heatset Presses

The CTG recommends the use of emissions control equipment to reduce emissions of VOC from 

inks used in heatset web offset lithographic and heatset letterpress printing for presses with 

potential to emit from the dryer, prior to controls, of at least 25 tons/year of VOC. The 

recommended levels of control are as follows: 

• The recommended level of control for VOC emissions from heatset dryers is 90 percent 

control efficiency for a control device whose first installation date was prior to the effective 

date of a State RACT rule, which was issued after the date of this CTG. 

• The recommended level of control for VOC emissions from heatset dryers is 95 percent 

control efficiency for a control device whose first installation date was on or after the 

effective date of the State RACT rule, which was issued after the date of this CTG. 

• To accommodate situations where the inlet VOC concentration is so low that a 90 or 95 

percent efficiency may not be achievable, it is recommended that an alternative requirement 

be specified for the control device outlet concentration to be no more than 20 ppmv as 

hexane on a dry basis. 

Fountain Solution VOC Content Limits

The CTG recommends VOC limits for fountain solutions used in offset lithographic printing for 

sources where the total actual emissions of VOC from all offset lithographic printing operations at 

the stationary source are at least 15 lb/day (or an equivalent level), prior to control. The 

recommended limits are: 

• Heatset Web Offset Lithographic Printing: 1.6% alcohol by weight (or 3% if chilled) 

• Sheet-fed Offset Lithographic Printing: 5% alcohol by weight (or 8.5% if chilled) 

• Coldset Web Offset Lithographic Printing: 5% percent alcohol substitute by weight and no 

alcohol in the fountain solution 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 20 

Cleaning Materials VOC Limits

The CTG recommends VOC limits for cleaning materials used in offset lithographic printing and 

letterpress printing for sources where the total actual emissions of VOC from all offset lithographic 

printing operations at the stationary source are at least 15 lb/day (or an equivalent level), prior to 

control. The recommended limits are: 

• Cleaning materials with a VOC composite vapor pressure less than 10 mm Hg at 20 °C, or 

• Cleaning materials containing less than 70% VOC by weight. 

The CTG also recommends work practices that require cleaning materials and used shop towels to 

be kept in closed containers. 

SMAQMD Requirements

District Rule 450 (Graphics Arts Operations) applies to graphic arts operations, including screening 

printing, flexographic printing, lithographic printing and letterpress printing, and any coating or 

laminating operation associated with flexible packaging material. The following requirements of 

Rule 450 are applicable to offset lithographic printing and letterpress printing: 

• Printing ink: 300 g/l 

• Adhesives: 150 g/l 

• Coatings: 300 g/l 

• Cleaning materials 

- General Maintenance/Repair: 72 g/l 

- Blanket/Roller Washes: 300 g/l or VOC partial pressure of 10 mm Hg at 20 °C 

- Metering Rollers/Printing Plates: 300 g/l or VOC partial pressure of 25 mm Hg at 20 °C 

- Other Components: 100 g/l and VOC partial pressure of 3 mm Hg at 20 °C 

As an alternative to the VOC content limits, emissions control equipment may be used provided that 

the control device efficiency is 95% or more on a mass basis, and the collection efficiency is at least 

70%. 

Rule 450 also requires that all VOC materials and VOC-containing cloth, sponges, and other 

materials used for solvent cleaning be stored in closed containers when not in use. 

SMAQMD Exemptions

Rule 450 does not apply to gravure printing, business and personal printers, and graphic arts 

sources that have actual emissions of 60 pounds VOC or less per quarter. The VOC limitations do 

not apply to aerosol adhesives used by 1) screen printing operations, provided the adhesive 

complies with the VOC limits specified under Section 300 of District Rule 460 – ADHESIVES AND 

SEALANTS; or 2) graphic arts operations that have facility VOC emissions less than 660 pounds 

per month. 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 21 

Conclusion

Rule 450 is not as stringent as the 2006 CTG for Offset Lithographic Printing and Letterpress 

Printing. For heatset presses with potential to emit from the dryer, prior to controls, of at least 25 

tons/year of VOC, the CTG recommends control equipment with an overall efficiency of 90-95%. 

Rule 450 does not require emission control equipment on these presses and the material VOC 

limits in Rule 450 do not provide an equivalent level of emission reduction. For offset lithographic 

printing sources with actual emissions of VOC of at least 15 lb/day, the CTG recommends more 

stringent limits on the VOC content of fountain solution than required by Rule 450. 

Staff is proposing to correct the RACT deficiencies by amending Rule 450 to include the following 

control device requirements for presses used in heatset web offset lithographic printing and heatset 

web letterpress printing with potential to emit, prior to controls, of at least 25 tons/year of VOC: 

90% overall efficiency if permit application is deemed complete prior to (date of adoption) 

95% overall efficiency if permit application is deemed complete after (date of adoption). 

Staff is proposing requirements, consistent with the CTG, for fountain solutions used by offset 

lithographic printing operations with actual VOC emissions of at least 450 pounds per calendar 

month. The proposed requirements are shown in the table on the following page. 

The proposed amendment of Rule 450 is scheduled for a public hearing on September 25, 2008. 

Staff has determined that these amendments will not affect any existing sources within the District 

because current sources are either below the applicability thresholds of the new requirements or 

already comply with the new requirements. 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 22 

VOC Content Limits 

Including water and exempt 

compounds 

MATERIAL TYPE 

Current Limits 

(g/l) 

(The specified 

limits remain in 

effect until limits 

are replaced by 

limits listed in 

the subsequent 

column.) 

Effective 

(One Year 

After Date 

Of 

Adoption) 

(% by 

weight) 

Heatset Web Offset Lithography 

Fountain Solutions Containing Alcohol 

1. Chilled Using Refrigerated Chiller 

2. Non-Chilled 

Fountain Solutions Containing No Alcohol 

1. Chilled Using Refrigerated Chiller 

2. Non-Chilled 

Coldset Web Offset Lithography 

Fountain Solutions Containing Alcohol 

1. Chilled Using Refrigerated Chiller 

2. Non-Chilled 

Fountain Solutions Containing No Alcohol 

1. Chilled Using Refrigerated Chiller 

2. Non-Chilled 

Sheet-fed Offset Lithography with maximum sheet size 

greater than 11 X 17 inches or total solution reservoir greater 

than 1 gallon 

Fountain Solutions Containing Alcohol 

1. Chilled Using Refrigerated Chiller 

2. Non-Chilled 

Fountain Solutions Containing No Alcohol 

1. Chilled Using Refrigerated Chiller 

2. Non-Chilled 

All Other Presses (includes offset lithographic presses 

exempt pursuant to Section 110.9) 

1. Chilled Using Refrigerated Chiller 

2. Non-Chilled 

100 

80 

100 

80 

100 

80 

100 

80 

100 

80 

100 

80 

100 

80 

3 

1.6 

5 

5 

(*See below) 

(*See below) 

5 

5 

8.5 

5 

5 

5 

10 

8 

* Staff is proposing that effective one year after date of adoption, fountain solutions containing alcohol 

shall not be used in coldset web offset lithography printing operations. 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 23 

Appendix B 

Analysis of New Major Sources under a Bump-Up to Severe Nonattainment 

Major Source 

Page 

Number

Cosumnes Power Plant (SMUD) 24 

Grafil 26 

Sacramento Power Authority 29 

Silgan Can Company 31 

UC Davis Medical Center 33 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 24 

Major Source: Cosumnes Power Plant (SMUD) 

Potential to Emit

VOC: 30 ton/yr (major) 

NOx: 125.6 tons/yr (major) 

Facility Description

The SMUD Cosumnes Power Plant is a combined cycle power plant with an electrical generating 

capacity of 500 MW. The plant consists of the following components: 

• Two combined cycle, natural gas-fired General Electric model 7FA gas turbines, rated at 

171.2 MW (1,865 mmBtu/hr input) each. 

• Two heat recovery steam generators to produce steam from the hot turbine exhaust gas. 

• One 180 MW steam turbine. 

• Two cooling towers, each designed to circulate 126,000 gal/min of water. 

Air Pollution Controls and Emission Limits

This facility is a major source of both NOx and VOC. Emissions of NOx and VOC are produced 

from natural gas combustion in the two gas turbines. Best Available Control Technology for NOx 

was applied to these units in the 2002 permit evaluation. The controls discussed below are subject 

to federally enforceable permit conditions under Title V Permit No. 2006-19-01. 

The two gas turbines are equipped with dry low NOx combustors and selective catalytic reduction 

(SCR) to control NOx emissions to a permit limit of 2 ppmv @ 15% O2. The permit also requires 

that the VOC emission be limited to 1.4 ppmv @ 15% O2. 

RACT Discussion

The gas turbines are subject to Rule 413 – Stationary Gas Turbines, which was demonstrated in 

the October 26, 2006 SIP revision to satisfy the RACT requirement for NOx for this source category. 

 The applicable NOx emission limit in Rule 413 is 9 ppmv @ 15% O2. 

The gas turbines are also subject to the less stringent requirements of Title 40 of the Code of 

Federal Regulations, Part 60, Subpart GG – Standards of Performance for Stationary Gas Turbines. 

 The applicable NOx limit from this regulation in 94 ppmv @ 15% O2, based on a heat input rate of 

11.5 kJ/w-hr. 

There are no District rules that limit the emissions of VOC from gas turbines. However, Staff is not 

aware of any cost effective control that can be applied to VOC emissions from combustion of 

natural gas, nor is there any federal guidance for such controls. The combustion process itself is 

inherently efficient in destroying VOC. 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 25 

Conclusion

The RACT requirements for NOx have been satisfied for the gas turbines because these units are 

subject to a SIP-approved rule that has been determined to satisfy RACT. However, there are no 

applicable RACT requirements to control VOC emissions from the gas-fired turbines. 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 26 

Major Source: Grafil 

Potential to Emit

VOC: 14.7 ton/yr (non-major) 

NOx: 26.1 tons/yr (major) 

Facility Description

Grafil, Inc. manufactures carbon fibers at its facility in Sacramento, California. The carbon fiber is 

used by Grafil’s customers to manufacture finished products such as sporting goods, satellites, 

helicopter rotor blades, drive shafts, pumps, valves and CNG tanks. 

Grafil, Inc. manufactures the carbon fiber from polyacrylic fiber. The carbon fiber is processed in 

two parallel production lines, designated as Line 31 and Line 32. The two production lines operate 

independently of each other. The carbon fiber produced from these lines receives a surface 

treatment by a water based nylon coating in a third processing line. 

High quality continuous polyacrylic fiber wound on spools are received and stored in the precursor 

warehouse. During processing, spools are transferred from the storage area and batch loaded to 

the feed end of each production line. Fiber is unwound from many spools simultaneously and 

processed through a sequence of production steps in Lines 31 and 32. These production steps 

include, in order: 

1. Surface oxidation in atmospheric ovens 

2. Tar removal in low temperature furnaces 

3. Carbonization in high temperature furnaces 

4. Surface treatment of the fiber with a solution that promotes good adhesion with polymer 

matrix systems, a necessary requirement for some end users. 

This facility consists of the following emission units: 

At Carbon Fiber Process Line No. 31: 

• (6) Electric Oxidation ovens, (4) end cap hoods, (2) rodding point hoods and low 

temperature rodding exhaust vented to a John Zink Thermal Oxidizer rated at 9.18 

mmBtu/hr (Outside Thermal Oxidizer No. 1). 

• Electric low temperature furnace and (1) Electric high temperature furnace vented to a 

Zeeco Thermal Oxidizer rated at 2.4 mmBtu/hr (Inside Thermal Oxidizer No. 2). 

• Inside Thermal Oxidizer No. 2 vented to JM Construction Model 120 JMCE 100T Baghouse 

with air flow rate at 1,200 cfm (Baghouse No. 1). 

At Carbon Fiber Process Line No. 32: 

• (6) Electric Oxidation ovens, (4) end cap hoods, (2) rodding point hoods and low 

temperature rodding exhaust vented to a John Zink Thermal Oxidizer rated at 9.18 

mmBtu/hr (Outside Thermal Oxidizer No. 3). 

• Electric low temperature furnace and (1) Electric high temperature furnace vented to a John 

Zink Thermal Oxidizer rated at 1.0 mmBtu/hr (Inside Thermal Oxidizer No. 4). 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 27 

• Inside Thermal Oxidizer No. 4 vented to JM Construction Model 120 JMCE 100T Baghouse 

with air flow rate at 1,500 cfm (Baghouse No. 1). 

Continuous Emission Monitoring System for HCN (1 Primary and 1 backup analyzer) monitors both 

Process Line No. 31 and Process Line No. 32. 

• Interscan Model LD28 CEM with range of 0-100 ppm HCN. 

Other Equipment: 

• Cleaver Brooks Model Promethean CBI-200-150-150 natural gas-fired boiler rated at 6.12 

mmBtu/hr. 

• Cleaver Brooks Model Promethean 4WI-NT-100 natural gas-fired boiler rated at 4.8 

mmBtu/hr. 

• Chrysler Model LH318 Internal Combustion Engine, emergency backup, spark-ignited with 

propane fuel, rated at 187 hp. 

• John Deere Model JU6H-UF30/6068T emergency backup diesel engine, rated at 140 hp. 

Air Pollution Controls and Emission Limits

The facility is a major source of NOx. Emissions of NOx are produced by the thermal oxidizers, 

boilers and internal combustion engine. The controls discussed below are subject to federally 

enforceable permit conditions under Title V Permit No. 2006-01-01. 

The four thermal oxidizers are emission control devices which capture and destroy VOC emissions 

from the processing lines. The boilers are equipped with low NOx burners and are limited by permit 

to a NOx emission limit of 9 ppmvd @ 3% O2. 

The propane-fueled emergency standby engine is limited to no more than 100 hours per year of 

operation for maintenance purposes and 200 hours per year for operation for all purposes 

(maintenance and emergency). The diesel-fueled emergency standby engine is limited to no more 

than 50 hours per year of operation for maintenance purposes and 200 hours per year for operation 

for all purposes (maintenance and emergency). 

RACT Discussion

Thermal oxidizers are emission control devices which are used to reduce VOC emissions. There is 

no EPA guidance on RACT that is applicable to NOx emissions from thermal oxidizers. There are 

no New Source Performance Standards (NSPS) or District rules that apply to NOx emissions from 

this source category. Additionally, no other air districts in California have a specific rule to reduce 

NOx emissions from thermal oxidizers. 

The two boilers are subject to Rule 411, NOx from Boilers, Process Heaters and Steam Generators, 

which was demonstrated in the October 26, 2006 SIP revision to satisfy the RACT requirement for 

this source category. For the boiler rated at 6.12 mmBtu/hr, the applicable NOx emission limit in 

Rule 411 is 15 ppmvd @ 3% O2. For the boiler rated at 4.8 mmBtu/hr, the applicable NOx emission 

limit in Rule 411 is 30 ppmvd @ 3% O2. 

The emergency standby engines are subject to Rule 412 – Stationary Internal Combustion Engines 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 28 

at Major Stationary Sources of NOx, which was demonstrated in the October 26, 2006 SIP revision 

to satisfy the RACT requirement for this source category. However, emergency standby engines 

are exempt from the emission limits of Rule 412 as long as they are operated no more 100 hours 

per year for maintenance purposes. 

Conclusion

The RACT requirements have been satisfied for the boilers and the internal combustion engines 

because these units are subject to rules that have been determined to satisfy RACT. 

There is no District rule limiting the emissions of NOx from thermal oxidizers. Thermal oxidizers are 

emissions control equipment used to reduce emissions of VOC and there is no federal guidance or 

other California district rules that apply to NOx emissions from this source category. 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 29 

Major Source: Sacramento Power Authority 

Potential to Emit

VOC: 20.0 ton/yr (non-major) 

NOx: 49.9 tons/yr (major) 

Facility Description

Sacramento Power Authority (SPA) is a cogeneration plant which generates electricity for the 

Sacramento Municipal Utility District (SMUD) and supplies up to 250,000 pounds per hour of 

process steam to Campbell Soup Company. The cogeneration plant consists of a combined cycle 

unit, its associated emission control equipment and a cooling tower. 

The cogeneration plant consists of the following components: 

• Siemens V84.2 combined cycle, gas-fired turbine unit, which generates approximately 103 

MW (nominal) of electric power. 

• Heat Recovery Steam Generator (HRSG) includes a 200 mmBtu/hr HHV duct burner 

system. 

• One Selective Catalytic Reduction (SCR) system used to control the NOx emissions from 

gas turbine unit and the duct burner unit. 

• One Oxidation Catalyst System used to primarily control Carbon Monoxide (CO) and 

secondarily to control Reactive Organic Compound (ROC) on the combustion turbine. 

• One Cooling Tower designed to circulate 45,000 gallons per minute of water. 

Air Pollution Controls and Emission Limits

This facility is a major source of NOx. Emissions of NOx are produced from natural gas combustion 

in the gas turbine and the duct burners. Best Available Control Technology for NOx was applied to 

these units in the initial permit evaluation. The controls discussed below are subject to federally 

enforceable permit conditions under Title V Permit No. 98-14-01. 

The combustion turbine generator is equipped with a selective catalytic reduction (SCR) to control 

NOx emissions to a permit limit of 3 ppmvd @ 15% O2. An oxidation catalyst system is operating to 

reduce CO and VOC emissions. A low-NOx duct burner is also used to limit NOx emissions from 

the HRSG. 

RACT Discussion

The gas turbine is subject to Rule 413 – Stationary Gas Turbines, which was demonstrated in the 

October 26, 2006 SIP revision to satisfy the RACT requirement for this source category. The 

applicable NOx emission limit in Rule 413 is 9 ppmv @ 15% O2. 

The gas turbine is also subject to the less stringent requirements of Title 40 of the Code of Federal 

Regulations, Part 60, Subpart GG – Standards of Performance for Stationary Gas Turbines. The 

applicable NOx limit from this regulation in 96 ppmv @ 15% O2, based on a heat input rate of 11.3 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 30 

kJ/w-hr. 

There is no EPA guidance on RACT that is applicable to the duct burners. There are, however, two 

New Source Performance Standards (NSPS) that apply to duct burners in combined cycle systems: 

Subparts Da and Db of 40 CFR Part 60. In each of these subparts, the NOx standard for duct 

burners is 0.2 lb/mmBtu, which is equivalent to approximately 55 ppmv @15% O2. 

The duct burners fire into the hot turbine exhaust, and their emissions are therefore combined with 

the emissions from the turbine upstream of the emission controls. It is not feasible to operate the 

duct burners without operating the turbines. Therefore, the emissions from the duct burners are 

also subject to the NOx limit of Rule 413, 9 ppmv @ 15% O2. This level of control satisfies the 

requirements of RACT for this source type. 

Conclusion

The RACT requirements have been satisfied for the gas turbines and duct burners because these 

units are subject to SIP-approved rules that have been determined to satisfy RACT. 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 31 

Major Source: Silgan Can Company 

Potential to Emit

VOC: 36.3 tons/yr (major) 

NOx: 20.8 tons/yr (non-major) 

Facility Description 

Silgan Can Company manufactures steel cans for the food canning industry. Silgan produces both 

two-piece and three-piece cans. The three-piece can manufacturing process produces minimal air 

pollutant emissions and is exempted from the District’s permitting requirements. The two-piece can 

manufacturing process produces the majority of the facility’s emissions. 

The two-piece can manufacturing process is also known as the Drawn and Ironed (D and I) can 

manufacturing process. It begins with the receipt of steel coil stock. The coil is unwound, fed 

through the lubricator, and finally fed through the cupping press. The formed cups are fed to the 

bodymakers where, through a punch and ring assembly, the can body is formed by the draw and 

ironing technique with an integral bottom. Lubrication oils are applied to facilitate the mechanical 

action and act as a coolant. 

Following this operation, the cans enter the trimmer where excess metal around the can rim is 

removed to give a uniform height to the can body. After trimming, the unfinished can is transported 

to the washer where the lubricator oils are removed. The can body is then treated by a flow coating 

application of a water borne enamel. This is referred to as the wash coating. After the wash 

coating, the enameled can body enters the wash coat oven. 

After the oven, the can body goes to the flanger where the rim of the can body is flanged. The can 

then goes to the beader where concentric rings are impressed on the side wall of the can. The can 

body is then passed to the test area to approve the integrity of the container. 

The next step of the process is to apply a water-borne inside enamel to the inside can body. This 

coating is similar in composition to the washcoat enamel. This coating is applied in an enclosed 

machine, where overspray and solvent flash-off is captured and ducted to the thermal oxidizer. The 

cans are then conveyed in a covered conveyor to the inside bake oven. Both ovens, the spray 

machine manifold, and the covered conveyor are vented to the thermal oxidizer. 

The following is a list of equipment used at Silgan Can Company: 

• Drawn and Ironed Can Manufacturing Process consisting of: 

1. Various bodymaking equipment 

2. Washcoat application equipment 

3. Inside spray coating equipment (vented to thermal oxidizer) 

• Cincinnati Machinery Model WCS-C46S Natural Gas-Fired Washcoat Oven with heat input 

rated at 6.4 mmBtu/hr (vented to thermal oxidizer) 

• Somerset Ross Natural Gas-Fired Inside Bake Oven with heat input rated at 14 mmBtu/hr 

(vented to thermal oxidizer) 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 32 

• Somerset Ross Model RI-3-15000-95 Thermal Oxidizer 

Air Pollution Controls and Emission Limits

This facility is a major source of VOC, which is emitted from the two-piece can manufacturing 

process. Best Available Control Technology for NOx was applied to these units in the initial permit 

evaluation. The controls discussed below are subject to federally enforceable permit conditions 

under Title V Permit No. 2005-15-01. 

The emissions from the washcoat oven, inside bake oven, and non-fugitive VOC emissions from the 

D and I can manufacturing line are vented to the thermal oxidizer to control the VOC emissions. 

The thermal oxidizer has a collection efficiency of at least 90% and destruction efficiency of at least 

95%. 

The facility is also subject to District Rule 452, Can Coating. This rule requires the facility to use 

coatings that meets the VOC content limits for specific coating categories. Alternatively, emission 

control equipment may be used instead of VOC content limits, provided that the control device 

efficiency is 95% or more, and the collection efficiency is at least 90%. Rule 452 also specifies a 

200 g/L limit for cleaning materials used for container assemble equipment. Additionally, all VOCmaterials and VOC-containing cloth, sponges, and other materials used for solvent cleaning must 

be stored in closed containers when not in use. 

RACT Discussion

The two-piece can manufacturing process is subject to Rule 452, which was demonstrated in the 

October 26, 2006 SIP revision to satisfy the RACT requirements for this source category. Potential 

emissions of VOC from the use of lubrication oils are not regulated by Rule 452, but there is no 

federal RACT guidance and no California district rules that address such emissions. 

Conclusion

The RACT requirements have been satisfied for this facility because the two-piece can 

manufacturing process is subject to a SIP-approved rule that has been determined to satisfy RACT. 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 33 

Major Source: UC Davis Medical Center 

Potential to Emit

VOC: 29 tons/yr (major) 

NOx: 91 tons/yr (major) 

Facility Description

The University of California, Davis (UC Davis) operates the UC Davis Medical Center in 

Sacramento. The UC Davis Medical Center is a health care provider for the community and a 

teaching hospital for the UC Davis School of Medicine. The university established the Medical 

Center in 1973 to support the clinical and research missions of the then new UC Davis School of 

Medicine. Licensed for 528 beds and fully accredited, UC Davis Medical Center is the region's 

dominant Level I comprehensive adult and pediatric trauma center. 

Electrical power for the facility is generated from an onsite co-generation central power plant. The 

electrical generation plant uses a natural gas fueled gas turbine to generate electricity and captures 

the heat emitted by the gas turbine to produce steam for heating and cooling. In addition, four large 

and eight small natural gas fueled boilers provide steam when the gas turbine capacity is exceeded 

or the gas turbine is out of service. Emergency electrical power is provided by eight diesel-fueled 

internal combustion engines driving electrical generators. Emergency water pumping for fire 

fighting is provided by one internal combustion engine driving a fire pump. 

The facility contains 25 permitted emission units: 

• A gas turbine, General Electric model LM 2500, with an input capacity of 260 mmBtu/hr, 

fired on natural gas. The turbine is equipped with water injection and selective catalytic 

reduction (SCR) for NOx control, and an oxidation catalyst for CO control. 

• Four 31.5 mmBtu/hr boilers, Johnston Boiler Company model PFTA750-4LG-150S, fired 

with natural gas as primary fuel and diesel as a backup fuel. 

• A 2 mmBtu/hr boiler, Fulton model PHW 2000, fired with natural gas only 

• Five 2,876-hp diesel engines, Caterpillar model 3516B DITA SC 140F, driving emergency 

backup electrical generators. 

• Eight 0.4 mmBtu/hr boilers, Bryan model MOD-400S-100-G, fired on natural gas, used for 

hot water heating. 

• A 750-hp diesel engine, Cummins model KTTA19G2, driving an emergency backup 

electrical generator. 

• A 156-hp diesel engine, Caterpillar model FM/ULI/3208 DINA, driving a water pump for fire 

fighting. 

• An 890-hp diesel engine, Caterpillar model 3412, driving an emergency backup electrical 

generator. 

• A 68-hp diesel engine, Cummins model 4B3.9-G, driving an emergency backup electrical 

generator. 

• A 157-hp diesel engine, John Deere model 4045H275H, driving an emergency backup 

electrical generator. 

• A gasoline dispensing facility, consisting of two 10,000 gallon underground gasoline tanks, 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 34 

one 10,000 gallon underground diesel tank, and 3 dispensing nozzles. The dispensing 

facility is equipped with Phase I and Phase II vapor recovery. 

Air Pollution Controls and Emission Limits

This facility is a major source for both NOx and VOC. Emissions of NOx and VOC are produced 

from the gas turbine, 13 boilers, and 10 diesel engines. VOC is also emitted from the gasoline 

dispensing facility. The controls discussed below are subject to federally enforceable permit 

conditions under Title V Permit No. 2005-16-01 

The gas turbine is equipped with water injection and SCR to control NOx emissions to a permit limit 

of 5 ppmv @ 15% O2. 

The four 31.5 mmBtu/hr boilers are equipped with low NOx burners that control NOx emissions to a 

permit limit of 9 ppmv NOx @ 3% O2 when firing on natural gas and 40 ppmv NOx @ 3% O2 when 

firing on diesel fuel. These boilers can fire on diesel fuel only when natural gas is unavailable, and 

each boiler is limited to 168 hours per calendar year (including up to 48 hours per year for 

equipment and emissions testing) of operation on diesel fuel. 

The 2 mmBtu/hr boiler has permitted emissions of 100 pounds of NOx per million cubic feet of 

natural gas, and is limited to an annual fuel usage of 40,000 therms. The eight 0.4 mmBtu/hr 

boilers have permitted emissions of 100 pounds of NOx per million cubic feet of natural gas. 

Four of the 2,876-hp emergency standby diesel engines are limited to 50 hours per year of 

operation for maintenance purposes and 750 hours per year for operation for all operation 

(maintenance and emergency). The other 2,876-hp emergency standby diesel engine and the 157-

hp emergency standby diesel engine are limited to 50 hours per year of operation for maintenance 

purposes and 200 hours per year for operation for all operation. 

The 750-hp, 156-hp, 890-hp, and 68-hp emergency standby diesel engines are limited to 40 hours 

per year of operation for maintenance purposes and 200 hours per year for operation for all 

operation. 

The gasoline dispensing facility is equipped with CARB-certified Phase I and Phase II vapor 

recovery systems that reduce VOC emissions by at least 95% by weight. The facility is permitted to 

dispense no more than 250,000 gallons of gasoline per calendar quarter. 

RACT Discussion

The gas turbine is subject to Rule 413 – Stationary Gas Turbines, which was demonstrated in the 

October 26, 2006 SIP revision to satisfy the RACT requirement for NOx for this source category. 

The applicable NOx emission limit in Rule 413 is 9 ppmv @ 15% O2. 

The four 31.5 mmBtu/hr boilers are subject to Rule 411 – NOx from Boiler, Process Heaters and 

Steam Generators, which was demonstrated in the October 26, 2006 SIP revision to satisfy the 

RACT requirement for this source category. The applicable NOx emission limit in Rule 411 is 9 

ppmv @ 3% O2 when firing on natural gas. When firing on diesel fuel, Rule 411 limits NOx 

emissions to 150 ppmv @ 3% O2, provided that each boiler is limited to 168 hours per calendar 
Staff Report 

Updated RACT SIP Analysis 

September 22, 2008, Page 35 

year (including up to 48 hours per year for equipment and emissions testing) of operation on diesel 

fuel. 

The 2 mmBtu/hr boiler is exempt from NOx emission limits under Rule 411 because it has been 

limited by permit to use no more than 40,000 therms of fuel. 

The eight 0.4 mmBtu/hr boilers are exempt from the requirements of Rule 411 because they have 

heat input ratings less than 1 mmBtu/hr. No California district has a rule requirement applicable to 

existing boilers of this size. However, South Coast AQMD Rule 1146.2, Ventura County APCD 

Rule 74.11.1, and San Joaquin Valley Unified APCD Rule 4308 contain NOx emission standards 

that are applicable to all new units at the time of sale or installation. The District’s Board of 

Directors will consider adoption of similar requirements in Rule 414 at a public hearing in 

September of 2009. 

There are no District rules that limit the VOC emissions from the gas-fired boilers and turbine. 

However, Staff is not aware of any cost effective controls that can be applied to VOC emissions 

from the combustion of natural gas, nor is there any federal guidance for such controls. The 

combustion process itself is inherently efficient in destroying VOC. Rule 411 contains CO emission 

limits that ensure efficient fuel combustion for boilers. 

The emergency standby engines are subject to Rule 412 – Stationary Internal Combustion Engines 

at Major Stationary Sources of NOx, which was demonstrated in the October 26, 2006 SIP revision 

to satisfy the RACT requirement for this source category, and includes emission limits for NOx and 

nonmethane hydrocarbons. However, emergency standby engines are exempt from the emission 

limits of Rule 412 as long as they are operated no more 100 hours per year for maintenance 

purposes. 

The gasoline dispensing facility is subject to Rule 448, Gasoline Transfer into Stationary Storage 

Containers, and Rule 449, Transfer of Gasoline into Vehicle Fuel Tanks, both of which were 

demonstrated in the October 26, 2006 SIP revision to satisfy the RACT requirements for this source 

category. These rules require CARB-certified Phase I and Phase II vapor recovery systems that 

reduce VOC emissions by at least 95% by weight. 

Conclusion

The RACT requirements for NOx have been satisfied for the gas turbine, boilers, and emergency 

standby engines at the UC Davis Medical Center, because all emission units are subject to or 

exempt from SIP-approved rules that have been determined to satisfy RACT for NOx. There are no 

applicable controls for VOC emissions from the gas-fired boilers and turbine. 

The RACT requirement for VOC has been satisfied for the gasoline dispensing facility and engines 

because they are subject to SIP-approved rules that have been determined to satisfy RACT for 

VOC. There are no applicable RACT controls for VOC emissions from the gas-fired boilers and 

turbine.