UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for the 

California State Implementation Plan

El Dorado County Air Quality Management District, 

Negative Declarations for Control Techniques Guidelines (CTG) 

Source Categories

Adopted December 11, 2012

Prepared by: Stanley Tong

November 2013



RULE IDENTIFICATION -

Agency:			El Dorado County Air Quality Management District (EDAQMD)

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

Subject of this TSD:	EDAQMD Negative Declarations

				Adopted 	– December 11, 2012 

				Submitted 	– September 30, 2013

				

BACKGROUND - 

Volatile organic compounds (VOCs) and nitrogen oxides (NOx) in the
presence of sunlight can lead to the formation of ground-level ozone or
“smog” which can result in significant impacts to human health and
the environment. Section 182 of the Clean Air Act (CAA) requires areas
that are classified as moderate or above for ozone nonattainment to
implement reasonably available control technology (RACT) for specific
types of sources. The El Dorado County Air Quality Management District
(EDAQMD) falls under this requirement as it is classified as a severe
ozone nonattainment area for the 1997 8-hour national ambient air
quality standard (“NAAQS”) for ozone (40 CFR 81.305).

Under CAA § 182(b)(2) and (f), EDAQMD must, at a minimum, adopt RACT
level controls for sources covered by a Control Techniques Guidelines
(CTG) document and for any other major stationary source of VOCs or NOx.
Alternatively, areas may adopt a negative declaration documenting that
the air district has no stationary sources or emitting facilities
subject to the CTG documents. The negative declaration must go through
the same public review requirements as any other SIP submittal. 

SUBMITTAL SUMMARY - 

EDAQMD analyzed its rules to determine if they satisfied RACT for the
1997 8-hour ozone standard. The District documented its findings in a
staff report, RACT SIP Update Analysis "2006 RACT SIP" and submitted its
analysis along with a number of negative declarations to EPA as a SIP
revision. EPA's review of EDAQMD's 2006 RACT SIP identified three
additional CTG source categories where it appeared EDAQMD had sources
below the CTG's applicability threshold and could therefore submit a
negative declaration in lieu of adopting or amending a RACT rule. EDAQMD
submitted the following negative declarations:

 

1. Surface Coating of Miscellaneous Metal Parts

EDAQMD's 2006 RACT SIP states that the District has non-major source(s)
in this CTG category and recommended adoption of a rule to limit VOC
emissions since the District did not have a rule covering this CTG
category. EPA's rulemaking proposing to approve EDAQMD's 2006 RACT SIP
analysis identified that the subject facilities did not exceed the
applicability threshold for the Miscellaneous Metal Parts and Products
CTG and recommended EDAQMD submit a negative declaration for this source
category.

2. Solvent Metal Cleaning

EDAQMD's 2006 RACT SIP states that District Rule 225 – Organic Solvent
Cleaning and Degreasing meets the 1977 solvent cleaning CTG. EPA's
evaluation of Rule 225 concluded that the rule could be improved to more
closely match VOC solvent cleaning limits in nearby air districts with a
similar ozone non-attainment classification, but that it was not
required to meet RACT since the District's sources were below the 1977
CTG's applicability threshold. Our proposed approval of EDAQMD's 2006
RACT SIP recommended the District submit a negative declaration for this
category and suggested the District consider updating its rule.

3. Graphic Arts – Rotogravure and Flexography 

EDAQMD's 2006 RACT SIP states that District Rule 231 – Graphic Arts
meets RACT. EPA's evaluation of Rule 231 concluded that the District did
not appear to have any graphic arts facilities that exceeded the 100 tpy
applicability threshold of the Rotogravure and Flexography CTG. Our
proposed approval of EDAQMD's 2006 RACT SIP recommended the District
submit a negative declaration for this category and suggested the
District also review the 2006 Lithographic, Letterpress and Flexible
Package Printing CTG to determine if there are facilities subject to its
lower applicability threshold of 15 lb/day or 2.7 tpy.

EDAQMD reviewed its permit database and files and conducted public
outreach inviting public comment on the District's conclusion that there
are no sources or reasonably foreseeable sources within the District to
which the above CTGs apply. No comments were received by EDAQMD during
the 30 day public comment period.

EPA EVALUATION AND RECOMMENDED ACTION -

In lieu of adopting RACT rules, Districts may adopt negative
declarations for CTG source categories if there are no sources in the
District covered by the CTG documents. 

EPA has evaluated the appropriate background and submittal
documentation, including our original recommendation to EDAQMD to submit
negative declarations on the following CTGs.

CTG Source Category	Negative Declaration – CTG Reference Document

Miscellaneous Metal Parts and Products	EPA-450/2-78-015 – Control of
VOC Emissions from Existing Stationary Sources, Volume VI: Surface
Coating of Miscellaneous Metal Parts and Products

Solvent Metal Cleaning	EPA-450/2-77-022 – Control of VOC Emissions
from Solvent Metal Cleaning

Graphic Arts – Rotogravure and Flexography	EPA-450/2-78-033 –
Control of VOC Emissions from Existing Stationary Sources, Volume VIII:
Graphic Arts – Rotogravure and Flexography



EPA is approving these negative declarations submitted on September 30,
2013 under section 110(k)(3) as meeting the requirements of section 110
and Part D of the CAA as amended in 1990. 

REFERENCES -

1.  El Dorado County Air Quality Management District Reasonably
Available Control Technology (RACT) State Implementation Plan (SIP)
Update Analysis Staff Report, dated December 15, 2006, adopted February
6, 2007; submitted July 11, 2007.

2. EPA proposed approval of EDAQMD 2006 RACT SIP. 78 FR 63934 (October
25, 2013).

3. EPA's TSD supporting proposed approval of EDAQMD's 2006 RACT SIP.

4. Issues Relating to VOC Regulation Cutpoints, Deficiencies, and
Deviations: Clarification to Appendix D of November 24, 1987 FEDERAL
REGISTER, May 25, 1988, Revised January 11, 1990 ("The Blue Book").

5. September 7, 1978 memo from Rhoads to EPA Regions, Clarification of
Degreasing Regulation Requirements.

6. EPA-450/2-78-015 – Control of VOC Emissions from Existing
Stationary Sources, Volume VI: Surface Coating of Miscellaneous Metal
Parts and Products.

7. EPA-450/2-77-022 – Control of VOC Emissions from Solvent Metal
Cleaning.

8. EPA-450/2-78-033 – Control of VOC Emissions from Existing
Stationary Sources, Volume VIII: Graphic Arts – Rotogravure and
Flexography.

 See Approval of Air Quality Implementation Plans; California; El Dorado
County Air Quality Management District; Reasonably Available Control
Technology for Ozone, Proposed Rule; 78 FR 63934 (October 25, 2013). 

 See EDAQMD 2006 RACT SIP page 10, Part 4.

 See 78 FR 63934 (October 25, 2013). One facility emitted 0.24 tons and
0.28 tons of VOCs in 2010 and 2011 and another facility emitted 0.7 tons
of VOCs in 2011, well below the CTG’s applicability threshold of 10
tons per year.

 See TSD accompanying proposed approval of EDAQMD's 2006 RACT SIP. 78 FR
63934 (October 25, 2013).

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