



                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                      REGION IX AIR AND RADIATION DIVISION

                          Technical Support Document 
                                      for
                            the EPA's Rulemaking
                                    for the
                     California State Implementation Plan

                   San Diego Air Pollution Control District
"2020 Reasonably Available Control Technology Demonstration for the National Ambient Air Quality Standards for Ozone in San Diego County, October 2020"

               Negative Declarations for CTG Source Categories: 
Manufacture of Synthesized Pharmaceutical Products, Fiberglass Boat Materials Manufacturing, Miscellaneous Metal and Plastic Parts Coatings, Tables 3-6.



Prepared by: Nancy Levin, Rules Office, Air and Radiation Division, EPA Region IX

                                 February 2022
DOCUMENT IDENTIFICATION

Agency
San Diego Air Pollution Control District (SDAPCD)
Previous action
2008 Eight-Hour Ozone Reasonably Available Control Technology Demonstration for San
Diego County (``2016 RACT SIP'')

Adopted  -  12/14/2016
Submitted  -  4/12/2017

Final Action: Partial Approval and Partial Disapproval
85 FR 77996 (December 3, 2020)

Subject of this Technical Support Document (TSD)
"2020 Reasonably Available Control Technology Demonstration for the National Ambient Air Quality Standards for Ozone in San Diego County, October 2020  -  Negative Declarations for CTG Source Categories, 2008 and 2015 ozone standards: 

Control of Volatile Organic Emissions from Manufacture of Synthesized Pharmaceutical Products EPA-450/2-78-029 1978/12

Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials, EPA - 453/R - 08 - 004 2008/09

Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings, EPA 453/R-08-003 2008/09, Tables 3-6

Adopted  -  10/14/2020
Submitted  -  12/29/2020

Completeness Finding
Complete by operation of law
Docket number; SAN
EPA-R09-OAR-2022-0253; SAN 9611

1. BACKGROUND 

Reasonably available control technology (RACT) requirements
The Clean Air Act (CAA) sections 172(c)(1) and 182 require nonattainment ozone areas classified as "Moderate" or above to adopt reasonably available control technology (RACT). CAA section 182 specifies that RACT is required for volatile organic compound (VOC) sources covered by a Control Techniques Guidelines (CTG) document and for all non-CTG major stationary sources of VOC or oxides of nitrogen (NOX). The SDAPCD falls under this requirement as it regulates an ozone nonattainment area (NAA) classified as "Severe" for the 2008 ozone national ambient air quality standard (NAAQS) (see 40 CFR 81.305). On December 29, 2020, the California Air Resources Board (CARB), on behalf of SDAPCD, submitted the "2020 Reasonably Available Control Technology Demonstration for the National Ambient Air Quality Standards For Ozone in San Diego County, October 2020" ("2020 RACT SIP"). This document, which addresses the Severe area RACT SIP requirements for the 2008 and 2015 ozone standards, includes negative declarations for the three CTG categories that are the subject of this TSD.

Section III.D of the preamble to the EPA's final rule to implement the 2008 8-hour ozone NAAQS (80 FR 12264, March 6, 2015) discusses RACT requirements. It states, in part, that RACT SIPs must contain adopted RACT regulations, certifications where appropriate that existing provisions are RACT, and/or negative declarations that no sources in the nonattainment area are covered by a specific CTG. Id. at 12278. It also provides that states must submit appropriate supporting information for their RACT submissions as described in the EPA's implementation rule for the 1997 ozone NAAQS. See id. and 70 FR 71612, 71652 (November 29, 2005).

Public Notice and Hearing Requirements
CAA sections 110(a)(1) and 110(l) and 40 CFR 51.102 require states to provide reasonable notice and an opportunity for a public hearing prior to adoption of SIP revisions. Section 110(k)(1)(B) requires the EPA to determine whether a SIP submittal is complete within 60 days of receipt. Any plan that the EPA does not affirmatively determine to be complete or incomplete will become complete six months after the day of submittal by operation of law. A finding of completeness does not approve the submittal as part of the SIP, nor does it indicate that the submittal is approvable. It does start a 12-month clock for the EPA to act on the SIP submittal (see CAA section 110(k)(2)).

The District's SIP submittal includes documentation of a notice of opportunity for public hearing and comment on the SIP submittal posted on September 14, 2020 in The Daily Transcript and Daily Journal. The SIP submittal also contains documentation of the October 14, 2020 public hearing on the SIP submittal. The submittal contains the SDAPCD Board resolution adopting the SIP on October 14, 2020. The State submitted the RACT SIP revisions on December 29, 2020, and, with one exception, they became complete by operation of law on June 29, 2021.

2. SCOPE OF ANALYSIS

In this action, the EPA is evaluating the submitted negative declarations for CTG source categories subject to this TSD to remedy deficiencies that the EPA identified in the District's 2016 RACT SIP for the 2008 ozone NAAQS, and to address the same CTG elements for 2015 ozone NAAQS. We will take separate action on the remaining RACT SIP elements addressed in the 2020 RACT SIP.

The following documents were used to support our review: 
 "Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State Implementation Plan Requirements"; 80 FR 12264 (March 6, 2015).
 "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). 
 "State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990"; 57 FR 55620 (November 25, 1992) ("the NOX Supplement"). 
 Memorandum from William T. Harnett to Regional Air Division Directors, dated May 18, 2006, "RACT Qs & As  -  Reasonably Available Control Technology (RACT) Questions and Answers." 
 Letter dated March 9, 2006 from EPA Region IX (Andrew Steckel) to CARB (Kurt Karperos) describing Region IX's understanding of what constitutes a minimally acceptable RACT SIP. 
 Letter dated April 4, 2006 from EPA Region IX (Andrew Steckel) to CARB (Kurt Karperos) listing the EPA's current CTGs, Alternative Control Techniques (ACTs), and other documents which may help to establish RACT. 
 EPA's CTGs and ACTs: https://www.epa.gov/ground-level-ozone-pollution/control-techniques-guidelines-and-alternative-control-techniques.
 CARB's facility emissions inventory database ("Facility Search Engine"): http://www.arb.ca.gov/app/emsinv/facinfo/facinfo.php. 
 	"Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations," ("the Bluebook") EPA OAQPS, May 25, 1988, Revised January 11, 1990:https://archive.epa.gov/ttn/ozone/web/pdf/voc_bluebook.pdf.
 	"Guidance Document for Correcting Common VOC & Other Rule Deficiencies," ("the Little Bluebook"), EPA Region 9, August 21, 2001.

3. NEGATIVE DECLARATIONS

In lieu of adopting RACT rules, districts must adopt negative declarations for CTG source categories if there are no sources in the district covered by the CTG. The District states that "Attachment B  -  CTG/ACT Categories with No Subject District Sources ("Negative Declaration" or ND)" identifies all CTGs for which there are no applicable sources in San Diego County. The District certifies a negative declaration for each CTG listed in Attachment B, stating the following:

      "Searches were performed within the District's permits and emission inventory databases, as well as the internet and yellow pages, to confirm there were no source types in San Diego County that would be subject to the CTGs. District staff also consulted with knowledgeable District inspectors and permit engineers to confirm there were no sources in any CTG category for which a Negative Declaration was claimed."

TABLE 1  -  Negative Declarations for CTG Source Categories for which SDAPCD Certifies It Has No Applicable Sources
                                      CTG
                                Source Category
                   Adopted for 2008 and 2015 Ozone Standards
Control of Volatile Organic Emissions from Manufacture of Synthesized Pharmaceutical Products
EPA-450/2-78-029 1978/12 
("Synthetized Pharmaceutical Products CTG")
Chemical synthesis; Fermentation; Extraction; Formulation and Packaging
10/14/2020
Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials
EPA - 453/R - 08 - 004 2008/09
("Fiberglass Boat Manufacturing Materials CTG")

Manufacture hulls or decks of boats from fiberglass, or build molds to make fiberglass boat hulls or decks
10/14/2020
Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings 
EPA 453/R-08-003 2008/09

("Miscellaneous Metal and Plastic Parts CTG")
Table 3 - Plastic Parts and Products
10/14/2020

Table 4  -  Automotive/Transportation and Business Machine Plastic Parts
10/14/2020

Table 5  -  Pleasure Craft Surface Coating
10/14/2020

Table 6 - Motor Vehicle Materials
10/14/2020

4. EPA EVALUATION: The EPA reviewed the CTGs listed for negative declarations in Table 1 and compared them against sources listed in CARB's Facility Search Engine. We did not identify any sources that would appear to be subject to the listed CTGs. Based on our review, we conclude that the negative declarations in the 2020 RACT SIP's "TABLE 2  -  Negative Declarations for CTG Source Categories for which SDAPCD Certifies It Has No Applicable Sources" appear to be appropriate. Our analysis is as follows:

Synthetized Pharmaceutical Products CTG: The District states that there are no sources in the nonattainment area with emissions greater than the CTG applicability threshold of 15 pounds per day (lb/day). Based on our discussions with the District, search of databases, and further analysis, we did not find facilities that met or exceeded the CTG threshold. 

Fiberglass Boat Manufacturing Materials CTG: The District states that there are no sources in the nonattainment area with emissions exceeding CTG applicability threshold of 15 lb/day or 2.7 tons per year (tpy), and that emissions from the largest fiberglass boat manufacturing operations are 0.5 tpy.  We checked the CARB Facility Search Engine for SIC codes related to fiberglass boat manufacturing and found that Driscoll Custom Boats has emitted 2.5 tpy VOC since 2014 or 13.7 lb/day, which is close to but less than the CTG threshold. The District explained that Driscoll Custom Boats performs other non-fiberglass boat operations, and that fiberglass boat manufacturing accounts for 0.5 tpy VOC, which is well below the CTG threshold.

Miscellaneous Metal and Plastic Parts, Tables 3-6: The District determined that no sources applicable to Tables 3, 4, 5, and 6 have emissions greater than the CTG applicability threshold of 15 lb of VOC per day. The 2020 RACT SIP states that "Since 2010, six of the eight facilities [subject to Table 5] have consistently demonstrated total coating and cleaning material use of less than five pounds of VOC per day before controls. The remaining two facilities respectively have emitted 13.2 and 12.1 pounds of VOC per day before controls, based on recent inventory data [and] ... have each emitted no more than 13.2 pounds of VOC per day since 2007, establishing a pattern of operational consistency." Further, the District states that it "is not aware of any facility that is close to meeting the 15 lb per day CTG Threshold for MMPP Tables 3, 4, and 6."

5. EPA ACTION: We propose to approve the following negative declarations for the 2008 and 2015 ozone standards: Synthesized Pharmaceutical Products CTG, Fiberglass Boat Manufacturing Materials CTG, and Miscellaneous Metal and Plastic Parts CTG, Tables 3-6. We also propose to determine that the submitted negative declarations cure the deficiencies identified in our partial disapproval of SCAPCD's 2016 RACT SIP with respect to the CTGs for Synthesized Pharmaceutical Products, Fiberglass Boat Manufacturing Materials, and Miscellaneous Metal and Plastic Parts, Tables 3-6.
 
6. REFERENCES
 
    Control of Volatile Organic Emissions from Manufacture of Synthesized Pharmaceutical Products EPA-450/2-78-029 1978/12.
    Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials, EPA - 453/R - 08 - 004 2008/09.
    Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings, EPA 453/R-08-003 2008/09, Tables 3-6.
    2008 Eight-Hour Ozone Reasonably Available Control Technology Demonstration for San Diego County (``2016 RACT SIP''); 85 FR 77996 (December 3, 2020).
   
