Mojave Desert 

Air Quality Management District 

Final 

Staff Report 

Adoption of the 

Federal Negative Declarations for 

Three Source Categories 

Adopted on 

August 23, 2010 

14306 PARK AVE, VICTORVILLE, CA 92392-2310 

PHONE: (760) 245-1661 

FAX: (760) 245-2699 
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STAFF REPORT 

TABLE OF CONTENTS

Federal Negative Declarations for Three CTG Source Categories 

I. PURPOSE OF STAFF REPORT ............................................................................................ 1 

II. EXECUTIVE SUMMARY..................................................................................................... 1 

III. STAFF RECOMMENDATION ............................................................................................. 2 

IV. LEGAL REQUIREMENTS CHECKLIST ............................................................................ 3 

V. DISCUSSION OF LEGAL REQUIREMENTS..................................................................... 4 

A. REQUIRED ELEMENTS/FINDINGS............................................................................... 4 

1. State Findings Required for Adoption of Rules & Regulations ..................................... 4 

a. Necessity..................................................................................................................... 4 

b. Authority..................................................................................................................... 4 

c. Clarity ......................................................................................................................... 5 

d. Consistency................................................................................................................. 5 

e. Nonduplication............................................................................................................ 5 

f. Reference .................................................................................................................... 5 

g. Public Notice & Comment, Public Hearing................................................................ 5 

2. Federal Elements (SIP Submittals, Other Federal Submittals)....................................... 5

a. Satisfaction of Underlying Federal Requirements...................................................... 6 

b. Public Notice and Comment ....................................................................................... 6 

c. Availability of Document ........................................................................................... 6 

d. Notice to Specified Entities ........................................................................................ 6 

e. Public Hearing ............................................................................................................ 6 

f. Legal Authority to Adopt and Implement................................................................... 6 

g. Applicable State Laws and Regulations Were Followed............................................ 6 

B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS ............................................ 7 

C. ECONOMIC ANALYSIS .................................................................................................. 7 

1. General............................................................................................................................ 7 

2. Incremental Cost Effectiveness....................................................................................... 7 

D. ENVIRONMENTAL ANALYSIS (CEQA)....................................................................... 7 

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS ..................................................... 8 

1. Potential Environmental Impacts.................................................................................... 8 

2. Mitigation of Impacts...................................................................................................... 8 

3. Alternative Methods of Compliance............................................................................... 8 

F. PUBLIC REVIEW.............................................................................................................. 8 

VI. TECHNICAL DISCUSSION ................................................................................................ 8 

E. SIP HISTORY .................................................................................................................... 9 

1. SIP History..................................................................................................................... 9 

a. SIP in the San Bernardino County Portion of MDAQMD ......................................... 9 

b. SIP in the Riverside County Portion of the MDAQMD............................................. 9 

2. SIP Analysis.................................................................................................................. 10 
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Appendix A – Federal Negative Declarations ............................................................................ A-1 

Appendix B - Public Notice Documents..................................................................................... B-1 

Appendix C - Public Comments and Responses......................................................................... C-1 

Appendix D - California Environmental Quality Act Documentation ....................................... D-1 

Appendix E - Bibliography..........................................................................................................E-1 
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STAFF REPORT 

Federal Negative Declarations for Three CTG Source Categories 

I. PURPOSE OF STAFF REPORT 

A staff report serves several discrete purposes. Its primary purpose is to provide a summary and 

background material to the members of the Governing Board. This allows the members of the 

Governing Board to be fully informed before making any required decision. It also provides the 

documentation necessary for the Governing Board to make any findings, which are required by 

law to be made prior to the approval or adoption of a document. In addition, a staff report 

ensures that the correct procedures and proper documentation for approval or adoption of a 

document have been performed. Finally, the staff report provides evidence for defense against 

legal challenges regarding the propriety of the approval or adoption of the document. 

II. EXECUTIVE SUMMARY 

The Mojave Desert Air Quality Management District (MDAQMD) Governing Board is being 

requested to conduct a public hearing, make findings, and then adopt a resolution adopting the

Federal Negative Declarations for Three Source Categories and directing staff actions. These 

“Federal Negative Declarations” (FNDs) are different from the Negative Declarations associated 

with the California Environmental Quality Act (CEQA). Instead, these FNDs, once adopted by 

the Governing Board, will serve as official certification to the United States Environmental 

Protection Agency (USEPA) that there are no stationary sources or emitting facilities in these 

categories located within the area designated as non-attainment for ozone within the MDAQMD.

Adoption of the FNDs will satisfy the specific federal requirement described below. Their 

adoption does not satisfy any other state or federal requirements imposed upon the District. 

There are no emission reductions associated with this action because it does not change any 

existing rules or regulations. 

The Federal Clean Air Act (FCAA) requires areas designated non-attainment and classified 

moderate and above to implement Reasonably Available Control Technology (RACT) for 

sources subject to Control Technique Guidelines (CTG) documents issued by the USEPA for 

“major sources” of volatile organic compounds (VOCs) and oxides of nitrogen (NOx) which are 

ozone precursors. For those source categories not represented within the area designated nonattainment for ozone, USEPA requires the submission of a “Negative Declaration” certifying that 

those sources are not present. These Federal “Negative Declarations” are revisions to the State 

Implementation Plan (SIP). The Federal Negative Declarations for Forty-Four Source

Categories was most recently adopted by the MDAQMD on January 22, 2007. The Federal 

Negative Declarations for Three Source Categories must be adopted to account for three source 

categories at the request of USEPA. These three source categories are: Control of VOC Leaks 

from Petroleum Refinery Equipment (EPA-450/2-78-036, 6/78, NTIS PB-286-158); Control of 

VOC Emissions from Manufacture of High-Density Polyethylene, Polypropylene, and 

Polystyrene Resins (EPA-450/3-83-008, 11/83); and Control of VOC Fugitive Emissions from 
2 MDAQMD Fed. Neg. Dec. 

Final Staff Report, 09/10/2010

Synthetic Organic Chemical Polymer and Resin Manufacturing Equipment (EPA-450/3-83-006, 

03/84). 

III. STAFF RECOMMENDATION 

Staff recommends that the Governing Board of the MDAQMD, after conducting a public 

hearing, adopt the Federal Negative Declarations for Three Source Categories. Such action is 

necessary to satisfy the federal requirements for submission of FNDs for each source category 

not represented within the District covered by a CTG or which meets the definition of a major 

source. 

The Governing Board of the MDAQMD adopted the Federal Negative Declarations for Three 

Source Categories on August 23, 2010. 
MDAQMD Fed. Neg. Dec. 3 

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IV. LEGAL REQUIREMENTS CHECKLIST 

The findings and analysis as indicated below are required for the procedurally correct adoption 

of the Federal Negative Declarations for Three Source Categories. Each item is discussed, if 

applicable, in Section V below. Copies of documents are included in the appropriate Appendix. 

FINDINGS REQUIRED FOR 

RULES & REGULATIONS:

 X Necessity 

 X Authority 

 X Clarity 

 X Consistency 

 X Non-duplication 

 X Reference 

 X Public Notice & Comment 

 X Public Hearing 

REQUIREMENTS FOR STATE 

IMPLEMENTATION PLAN 

SUBMISSION (SIP): 

 X Public Notice & Comment 

 X Availability of Document 

 X Notice to Specified Entities (State, Air 

Districts, USEPA, Other States) 

 X Public Hearing 

 X Legal Authority to adopt and implement the 

document. 

 X Applicable State laws and regulations were 

followed. 

ELEMENTS OF A FEDERAL 

SUBMISSION:

 X Elements as set forth in applicable Federal 

law or regulations. 

CALIFORNIA ENVIRONMENTAL QUALITY 

ACT REQUIREMENTS (CEQA):

N/A Ministerial Action 

N/A Exemption 

 X Negative Declaration 

N/A Environmental Impact Report 

 X Appropriate findings, if necessary. 

 X Public Notice & Comment 

SUPPLEMENTAL ENVIRONMENTAL 

ANALYSIS (RULES & REGULATIONS ONLY):

 X Environmental impacts of compliance. 

N/A Mitigation of impacts. 

N/A Alternative methods of compliance. 

OTHER: 

 X Written analysis of existing air pollution 

control requirements 

 X Economic Analysis 

 X Public Review
4 MDAQMD Fed. Neg. Dec. 

Final Staff Report, 09/10/2010 

V. DISCUSSION OF LEGAL REQUIREMENTS 

A. REQUIRED ELEMENTS/FINDINGS 

This section discusses the State of California statutory requirements that apply to the 

adoption of the Federal Negative Declarations for Three Source Categories (specifically: 

Control of VOC Leaks from Petroleum Refinery Equipment (EPA-450/2-78-036, 6/78, 

NTIS PB-286-158); Control of VOC Emissions from Manufacture of High-Density 

Polyethylene, Polypropylene, and Polystyrene Resins (EPA-450/3-83-008, 11/83); and 

Control of VOC Fugitive Emissions from Synthetic Organic Chemical Polymer and Resin 

Manufacturing Equipment (EPA-450/3-83-006, 03/84)). Since this document is required 

to be adopted pursuant to public notice and other requirements under 42 USC 7410(a)(2), 

the District considers the rule adoption process pursuant to Health & Safety (H&S) Code 

§40702 to be a proper way to meet these requirements. Therefore, these are actions, that 

need to be performed, and/or information, that must be provided in order to adopt this 

document in a procedurally correct manner. 

1. State Findings Required for Adoption of Rules & Regulations 

Before adopting, amending, or repealing a rule or regulation, the District 

Governing Board is required to make findings of necessity, authority, clarity, 

consistency, non-duplication, and reference based upon relevant information 

presented at the hearing. The information below was provided to assist the Board 

in making these findings. 

a. Necessity 

The adoption of the Federal Negative Declarations for Three 

Source Categories is necessary because those source categories are 

not represented within the area of the District designated nonattainment for ozone and USEPA requires the submission of a 

FND certifying that those sources are not present. The Federal 

Negative Declarations for Forty-Four Source Categories was most 

recently adopted by the MDAQMD on January 22, 2007. The 

Federal Negative Declarations for Three Source Categories is 

being adopted at the specific request of USEPA to cover three 

categories not addressed in the previous action. 

b. Authority 

MDAQMD has the authority pursuant to California H&S Code 

§40702, 40725-40728 to adopt, amend or repeal rules and 

regulations and to do such actions that are necessary or proper to 

execute the powers and duties granted to and imposed upon 

MDAQMD. 
MDAQMD Fed. Neg. Dec. 5 

Final Staff Report, 09/10/2010 

c. Clarity 

The adoption is clear in that it is written so that the FND certifying 

that these types of sources are not present within the District is 

easily understood. 

d. Consistency 

The adoption of the Federal Negative Declarations for Three 

Source Categories is in harmony with, and not in conflict with or 

contradictory to any state law or regulation, federal law or 

regulation, or court decisions. USEPA has specifically requested 

the adoption of a FND for these three source categories to cover 

three categories not addressed in the previous action. 

e. Non-duplication 

The adoption of the Federal Negative Declarations for Three 

Source Categories does not impose the same requirements as an 

existing state or federal law or regulation because federal law 

requires the adoption and certification of “Negative Declarations” 

for those source categories not represented within the area 

designated non-attainment for ozone. 

f. Reference 

The District has the authority pursuant to H&S Code §40702 to 

adopt, amend or repeal rules and regulations and do such acts as 

necessary and proper to execute the powers and duties granted to and 

imposed upon the District. 

g. Public Notice & Comment, Public Hearing 

Notice for the public hearing for the proposed adoption of the 

Federal Negative Declarations for Three Source Categories was 

published July 22, 2010. See Appendix “B” for a copy of the public 

notice. See Appendix “C” for copies of comments, if any, and 

MDAQMD responses. 

2. Federal Elements (SIP Submittals, Other Federal Submittals) 

Submittals to USEPA are required to include various elements depending upon 

the type of document submitted and the underlying federal law, which requires 

the submittal. The information below indicates which elements are required for 

the proposed adoption of the Federal Negative Declarations for Three Source 

Categories and how they were satisfied. 
6 MDAQMD Fed. Neg. Dec. 

Final Staff Report, 09/10/2010 

a. Satisfaction of Underlying Federal Requirements 

The adoption of the Federal Negative Declarations for Three 

Source Categories is subject to all the requirements for a SIP 

submittal because the “Negative Declarations” will be included in 

the MDAQMD SIP. The criteria for determining completeness of 

SIP submissions are set forth in 40 CFR Part 51, Appendix V, 2.0. 

b. Public Notice and Comment 

Notice for the public hearing for the proposed adoption of the 

Federal Negative Declarations for Three Source Categories was 

published July 22, 2010. See Appendix “B” for a copy of the public 

notice. 

c. Availability of Document 

Copies of the proposed adoption of the Federal Negative 

Declarations for Three Source Categories and the accompanying 

draft staff report was made available to the public on July 8, 2010. 

d. Notice to Specified Entities 

Copies of the proposed adoption of the Federal Negative 

Declarations for Three Source Categories and the accompanying 

draft staff report was mailed to all affected agencies, including but 

not limited to the California Air Resources Board (CARB) and 

USEPA. The proposed action was sent to CARB and USEPA on 

July 8, 2010. 

e. Public Hearing 

A public hearing to consider the proposed adoption of the Federal 

Negative Declarations for Three Source Categories was held on 

August 23, 2010. 

f. Legal Authority to Adopt and Implement 

The MDAQMD has the authority pursuant to H&S Code §40702 

to adopt, amend, or repeal rules and regulations and to do such acts 

as may be necessary or proper to execute the duties imposed upon 

the MDAQMD. 

g. Applicable State Laws and Regulations Were Followed 

Public notice and hearing procedures pursuant to H&S Code 

§§40725-40728 have been followed. See Section (V)(A)(1) above 

for compliance with state findings required pursuant to H&S Code 
MDAQMD Fed. Neg. Dec. 7 

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§40727. See Section (V)(B) below for compliance with the 

required analysis of existing requirements pursuant to H&S Code 

§40727.2. See Section (V)(C) for compliance with economic 

analysis requirements pursuant to H&S Code §40920.6. See 

Section (V)(D) below for compliance with provisions of the 

California Environmental Quality Act (CEQA). 

B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS 

H&S Code §40727.2 requires air districts to prepare a written analysis of all existing 

federal air pollution control requirements that apply to the same equipment or source type 

as the rule proposed for modification by the district. The proposed adoption of the 

Federal Negative Declarations for Three Source Categories will certify FNDs for 

Control of VOC Leaks from Petroleum Refinery Equipment (EPA-450/2-78-036, 6/78, 

NTIS PB-286-158); Control of VOC Emissions from Manufacture of High-Density 

Polyethylene, Polypropylene, and Polystyrene Resins (EPA-450/3-83-008, 11/83); and 

Control of VOC Fugitive Emissions from Synthetic Organic Chemical Polymer and Resin 

Manufacturing Equipment (EPA-450/3-83-006, 03/84) are not represented within the area 

designated non-attainment for ozone. Although the Federal Negative Declarations for 

Forty-Four Source Categories was most recently adopted on January 22, 2007, the

Federal Negative Declarations for Three Source Categories is being adopted at the 

request of USEPA to cover three categories not addressed in the previous action. 

C. ECONOMIC ANALYSIS 

1. General 

Adoption of the FNDs will identify three source categories listed above not 

represented within the area designated non-attainment. The adoption will have no 

economic impact. 

2. Incremental Cost Effectiveness 

Pursuant to H&S Code §40920.6, incremental cost effectiveness calculations are 

required for rules and regulations which are adopted or amended to meet the 

California Clean Air Act requirements for Best Available Retrofit Control 

Technology (BARCT) or “all feasible measures” to control volatile compounds, 

oxides of nitrogen or oxides of sulfur. 

The proposed adoption of the Federal Negative Declarations for Three Source 

Categories is not subject to incremental cost effectiveness calculations because 

this rule does not impose BARCT or “all feasible measures”.

D. ENVIRONMENTAL ANALYSIS (CEQA) 

Through the process described below, it was determined that a Notice of Exemption 

would be the appropriate CEQA process for the adoption of the Federal Negative 

Declarations for Three Source Categories.
8 MDAQMD Fed. Neg. Dec. 

Final Staff Report, 09/10/2010 

1. The adoption of the Federal Negative Declarations for Three Source 

Categories meets the CEQA definition of "project." They are not "ministerial" 

actions. 

2. The adoption of the Federal Negative Declarations for Three Source 

Categories is exempt from CEQA review because it will not create any adverse 

impacts on the environment. Because there is no potential that the adoption might 

cause the release of additional air contaminants or create any adverse 

environmental impacts, a Class 8 categorical exemption (14 Cal. Code Reg. 

§15308) applies. 

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS 

1. Potential Environmental Impacts 

There are no potential negative environmental impacts of compliance with the 

proposed adoption of the FNDs because the FND merely certifies that the 

particular source categories are not located within the District. 

2. Mitigation of Impacts 

N/A 

3. Alternative Methods of Compliance 

N/A 

F. PUBLIC REVIEW 

See Staff Report Section (V)(A)(1)(g) and (2)(b), as well as Appendix “B” 

VI. TECHNICAL DISCUSSION 

USEPA required that all non-attainment areas submit an updated RACT SIP Analysis. 

The purpose of the RACT SIP Analysis is to ensure that District Rules adequately 

address current RACT requirements. MDAQMD review identified many source 

categories that do not have corresponding sources (major or minor) within the jurisdiction 

of the MDAQMD. The Federal Negative Declarations for Forty-Four Source

Categories was most recently adopted on January 22, 2007 for these source categories. 

The Federal Negative Declarations for Three Source Categories was adopted at the 

request of USEPA to cover three categories not addressed in the previous action. 
MDAQMD Fed. Neg. Dec. 9 

Final Staff Report, 09/10/2010 

Table 1 

Source Category CTG/Guidance Document Covering action

Petroleum Refinery Equipment

Control of VOC Leaks from Petroleum Refinery 

Equipment (EPA-450/2-78-036, 6/78, NTIS PB-286-

158)

Manufacture of High-Density 

Polyethylene, Polypropylene, and 

Polystyrene Resins

Control of VOC Emissions from Manufacture of 

High-Density Polyethylene, Polypropylene, and 

polystyrene Resins (EPA-450/3-83-008, 11/83)

Fugitive Emissions from Synthetic 

Organic Chemical Polymer and Resin 

Manufacturing Equipment

Control of VOC Fugitive Emissions from Synthetic 

Organic Polymer and Resin Manufacturing 

Equipment (EPA-450/3-83-006, 3/84)

FEDERAL NEGATIVE DECLARATIONS FOR THREE SOURCE CATEGORIES

E. SIP HISTORY 

1. SIP History 

a. SIP in the San Bernardino County Portion of MDAQMD 

On July 1, 1993 the MDAQMD was formed pursuant to statute. 

Pursuant to statute it also retained all the rules and regulations of 

the SBCAPCD until such time as the Governing Board of the 

MDAQMD wished to adopt, amend or rescind such rules. The 

MDAQMD Governing Board, at its very first meeting, reaffirmed 

all the rules and regulations of the SBCAPCD. Since SIP revisions 

in California are adopted by USEPA as effective in areas which 

happen to be defined by both air basin designations and the 

jurisdictional boundaries of local air districts within those air 

basins, the MDAQMD “inherited” the SBCAPCD SIP which was 

in effect for what is now called the San Bernardino County Portion 

of MDAB. 

b. SIP in the Riverside County (Blythe/Palo Verde Valley) Portion of 

the MDAQMD 

One of the provisions of the legislations which created the 

MDAQMD allowed areas contiguous to the MDAQMD 

boundaries and within the same air basin to leave their current air 

district and become a part of the MDAQMD. On July 1, 1994 the 

area commonly known as the Palo Verde Valley in Riverside 

County, including the City of Blythe, left SCAQMD and joined the 

MDAQMD. Since USEPA adopts SIP revisions in California as 

effective within the jurisdictional boundaries of local air districts, 

when the local boundaries change the SIP as approved by USEPA 

for that area up to the date of the change remains as the SIP in that 

particular area. Upon annexation of the Blythe/Palo Verde Valley 
10 MDAQMD Fed. Neg. Dec. 

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the MDAQMD acquired the SIP prior to July 1, 1994 that was 

effective in the Blythe/Palo Verde Valley. Therefore, the SIP 

history for the Blythe/Palo Verde Valley Portion of the MDAQMD 

is based upon the rules adopted and approved for that portion of 

Riverside County by SCAQMD. 

2. SIP Analysis 

The Federal Negative Declarations for Forty-Four Source Categories was most 

recently adopted on January 22, 2007 for these source categories. The Federal 

Negative Declarations for Three Source Categories, specifically the source 

categories: Control of VOC Leaks from Petroleum Refinery Equipment (EPA450/2-78-036, 6/78, NTIS PB-286-158); Control of VOC Emissions from 

Manufacture of High-Density Polyethylene, Polypropylene, and Polystyrene 

Resins (EPA-450/3-83-008, 11/83); and Control of VOC Fugitive Emissions from 

Synthetic Organic Chemical Polymer and Resin Manufacturing Equipment (EPA450/3-83-006, 03/84), are being adopted at the request of USEPA to cover three 

categories not addressed in the previous action. 

The MDAQMD has determined that no sources in the three source categories 

listed in Table 1 exist within its jurisdiction. 
MDAQMD Fed. Neg. Dec. A-1 

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Appendix “A”

Federal Negative Declarations for Three Source Categories 

Draft Version 

1. Federal Negative Declaration (8-hr Ozone Standard) for Three Source Categories 
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Appendix “B” 

Public Notice Documents 

1. Proof of Publication – Daily Press, 07/22/2010 

2. Proof of Publication – Riverside Press Enterprise, 07/22/2010 
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Appendix “C” 

Public Comments and Responses 

1. USEPA email, October 26, 2009 

2. USEPA email, March 12, 2010 

3. USEPA “No Comment” letter, July 20, 2010 
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1 

2 

Comment 1 
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District response to USEPA comments 

1. Control of VOC Leaks from Petroleum Refinery Equipment (EPA-450/2-78-036, 

6/78, NTIS PB-286-158) is included in the Federal Negative Declarations for Three 

Source Categories proposed for adoption. 

2. Control of VOC Emissions from Manufacture of High-Density Polyethylene, 

Polypropylene, and Polystyrene Resins (EPA-450/3-83-008, 11/83) and Control of 

VOC Fugitive Emissions from Synthetic Organic Chemical Polymer and Resin 

Manufacturing Equipment (EPA-450/3-83-006, 03/84) are included in the Federal 

Negative Declarations for Three Source Categories proposed for adoption. There are 

no facilities in the MDAQMD engaged in the manufacture of polymer resins. 
C-6 MDAQMD Fed. Neg. Dec. 

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1 

Comment 2 
MDAQMD Fed. Neg. Dec. C-7 

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District Response to USEPA email 

1. Control of VOC Leaks from Petroleum Refinery Equipment (EPA-450/2-78-036, 6/78, 

NTIS PB-286-158), Control of VOC Emissions from Manufacture of High-Density 

Polyethylene, Polypropylene, and Polystyrene Resins (EPA-450/3-83-008, 11/83), and 

Control of VOC Fugitive Emissions from Synthetic Organic Chemical Polymer and 

Resin Manufacturing Equipment (EPA-450/3-83-006, 03/84) are included in the 

Federal Negative Declarations for Three Source Categories proposed for adoption. 
MDAQMD Fed. Neg. Dec. C-9 

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Comment 3 
C-10 MDAQMD Fed. Neg. Dec. 

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District Response to USEPA “No Comment” letter 

No comment required. 
MDAQMD Fed. Neg. Dec. D-1 

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Appendix “D” 

California Environmental Quality Act 

Documentation 

1. Notice of Exemption – San Bernardino County 

2. Notice of Exemption – Riverside County 
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Appendix “E” 

Bibliography

The following documents were consulted in the preparation of this staff report. 

1. Environmental Protection Agency – Final Rule to Implement the 8-Hour Ozone 

NAAQS (70 FR 71617, November 29, 2005) 

2. EPA – various CTGs, ACTs, and other documents 

3. California Health and Safety Code – various sections 
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