UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX AIR DIVISION

Technical Support Document

for Revisions to the California State Implementation Plan

, Feather River Air Quality Management District

2006 Reasonably Available Control Te chnology (RACT) Analysis for State Implementation Plan (SIP)

November 2006

Reasonably Available Control Technology State Implementation Plan Revision Negative Declaration for Control Techniques Guidelines Issued 2006

- 2008 Adopted June 1, 2009

Reasona bly Available Control Technology Analysis

and N egative Declarations July 3, 2014

Prepared by: James Shears Reviewed by: Andrew Steckel

January 2015- 2

-

RULE IDENTIFICATION

-

Agency: Feather River Air Quality Management District ( FR AQM D )

SIP Approved Version : None

S ubject of this TSD: FR AQMD Reasonably Available Control Technology

2006 Reasonably Available Control Technology (RACT) Analysis for State Implementation Plan (SIP), dated November 2006 Adopted December 4, 2006 S ubmitted July 11, 2007

Reasonably Available Control Technology State Implementation Plan Revision, Negative Declaration for Control Techniques Guidelines Issued 2006

- 2008

, adopted June 1, 2009 Adopted June 1, 2009 Submitted October 27, 2009

Reasona bly Available Control Technology Analysis and Negative Declarations, dated July 3, 2014 Adopted August 4, 2014 Submitted September 29, 2014

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 t o implement reasonably available control technology (RACT) for specific types of sources. The Feather River Air Quality Management District (FRAQMD) is subject to this requirement

, as the southern part of Sutter County in the FRAQMD is designated and clas sified as a severe 1 ozone nonattainment area for the 1997 and 2008 8

- hour national ambient air quality standard s (NAAQS) for ozone (40 CFR 81.305).

1 On May 5, 2010 (75 FR 24409), EPA granted the State of California’s request to reclassify t he Sacramento Metropolitan ozone nonattainment area, which includes the southern portion of Sutter County in FRAQMD, from “serious” to “severe

- 15” for the 1997 8

- hour ozone standard

. A separate area of Sutter County, the portion of the Sutter Buttes mounta in range at or above 2,000 feet in elevation , is also designated nonattainment for the 1997 8

- hour standard, but is classified as marginal, and is therefore not subject to the RACT requirement.- 3

-

Under CAA 182(b)(2) and (f), FRAQMD 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, FRAQMD may adopt a negative declaration documenting that the air district has no stationary sources or emitting facilities subject to the CTG documents and no other major stationary source of VOCs or NOx . The negative declaration must go through the same public review requirements as any other SIP document.

On December 4, 2006, FRAQMD adopted its 2006 RACT SIP

, which included several nega tive declarations for the 1997 ozone standard . The 2006 negative declarations covered aerospace coatings, automobile coatings, cutback asphalt, dry cleaning, gasoline loading terminals, gasoline bulk plants, graphic arts, large appliance coating, magnet wi re coating, metal can/coil coating, metal furniture, metal parts and product s coating, natural gas/gasoline equipment leaks at processing plants, paper and fabric coating, petroleum liquid storage tanks, pharmaceutical products, resin manufacturing, refine ries, rubber tire manufacturing, ship coatings, solvent cleaning degreasers, synthetic organic chemical manufacturing, flat wood paneling and wood furniture coating. EPA did not act on FRAQMD’s 2006 RACT SIP

, including the negative declarations, pending r esolution of issues related to the gasoline vapor recovery rule , Rule 3.8, which did not satisfy the CTG at that time

. Between 2006 and 2008, EPA issued 11 new or updated CTGs. FRAQMD reviewed its permitted facilities in the South Sutter County 1997 ozon e nonattainment area. On June 1, 2009 FRAQMD adopted negative declarations for these 11 CTGs

. The se negative declarations covered industrial cleaning solvents, offset lithographic printing and letterpress printing, flexible package printing, flat wood pane ling coatings, paper, film, and foil coatings, large appliance coatings, metal furniture coatings, miscellaneous metal parts and plastic parts coatings, fiberglass boat manufacturing materials, miscellaneous industrial adhesives, and automobile and light

- d uty truck assembly coatings. FRAQMD reported there are no current

sources and no anticipated sources subject to the 11 additional CTGs in the ozone nonattainment area

. Effective July 20, 2012, t he southern portion of Sutter County was designated nonatt ainment and classified as “severe” for the 2008 8

- hour ozone NAAQS. Accordingly, FRAQMD was required to submit a new RACT SIP , including renewed negative declarations. On August 14, 2014, FRAQMD adopted its 2014 RACT Analysis and Negative Declaration

, whic h update d the 2009 and 2006 negative declarations

. It reported no current or anticipated sources except for gasoline transfer facilities subject to the vapor recovery systems CTG. Th e 2014 RACT SIP submittal also revised the vapor recovery rule, Rule 3.8

, in an effort to satisfy the CTG. The revisions for Rule 3.8 are analyzed in a separate EPA technical support document.

SUMMARY OF SUBMITTALS

FRAQMD’s 2006 RACT SIP

The District adopted its 2006 RACT SIP, including the negative declarations, on Dec ember 4, 2006 and the California Air Resources Board (CARB) submitted it to EPA on July 11, 2007. The CARB submittal included a completeness checklist which indicated the package was- 4

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complete. The submittal became complete by operation of law on January 11, 2008 pursuant to CAA 110(k)(1)(B).

The 2006 RACT SIP included the following documents:

a. Feather River Air Quality Management District 2006 Reasonably Available Control Technology Analysis for State Implementation Plan, December 4, 2006

. b. Resolution # 2006

- 10 of the Feather River Air Quality Management District Board approving and adopting the Ozone State Implementation Plan Revision Reasonably Available Control Technology as Applicable to the 8

- Hour Ozone Standard

– adopted on December 4, 2006.

The SI P identified southern Sutter County as a serious nonattainment area for the 1997 8

- hour ozone NAAQS. FRAQMD reviewed its master database of permitted facilities and identified 26 stationary sources in south Sutter County. The 2006 RACT SIP includes a tab le of these permitted facilities, the business type, and the potential emissions of ozone precursors. The District also reviewed its database for major sou rces, those emitting at least 25 tons per year or more of VOC or NOx, and did not identify any major sources in the ozone nonattainment area

. FRAQMD reviewed the CTG source categories and concluded the only CTG that applied in south Sutter County is for gasoline service stations. The District concluded that District Rule 3.8 Storage and Transfer of G asoline (amended 06/1991) and Rule 3.12 Benzene Airborne Toxic Control Measure

– Retail Service Stations (amended 06/1991) are compatible with CTG requirements on Stage I Vapor Recovery System for both retail and private gasoline service stations. The Di s trict concluded that both rules enable the exempt ion of low

- use stations with a monthly throughput of 25,000 gallons or less. FRAQMD considered vapor recovery systems to not be cost effective for such stations

.

2009 RACT SIP Revision

The District adop ted its 2009 RACT SIP revision, which included negative declaration s for 11 CTGs issued from 2006 to 2008, on June 1, 2009 and CARB submitted it to EPA on October 27, 2009. The submittal became complete by operation of law on April 27, 2010 pursuant to CA A 110(k)(1)(B).

The 2009 RACT SIP included the following documents:

a. Feather River Air Quality Management District 2009 Reasonably Available Control Technology State Implementation Plan Revision for FRAQMD Nonattainment Areas Sutter Buttes and South Sutte r County Portion of the Sacramento Federal 8

- Hour Ozone (SFNA), Negative Declaration for Control Techniques Guidelines Issued 2006

- 2008, June 1, 2009. b. Resolution #2009

- 06 of the Feather River Air Quality Management District Board approving and adopting th e Ozone State Implementation Plan Revision Reasonably Available Control Technology as Applicable to the 8

- Hour Ozone Standard

– adopted on June 1, 2009.- 5

-

FRAQMD reviewed its master database of permitted facilities and identified 32 permitted stationary so urces in south Sutter County and no sources atop the Sutter Buttes ozone nonattainment area . The 2009 RACT SIP revision includes a table of these permitted facilities, the business type, and the potential emissions of ozone precursors. The District also reviewed its database for major sources (i.e. those emitting at least 25 tons per year or more of VOC or NOx ) and did not identify any major sources. The largest s ource, a heavy equipment dealer, emitted 8.75 tpy of total hydrocarbon mostly due to the pai nting of construction equipment

. T he District took into account the 11 new or up d a t ed CTGs issu ed from 2006 to 2008 in making this determination

.

2014 RACT SIP

The District adopted its 2014 RACT analysis and negative declaration on August 4, 2014 and CAR B submitted it to EPA on September 29, 2014. EPA found it to be complete and issued a completeness letter on January 23, 2015.

FRAQMD’s 2014 RACT SIP included the following documents:

a. 2014 Reasonably Available Control Technology Analysis and Negative Decl aration Prepared by the Feather River Air Quality Management District pursuant to Sections 182(b)(2) and 182(f) of the Clean Air Act for the south Sutter County portion of the Sacramento Metro Nonattainment Area for the 2008 8

- Hour Ozone National Ambient A ir Quality Standard, August 4, 2014. b. Resolution # 2014

- 10 of the Feather River Air Quality Management District Board approving and adopting the Reasonably Available Control Technology Analysis and Negative Declaration as Applicable to the 2008 8

- Hour Ozone National Ambient Air Quality Standard

– adopted on August 4, 2014.

FRAQMD reviewed its master database of permitted facilities and identified 37 sources in south Sutter County. The 2014 RACT SIP includes a table of these permitted facilities, the bus iness type, and the potential emissions of ozone precursors. The District also reviewed its database for major sources, those emitting at least 25 tons per year or more of VOC or NOx and did not identify any major sources in the ozone nonattainment area

. The only source subject to RACT guidance is gasoline service stations. The CTG Design Criteria for Stage I Vapor Control Systems

– Gasoline Service Stations (EPA

- 450/R

- 75

- 102) was determined to be applicable to the gas stations in the nonattainment area. As noted above, t he District adopted amendmen ts to Rule 3.8 on June 2, 2014 and submitted it to EPA for approval into the SIP . The revisions to th e rule ar e analyzed in a separate EPA technical support document.

Table 1 lists the negative declarations included in the 2006, 2009 and 2014 RACT SIPS. The negative declarations in the 2006 and 2009 RACT SIPs are for the 1997 8

- hour ozone standard. The negative declarations in the 2014 RACT SIP are for the 2008 8

- hour ozone standard.- 6

- 

### Table 1

– Negative De clarations for the 2006, 2009 and 2014 RACT SIPS

CTG Source Category Negative Declaration CTG Reference Document 2006 RACT SIP 2009 RACT SIP 2014

RACT SIP Aerospace EPA

- 453/R

- 97

- 004

– Control of VOC Emissions from Coating Operations at Aerospace Manufac turing and Rework X X

Automobile Coating; Metal Coil Container, & Closure; Paper & Fabric EPA

- 450/2

- 77

- 008

– Control of Volatile Organic Emissions from Existing Stationary Sources

– Volume II Surface Coating of Cans, Coils, Paper, Fabrics, Aut omobiles, and Light

- Duty Trucks X X

Automobile and Light

- Duty Truck Assembly Coatings EPA

- 453/R

- 08

- 006

– Control Techniques Guidelines for Automobile and Light

- Duty Assembly Coatings X X

Cutback Asphalt EPA

- 450/2

- 77

- 037

– Control of Volat ile Organic Emissions from Use of Cutback Asphalt X X

Dry Cleaning EPA

- 450/3

- 82

- 009

– Control of Volatile Organic Compound Emissions from Large Petroleum Dry Cleaners X X

Flat Wood Paneling Coatings EPA

- 453/R

- 06

- 004

– Control Tech niques Guidelines for Flat Wood Paneling Coatings X X

Fiberglass Boat Manufacturing Materials EPA

- 453/R

- 08

- 004

– Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials X X

Flexible Package Printing EPA

- 453/R06

- 003

– Con trol Techniques Guidelines for Flexible Package Printing X X

Gasoline Loading Terminal EPA

- 450/2

- 77

- 026

– Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals X X

Gasoline Trucks EPA

- 450/2

- 78

- 051

– Control of Volatile Or ganic Compound Leaks from Gasoline Tank Trucks and Vapor Collection Systems X X

Gasoline Bulk Plants EPA

- 450/2

- 77

- 035

– Control of Volatile Organic Emissions from Gasoline Bulk Plants X X- 7

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CTG Source Category Negative Declaration CTG Reference Document 2006 RACT SIP 2009 RACT SIP 2014

RACT SIP Graphic Arts Rotogravure and Flexography EP A

- 450/2

- 78

- 033

– Control of Volatile Organic Emissions from Existing Stationary Sources

– Volume VIII: Rotogravure and Flexography X X

Industrial Cleaning Solvents EPA

- 453/R

- 06

- 001

– Control Techniques Guidelines for Industrial Cleaning Solve nts X X X

Large Appliance Coating EPA

- 450/2

- 77

- 034

– Control of Volatile Organic Emissions from Existing Stationary Sources, Volume V: Surface Coating of Large Appliances X X

Large Appliance Coating EPA

- 453/R

- 07

- 004

– Control Tec hniques for Large Appliance Coatings X X

Magnet Wire Coating EPA

- 450/2

- 77

- 033

– Control of Volatile Organic Emissions from Existing Stationary Sources

– Volume IV: Surface Coating of Insulation of Magnet Wire X X

Metal Can Coating M etal Coil Coating EPA

- 450/2

- 77

- 008

– Control of Volatile Organic Emissions from Existing Stationary Sources

– Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light

- Duty Trucks X X

Metal Furniture EPA

- 450/2

- 77

- 032

– Control of Volatile Organic Emissions from Existing Stationary Sources

– Volume III: Surface Coating of Metal Furniture X X

Metal Furniture Coatings EPA

- 453/R

- 07

- 005

– Control Techniques Guidelines for Metal Furniture Coatings X X

M etal Parts and Products EPA

- 450/2

- 78

- 015

– Control of Volatile Organic Emissions from Existing Stationary Sources

– Volume VI: Surface Coating of Miscellaneous Parts and Products X X

Miscellaneous Industrial Adhesives EPA

- 453/R

- 08

- 005

– Contr ol Techniques Guidelines for Miscellaneous Industrial Adhesives X X X- 8

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CTG Source Category Negative Declaration CTG Reference Document 2006 RACT SIP 2009 RACT SIP 2014

RACT SIP Miscellaneous Metal and Plastic Parts Coatings EPA

- 453/R

- 08

- 003

– Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings X X

Natural Gas/ Gasoline EPA

- 450/2

- 83

- 007

– Control of VOC Equipment Leaks from Natural Gas/Gasoline Processing Plants X X

Offset Lithographic Printing and Letterpress Printing EPA

- 453/R

- 06

- 002

– Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing X X

Paper and Fabric Coating EPA

- 450/2

- 77

- 008

– Control of Volatile Organic Emissions from Existing Stationary Sources

– Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light

- Duty Trucks X X

Paper, Film, and Foil Coatings EPA

- 453/R

- 07

- 003

– Control Techniques Guidelines for Paper, Film, and Foil Coatings X X

Perchloroethylene Dry Cleaning Systems 2 EPA

- 450/2

- 78

- 050

– Control of Volatile Organic Emissions from Perchloroeth y le ne Dry Cleaning Systems X

Petroleum Liquid Storage Tanks EPA

- 450/2

- 77

- 036

– Control of VOC Emissions from Storage of Petroleum Liquids in Fixed Roof Tanks X X

Petroleum Liquid Storage Tanks EPA

- 450/2

- 78

- 047

– Control of VOC Emissions fro m Petroleum Liquid Storage in External Floating Roof Tanks X X

Pharmaceutical Products EPA

- 450/2

- 78

- 029

– Control of Volatile Organic Emissions from Manufacture of Synthesized Pharmaceutical Products X X

Resin Manufacturing EPA

- 45 0/3

- 83

- 008

– Control of VOC Emissions from Manufacture of High

Density Polyethylene, Polypropylene, and Polystyrene Resins X X

2 This item is not a CTG because EPA exempted perchloroeth y len e as a VOC for purposes of ozone SIPs

. 61 FR 4588 (February 7, 1996)(codified at 40 CFR 51.100(s)(1) )

.- 9

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CTG Source Category Negative Declaration CTG Reference Document 2006 RACT SIP 2009 RACT SIP 2014

RACT SIP Resin Manufacturing EPA

- 450/3

- 83

- 006

– Control of VOC Fugitive Emissions from Synthetic Organic Chemical Polymer and Resin Manufacturing Equipment X X

Refineries EPA

- 450/2

- 77

- 025

– Control of Refinery Vacuum Producing Systems, Wastewater Separators, and Process Unit Turnarounds X X

Refineries EPA

- 450/2

- 78

- 036

– Control of VOC Leaks from Petrole um Refinery Equipment X X

Rubber Tire Manufacturing EPA

- 450/2

- 78

- 030

– Control of Volatile Organic Emissions from Manufacture of Pneumatic Rubber Tires X X

Ship Coatings 61 FR 44050 Shipbuilding and Ship Repair Operations (Surface Coating) X X

Ship Coatings EPA

- 453/R

- 94

- 032

– Alternative Control Technology Document

– Surface Coating Operations at Shipbuilding and Ship Repair Operations (Surface Coating) X

Solvent Cleaning Degreasers EPA

- 450/2

- 77

- 022

– Control of Volatile Organic Emissions from Solvent Metal Cleaning X X

Synthetic Organic Chemical Manufacturing EPA

- 450/3

- 84

- 015

– Control of VOC Emissions from Air Oxidation Processes in Synthetic Organic Chemical Manufacturing Industry X X

Synthetic Organic Chemical Manufacturing EPA

- 450/4

- 91

- 031

– Control of VOC Emissions from Reactor Processes and Distillation Operations in Synthetic Organic Chemical Manufacturing Industry X X

Wood Coating Factory Surface of Flat Wo od Paneling EPA

- 450/2

- 78

- 032

– Control of Volatile Organic Emissions from Existing Stationary Sources

– Volume VII: Factory Surface of Flat Wood Paneling X X

Wood Furniture Coating EPA

- 453/R

- 96

- 007

– Control of VOC Emissions from Wood Furnitu re Manufacturing Operations X X- 10

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EPA EVALUATION AND RECOMMENDATIONS

EPA evaluated the following elements of FR AQMD ’s 20 0 6, 2009 and 2014 RACT SIP s :

 Efforts to identify all source categories within the District requiring RACT.

 N egative declar ations where there are no facilities subject to a CTG

.

 List of the State/local regulations that implement RACT.

 The bases for concluding that all referenced regulations fulfill RACT.

To review FRAQMD’s negative declarations, we looked at CARB’s emissions inventory web page 3 and sorted the listing to identify all VOC sources greater than 2.2 tons/year 4 and NOx sources greater than 25 tpy. We also reviewed EPA Region 9’s internal mapping program to identify locations of VOC and NOx Sources in the south Sut ter County ozone nonattainment

area , and performed an internet yellow pages search of sources that may be covered by the negative declarations.

The following documents were also used to support our review:

 “ Final Rule to Implement the 1997 8

- Hour Ozone Na tional Ambient Air Quality Standard

– Phase 2 ” (70 FR 71612; November 29, 2005).

 Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State Implementation Plan Requirements”

– Final Rule (8 0 FR 12264 ; March 6 , 2015 ).

 “ State Impleme ntation Plans, General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990 ” (57 FR 13498; April 16, 1992).

 Enforceability

- Section 110(a) of the CAA requires enforceable emission limitations and other control measures. Sever al EPA guidance documents are used to evaluate rule enforceability, including 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, 19 90 ("The Blue Book"), and EPA Region IX’s Guidance Document for Correcting Common VOC and Other Rule Deficiencies

, August 21, 2001 (the "Little Bluebook").

 “ State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for Implementation of Title I of the C lean Air Act Amendments of 1990 ” (57 FR 55620, November 25, 1992) ("the NOx Supplement").

 Memorandum from William T. Harnett to Regional Air Division Directors, (May 18, 2006), “RACT Qs & As

– Reasonably Available Control Technology (RAC T) Questions and Answers”.

3 http://www.arb.ca.gov/app/emsinv/facinfo/facinfo.php CARB’s emissions inventory we b page lists permitted sources in the FRAQMD and does not differentiate between sources located in the attainment versus the nonattainment area.

4 The cut

- off of 2.2 tpy was selected as a natural separation point in CARB’s emissions inventory for FRAQMD. I t was also selected as a conservative threshold to review sources as many of the CTGs have an applicability threshold of 2.7 or 3 tpy.- 11

-

 RACT SIPs, 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.

 EPA's CTGs http://www.epa.gov/groundlevelozone/SIPToolkit/ctgs.html

 CARB’s emissions inventory database http://www.arb.ca.gov/app/emsinv/facinfo/facinfo.ph p

 FR AQMD

, CARB and EPA Region IX databases of FR AQM D rules FR AQM D: http://www.fraqmd.org/Rules.html CARB: http://www.arb.ca.gov/rldb/rldb.htm EPA: http://epa.gov/region09/air/sips/index.html

1. VOC R ules for S ources S ubject to a CTG

FR AQMD Action

– 2006 RACT SIP :

The District listed 26 permitted stationary sources in south Sutter County. No major sources were identified. None of the sources were subject to a CTG except for the gasoline service station CTG. The District concluded that District Rule 3.8 Storage and Transfer of Gasoline (amended 06/1991) and Rule 3.12 Benzene Airborne Toxi c Control Measure

– Retail Service Stations (amended 06/1991) are compatible with CTG requirements on Phase I Vapor Recovery System for both retail and private gasoline service stations. The 06/1991 version of District Rule 3.8 allowed an exempt ion for st ations that do not exceed 25,000 gallons per month

.

EPA Evaluation

– 2006 RACT SIP :

We reviewed Table 1 of the 2006 RACT SIP and did not identify any additional sources subject to a CTG. We also checked CARB’s 2006 emissions inventory for sources in sou th Sutter County and did not identify any additional sources that might be subject to a CTG . The emission sources that we found included the following: natural gas production, rice dryers, auto body shop, used construction equipment, concrete batch plant

, and internal c ombustion engines. These sources are not subject to CTGs.

Regarding the gasoline station CTG, the 06/1991 version of Rule 3.8 do es not satisfy the applicable CTG: EPA

- 450/R

- 75

- 102 Design Criteria for Stage I Vapor Control Systems

– Gas oline Service Stations which has a 10,000 gallon per month applicability threshold 5 while rule 3.8 contained a 25,000 gallon per month exemption. In 2014 , FRAQMD amended Rule 3.8 to comply with the service station CTG and submitted the revised rule to EPA

. EPA is taking action to approve this rule concurrently with our action on the RACT SIPs.

FRAQMD Action

– 2009 RACT SIP :

5 Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations; Clarification to Appendix D of November 24, 1987 Federal Register (aka “T he Blue Book ”) , Table 1. www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf- 12

-

FRAQMD reviewed its master database of permitted facilities and identified 32 stationary sources in south Sutter County. The Dist rict also reviewed its database for major sources, those emitting at least 25 tons or more of VOC or NOx and did not identify any major sources. The District included in its review the 11 new or updated CTGs issued from 2006 to 2008 in its determination. Regarding Rule 3.8, the gasoline station rule, FRAQMD indicated it planned to amend the rule to satisfy the CTG.

EPA Evaluation

– 2009 RACT SIP : The primary purpose of FRAQMD’s 2009 RACT SIP was to submit negative declarations for the CTGs that EPA iss ued from 2006 to 200 8

. Based on our research, t he permitted stationary sources in the south Sutter County ozone nonattainment area that are not subject to a CTG include: rice dryers, concrete batch plant, internal combustion engines, animal crematory, use d construction equipment, and an auto body shop.

Table 1 presents our comparison of the negative declarations reported by FRAQMD in the 2006, 2009 and 2014 RACT SIPs. The 11 new/updated CTGs, that were not extant at the time the 2006 RACT SIP was develop ed , are shown as negative declarations in the 2 009 RACT SIP column. Rule 3.8, the gasoline station rule, was later amended in 2014 in an effort to satisfy the CTG.

FRAQMD Action

– 2014 RACT SIP :

FRAQMD prepared the 2014 RACT analysis pursuant to Sectio ns 182(b)(2) and (f) of the CAA for the 2008 8

- hour ozone NAAQS. The District reviewed the existing facilities and sources in the nonattainment portion of Sutter County. Most of the sources that existed when the 2006 and 2009 RACT analyses occurred are s till operating. None of the 37 sources the District identified in its 2014 RACT SIP are subject to a CTG except for the gasoline station CTG. On June 2, 2014, FRAQMD adopted amendments to Rule 3.8 that strengthened the control measures of the Rule in an effort to make the rule as stringent as the CTG.

EPA Evaluation

– 2014 RACT SIP :

We reviewed Table 1 of the 20 14 RACT SIP (“Summary of Source Types in South Sutter County”) and did not identify any additional sources subject to a CTG. We also checked CARB’s 20 12 emissions inventory for sources in south Sutter County and did not identify any additional sources that might be subject to a CTG. Based on our research, t he permitted emission sources in the south Sutter County ozone nonattainment area includ ed the following: rice dryers, concrete batch plant, internal combustion engines, animal crematory, u sed construction equipment, and auto body shop.

Table 1 includes the negative declarations reported by FRAQMD for the 2014 RACT SIP. Regarding the adopte d amendments to Rule 3.8 to satisfy the gasoline station CTG, those amendments have been analyzed by EPA in a separate TSD.

2. N egative D eclarations W here T here are no F acilities S ubject to a CTG

FR AQMD A ction

– 2006 RACT SIP :- 13

-

Table 2 of the FR AQMD 200 6 R ACT SIP lists CTG categories that are applicable to minor sources in south Sutter County and annotates those CTGs for which the District has no stationary sources subject to the CTGs

. FR AQM D compiled this list by comparing its rules against EPA’s list of CTGs and ACTs and reviewing its permits, emissions inventory, and consulting with knowledgeable staff of the District’s permit and enforcement divisions to determine if it had any stationary sources subject to the CTGs . For the negative declarations liste d in FR AQM D’s 20 0 6 RACT SIP Table 2, the District indicated it does not anticipate sources in t hese categories in the future.

EPA E valuation

– 2006 RACT SIP :

FR AQM D’s 200 6 RACT SIP, Table 2

, lists the n egative d eclarations for the CTG source categories where the District has no sources subject to a CTG . A negative declaration is not required for ACTs or for other non

- CTG source categories. T able 1 of this TSD lists the CTG source categories for the 2006 RACT SIP along with the negative declarations for the 2009 and 2014 RACT SIPs. EPA is acting on the negative declarations listed in Table 1 of this TSD

.
For the 2006 negative declarations, w e searched CARB’s emissions inventory database for 2006 to verify there wer e no facilities in FR AQM D that might be subject to the CTGs listed in Table 1

. W e concur with the District’s negative declaration s for 2006

.

FRAQMD Action

– 2009 RACT SIP:

FRAQMD’s 2009 RACT SIP, Table 1, lists the 11 new or updated CTGs that were issued from 2006 to 2008. The District analyz ed its permitted facilities database for facilities that would be subject to each of the 11 CTGs, and found no sources located in the south Sutter County nonattainment area

. The District does not anticipate any new sources that may be subject to the 2006

– 2008 CTGs

.

EPA Evaluation

– 2009 RACT SIP:

We reviewed FRAQMD’s list of permitted facilities in 2009 and found that nearly all of the same facilities that were operating in 2006 were still in operation with similarly low emission levels as in 2006

. We searched CARB’s emissions inventory database for 2009 to verify there were no facilities that might be subject to the CTGs listed in Table 1 . We concur with the District’s negative declarations for 2009.

FRAQMD Action

– 2014 RACT SIP:

FRAQMD’s 2014 R ACT SIP, Appendix C, lists the negative declarations for the CTG sources in south Sutter County

. FRAQMD reported in Appendix A that there were 37 permitted sources as of June 3, 2014, five more than were reported in the 2009 RACT SIP. The District does n ot anticipate sources in the CTG categories in the future.- 14

-

FRAQMD indicated that gasoline service stations are subject to CTGs. On June 2, 2014, FRAQMD adopted amendments to Rule 3.8 that lowered the gasoline station exemption threshold for requiring vap or recovery systems to a maximum of 10,000 gallons per month.

EPA Evaluation

– 2014 RACT SIP:

We reviewed FRAQMD’s list of permitted facilities in 2014, Appendix A, and found that most of the facilities that were operating in 2009 were still in operation with similarly low emission levels as in 2009. The facility with the largest source of VOC emissions was Holt of California, but the reported potential emission level was reduced to 7.85 tons/year for 2014 instead of 8.75 tons/year reported for 2009. Th e reduction is primarily attributed to a new above ground storage tank having improved emissions control. The permitted level of 2

, 000 gallons/year of paint usage has not changed from 2006 to 2014. T able 1 in the 2014 RACT SIP summarizes the source types in south Sutter County: rice dryers, concrete batch plant, private gasoline dispensing, retail gasoline, emergency internal combustion engines, animal crematory, automotive repair, soil remediation, and various equipment (Holt). These are essentially the same source types as reported in the 2009 RACT SIP.

Table 1 compares the negative declarations for 2014 to the negative declarations for 2006 and 2009. The declarations are the same for each year except that the 2006 RACT SIP does not include the 11 n ew or updated CTGs that were adopted from 2006 to 2008. We agree with the District’s certification that there are no new sources subject to the CTG categories in Table 1 for 2014

.

3. Negative D eclaration for Major non

- CTG Sources of VOC or NOx

CAA § 182(b)(2) and (f) require RACT for stationary source categories covered by CTG document s and all other major st ationary sources of VOCs or NOx. FR AQM D was initially classified as serious nonattainment for the 1997 8

- hour ozone NAAQS for south Sutter County , but was subsequently reclassified as severe for the 1997 ozone standard

. Later i t was classified as severe nonattainment for the 2008 8

- hour NAAQS. 2 A major source in a

severe ozone nonattainment area is defined as a stationary source that emits, or h as the potential to emit, at least 25 tons p er year of VOCs or NOx. 6 A negative declaration may be submitted where there are no major non

- CTG sources located in the nonattainment area

. 7

FR AQMD Action :

FR AQM D’s 20 0 6, 2009 and 2014 RACT SIP s report s that the largest stationary emission source in the nonattainment area , Holt of California, emits approximately 8 t ons per year of ROG (VOCs).

6 See CAA §§ 182(b) (2) , (d) and (f) and 302(j).

7 Memorandum from W illiam T. Harnett to Regional Air Division Directors, (May 18, 2006), “RACT Qs & As

– Reasonably Available Control Technology (RACT) Qu estions and Answers, ” page 7

.- 15

-

EPA Evaluation :

We re viewed FR AQMD’s negative declaration s with respect to major non

- CTG sources of NOx or VOCs . In order to confirm that there are no such sources in the nonattainment area,

w e searched CARB’s emissions inventory database

. We found no major stationary sources of NOx or VOCs, but we note that Holt of California is reported by FRAQMD to have the capabili ty to emit 195 pounds per day of VOC emissions in its metal coating operations. Such an emissions rate would produce over 30 tons/year which would make the facility a major source of emissions requiring RACT controls. However, the facility’s pre

- construct ion permit also includes a throughput limit of 2000 pounds per year, as well as limits on the VOC content of coatings and solvents. 8 Collectively, these requirements limit the facility’s potential to emit to 7.85 tons/year of VOC

. 9 Therefore, the facility is not subject to RACT.

Conclusion :

We agree with the District’s certification that there are no sources subject to the CTG categories in Table 1 and no major non

- CTG sources

. The only sources in the south Sutter nonattainment area that are subject to a CTG are gasoline service stations. In a separate TSD, we have evaluated gasoline station Rule 3.8 and determined that it fulfills RACT requirements. Accordingly, we recommend full approval of FRAQMD’s RACT SIPs and negative declarations for 2006, 2009 and 2014 under section 110(k)(3) as meeting the requirements of section 110 and Part D of the CAA as amended in 1990.

REFERENCES

1. Feather River Air Quality Management District 2006 Reasonably Available Control Technology Analysis for State Implement ation Plan, adopted December 4, 2006; submitted July 11, 2007.

2. Feather River Air Quality Management District 2009 Reasonably Available Control Technology (RACT) State Implementation Plan (SIP) Revision for FRAQMD Nonattainment Areas Sutter Buttes and South Sutter County Portion of the Sacramento Federal 8

- Hour Ozone (SNFA), Negative Declaration for Control Techniques Guidelines Issued 2006

- 2008, adopted June 1, 2009; submitted October 27, 2009.

3. 2014 Reasonably Available Control Technology (RACT) Analysis and Negative Declaration Prepared by the Feather River Air Quality Management District pursuant to Sections 182(b)(2) and 182(f) of the Clean Air Act for the south Sutter County portion of the Sacramento Metro Nonattainment Area for the 2008 8

- Hou r Ozone National Ambient Air Quality Standard, adopted August 4, 2014; submitted September 29, 2014.

8 Feather River Air Quality Management District

, Authority to Construct/Permit to Operate P 16003 , Holt of California Incorporated (December 17, 2007).

9 16003G (Summary) Holt of California Potential to Emit Calculations (January 13, 2010) . See also, Reasonably Available Control Technology (RACT) Analysis and Negative Declaration, Staff Report, A ugust 4, 2014, page 7.- 16

-

4

. “ Final Rule to Implement the 8

- Hour Ozone National Ambient Air Quality Standard

– Phase 2” 70 FR 71612; November 29, 2005). http://www.gpo.gov/fdsys/pkg/FR

- 2005

- 11

- 29/pdf/05

- 22698.pdf

5 . “ Fin al Rule To Implement the 1997 8

- Hour Ozone National Ambient Air Quality Standard: Classification of Areas That Were Initially Classified U nder Subpart 1; Revision of the Anti

Backsliding Provisions To Address 1

- Hour Contingency Measure Requirements; Deletion of Obsolete 1

- Hour Ozone Standard Provision ”

– Final Rule ( 77 FR 28424 ; May 14, 2012)

5

. “Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State Implementation Plan Requirements”

– Final Rule ( 80 FR 12264 ; March 6, 201 5

. http://www.gpo.gov/fdsys/pkg/FR

- 2015

- 03

- 06/pdf/2015

- 04012.pdf

6. “ 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).

7

. Issues Relatin g 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")

.

8

. EPA Region IX’s Guidance Document for Correcting Common VOC and O ther Rule Deficiencies

, August 21, 2001 (the "Little Bluebook").

9

. “ 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” ).

10

. RACT Qs & As

– Reasonably Available Control Technology (RACT): Questions and Answers, May 18, 2006 Memorandum from William T. Harnett, Director, Air Quality Policy Division, to Regional Air Division Directors. http://www.epa.gov/ttn/caaa/t1/memoranda/ractqanda.pdf

11

. RACT SIPs, Letter dated March 9, 2006 from EPA Region IX (Andrew Steckel) to CARB (Kurt Karperos) describing Region IX’s understanding of what constituted a minimally acceptable RACT SIP.

12

. EPA's CTGs and ACTs http://www.epa.gov/groundlevelozone/SIPToolkit/ctgs.html

13

. CARB’s emissions inventory database http://www.arb.ca.gov/app/emsinv/facinfo/facinfo.php

14

. FR AQM D, CARB and EPA Region IX databases of FR AQMD rules FR AQMD : http://www.fraqmd.org/Rules.html CARB: http://www.arb.ca.gov/rldb/rldb.htm EPA: http://epa.gov/region09/air/sips/index.html- 17

-

15. Feather River Air Quality Management District, Authority to Construct/Permit t o Operate P16003, Holt of California Incorporated (December 17, 2007).

16. 16003G (Summary) Holt of California Potential to Emit Calculations (January 13, 2010).