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 Technology (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

Reasonably Available Control Technology Analysis 

and Negative Declarations

July 3, 2014

Prepared by: James Shears

Reviewed by: Andrew Steckel

January 2015
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RULE IDENTIFICATION -

Agency: Feather River Air Quality Management District (FRAQMD)

SIP Approved Version: None

Subject of this TSD: FRAQMD Reasonably Available Control Technology

2006 Reasonably Available Control Technology (RACT) Analysis 

for State Implementation Plan (SIP), dated November 2006

Adopted December 4, 2006

Submitted 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

Reasonably 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 to 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 classified as a severe1 ozone nonattainment 

area for the 1997 and 2008 8-hour national ambient air quality standards (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 the 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 mountain 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.
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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 

negative 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 wire coating, 

metal can/coil coating, metal furniture, metal parts and products coating, natural gas/gasoline 

equipment leaks at processing plants, paper and fabric coating, petroleum liquid storage 

tanks, pharmaceutical products, resin manufacturing, refineries, 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 resolution 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 ozone nonattainment area. On June 1, 

2009 FRAQMD adopted negative declarations for these 11 CTGs. These negative 

declarations covered industrial cleaning solvents, offset lithographic printing and letterpress 

printing, flexible package printing, flat wood paneling 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-duty 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, the southern portion of Sutter County was designated nonattainment

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, which updated

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. The 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 December 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 
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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 SIP 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 table 

of these permitted facilities, the business 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. 

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 Gasoline (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 District concluded that both rules enable the exemption 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 adopted its 2009 RACT SIP revision, which included negative declarations 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 

CAA 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 Sutter 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 the Ozone State Implementation Plan Revision Reasonably 

Available Control Technology as Applicable to the 8-Hour Ozone Standard – adopted 

on June 1, 2009.
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FRAQMD reviewed its master database of permitted facilities and identified 32 permitted 

stationary sources 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 source, a heavy 

equipment dealer, emitted 8.75 tpy of total hydrocarbon mostly due to the painting of 

construction equipment. The District took into account the 11 new or updated CTGs issued 

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 

CARB 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 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-Hour Ozone National Ambient 

Air 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 

business 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, the District 

adopted amendments to Rule 3.8 on June 2, 2014 and submitted it to EPA for approval into 

the SIP. The revisions to the rule are 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.
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Table 1 – Negative Declarations 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 Manufacturing 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, Automobiles, 

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 

Volatile 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 

Techniques 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 – Control 

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 Organic 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
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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 

EPA-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 Solvents

 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 

Techniques 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

Metal 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

Metal 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 – Control 

Techniques Guidelines for 

Miscellaneous Industrial Adhesives

 X X X
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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 

Systems2

EPA-450/2-78-050 – Control of 

Volatile Organic Emissions from 

Perchloroethylene 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 from 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-450/3-83-008 – Control of VOC 

Emissions from Manufacture of HighDensity Polyethylene, Polypropylene, 

and Polystyrene Resins

 X X

 

2 This item is not a CTG because EPA exempted perchloroethylene as a VOC for purposes of ozone SIPs. 61 FR 

4588 (February 7, 1996)(codified at 40 CFR 51.100(s)(1)).
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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 Petroleum 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 Wood 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 Furniture 

Manufacturing Operations

 X X
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EPA EVALUATION AND RECOMMENDATIONS

EPA evaluated the following elements of FRAQMD’s 2006, 2009 and 2014 RACT SIPs:

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

 Negative declarations 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 

page3 and sorted the listing to identify all VOC sources greater than 2.2 tons/year4 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 Sutter 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 National 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 (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).

 Enforceability - Section 110(a) of the CAA requires enforceable emission limitations and 

other control measures. Several 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, 1990 ("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 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, (May 18, 2006), 

“RACT Qs & As – Reasonably Available Control Technology (RACT) Questions and 

Answers”.

 

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

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. 
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 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.php

 FRAQMD, CARB and EPA Region IX databases of FRAQMD rules

FRAQMD: 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 Rules for Sources Subject to a CTG 

FRAQMD 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 Toxic 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 exemption for stations 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 south 

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 combustion

engines. These sources are not subject to CTGs. 

Regarding the gasoline station CTG, the 06/1991 version of Rule 3.8 does not satisfy the 

applicable CTG: EPA-450/R-75-102 Design Criteria for Stage I Vapor Control Systems –

Gasoline Service Stations which has a 10,000 gallon per month applicability threshold5 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 “The Blue Book”), Table 1. 

www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf
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FRAQMD reviewed its master database of permitted facilities and identified 32 stationary 

sources in south Sutter County. The District 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 issued from 2006 to 2008. Based on our research, the 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, used 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 developed, are shown as negative declarations in the 2009 

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 Sections 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 still 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 2014 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 2012 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, the permitted 

emission sources in the south Sutter County ozone nonattainment area included the following: 

rice dryers, concrete batch plant, internal combustion engines, animal crematory, used 

construction equipment, and auto body shop.

Table 1 includes the negative declarations reported by FRAQMD for the 2014 RACT SIP. 

Regarding the adopted amendments to Rule 3.8 to satisfy the gasoline station CTG, those 

amendments have been analyzed by EPA in a separate TSD. 

2. Negative Declarations Where There are no Facilities Subject to a CTG

FRAQMD Action – 2006 RACT SIP:
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Table 2 of the FRAQMD 2006 RACT 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. FRAQMD 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 

listed in FRAQMD’s 2006 RACT SIP Table 2, the District indicated it does not anticipate 

sources in these categories in the future. 

EPA Evaluation – 2006 RACT SIP:

FRAQMD’s 2006 RACT SIP, Table 2, lists the negative declarations 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. Table 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, we searched CARB’s emissions inventory database for 

2006 to verify there were no facilities in FRAQMD that might be subject to the CTGs listed in 

Table 1. We concur with the District’s negative declarations 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 analyzed 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 RACT 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 not anticipate sources in the CTG categories in the future.
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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 vapor 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. The 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. Table 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 new 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 Declaration for Major non-CTG Sources of VOC or NOx

CAA § 182(b)(2) and (f) require RACT for stationary source categories covered by CTG 

documents and all other major stationary sources of VOCs or NOx. FRAQMD 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 it

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 has the 

potential to emit, at least 25 tons per 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

FRAQMD Action:

FRAQMD’s 2006, 2009 and 2014 RACT SIPs reports that the largest stationary emission 

source in the nonattainment area, Holt of California, emits approximately 8 tons per year of 

ROG (VOCs). 

 

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

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

Reasonably Available Control Technology (RACT) Questions and Answers,” page 7.
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EPA Evaluation:

We reviewed FRAQMD’s negative declarations 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, 

we 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 

capability 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-construction 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 Implementation 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-Hour 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 P16003, 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, August 4, 2014, page 7.
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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. “Final Rule To Implement the 1997 8-Hour Ozone National Ambient Air Quality Standard: 

Classification of Areas That Were Initially Classified Under Subpart 1; Revision of the AntiBacksliding 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, 2015. 

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 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").

8. EPA Region IX’s Guidance Document for Correcting Common VOC and Other 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. FRAQMD, CARB and EPA Region IX databases of FRAQMD rules

FRAQMD: http://www.fraqmd.org/Rules.html

CARB: http://www.arb.ca.gov/rldb/rldb.htm

EPA: http://epa.gov/region09/air/sips/index.html
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15. Feather River Air Quality Management District, Authority to Construct/Permit to Operate 

P16003, Holt of California Incorporated (December 17, 2007).

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