SERVING THE COUNTIES OF NEVADA, PLUMAS AND SIERRA NORTHERN SIERRA AIR QUALITY MANAGEMENT DISTRICT Gretchen Bennitt, APCO

Main Office Quincy Field Office Truckee Field Office 200 Litton Drive, Ste. 320 Courthouse Annex 1345 0 Donner Pass Road, Suite B

P.O. Box 2509 P.O. Box 3981 P.O. Box 9766 Grass Valley, CA 95945 Quincy, CA 95971 Truckee, CA 96162
(530) 274

- 9360 / FAX: (530) 274

- 7546 (530) 283

- 4654 / FAX: (530) 283

- 0699 (530) 550

- 7872 / FAX: (530) 587

- 26 23 office@myairdistrict.com; www.myairdistrict.com



## REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT)

STATE IMPLEMENTATION PLAN (SIP) REVISION

FOR



## WESTERN NEVADA COUNTY

8

- HOUR OZONE NON

- ATTAINMENT AREA

NEGATIVE DECLARATIONS FOR CONTROL TECHNIQUES

GUIDELINES ISSUED IN 2008

Submitted In Partial Fulfillment of Requirements under the Federal Clean Air Act

Date for Public Hearing: April 25, 2011 (alternatively May 23, 2011 in case of April meeting cancellation)

Date for Rule Adoption: Same as Public Hearing (Unless comments received necessitate modification)

Prepared by Samuel F. Longmire, Air Pollution Control SpecialistSERVING THE COUNTIES OF NEVADA, PLUMAS AND SIERRA 1

INTRODUCTION

The Northern Sierra Air Quality Management District (NSAQMD) includes the rural California counties of Plumas, Sierra and Nevada. Western Nevada County was designated in 2004 by

EPA as a Non

- attainment Area for the national 1997 8

- hour ozone air quality standard, pursuant

to the federal Clean Air Act (CAA). The area was originally classified as a “Basic Non

attainment” area, but the Basic classification was subsequently remanded. EPA has indicated that in May, 2011, Western Nevada County will be proposed for reclassification as a Moder ate

Non

- attainment Area. The population of the Western Nevada County ozone Non

- attainment Area, which includes Grass Valley and Nevada City, is approximately 77,000.

The California Air Resources Board (ARB) has submitted to EPA a request for a Clean Data Finding for Western Nevada County (based on monitors indicating ozone concentrations below the federal standard). The NSAQMD anticipates that EPA will approve the Clean Data Finding. This would suspend some of the planning requirements in the CAA, but w ould not suspend requirements for Reasonably Available Control Technology (RACT) for ozone precursors.

The CAA requires certain categories of sources (specified in Section 183(e)) in ozone non

attainment areas to implement rules meeting RACT requirements for inclusion in California’s State Implementation Plan (SIP). RACT is defined as the lowest emission limitation that a particular source is capable of meeting by the application of control technology (i.e., devices, systems, process modification, or othe r apparatus or techniques that reduce air pollution) that is reasonably available, considering technological and economic feasibility. The RACT requirement is meant to ensure that ozone non

- attainment areas are taking reasonable steps to

minimize the emis sion of ozone precursors, which are oxides of nitrogen (NOx) and volatile organic compounds (VOCs). In order to assist areas in identifying and implementing RACT, EPA issues Control Techniques Guidelines (CTGs) for specific source categories. These serve to define RACT, and each non

- attainment area must implement measures laid out in a CTG, or the equivalent, if there are sources in the area to which that CTG applies. Failure to adopt rules fully satisfying RACT can result in federal sanctions including withholding of federal highway dollars and increased emission offset requirements for local, major emission sources.

The NSAQMD has already implemented all of the measures EPA identified as RACT via issuance of CTGs through 2007 that apply to existing sou rces in the non

- attainment area. In 2008, EPA issued 4 additional CTGs. None were issued in 2009 or 2010.

In February, 2010 the NSAQMD adopted Rule 228 (Metal Parts and Products Coating) to meet the requirements of one of the 2008 CTGs. This is the “Co ntrol Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings” (EPA

- 453/R

- 08

- 003, September 2008). Along with submission of that rule to EPA for inclusion in the SIP, the NSAQMD submitted a Negative Declaration for portions of that CTG th at do not apply to sources located within the NSAQMD (mainly the plastic parts coating provisions).SERVING THE COUNTIES OF NEVADA, PLUMAS AND SIERRA 2

A list of the three previously unaddressed 2008 CTGs is as follows:

1) Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials (EPA

- 453 /R

- 08

- 004, September 2008)

2) Control Techniques Guidelines for Miscellaneous Industrial Adhesives (EPA

- 453/R

- 08

- 005, September 2008)

3) Control Techniques Guidelines for Automobile and Light

- Duty Truck Assembly Coatings (EPA

- 453/R

- 08

- 006, September 20 08)

The NSAQMD evaluated each CTG for applicability in the non

- attainment area, as discussed herein. Accordingly, the NSAQMD has determined that none of these remaining three CTGs issued in 2008 apply to sources located in the non

- attainment area.

Thi s document is termed a “Negative Declaration,” and it provides supporting evidence for the NSAQMD’s determination. It also includes a commitment to adopt and implement RACT in the event that a source to which a CTG applies is identified in the non

- attainm ent area in the future. A Negative Declaration constitutes a revision to a non

- attainment area’s SIP. It must be approved by the governing body of the agency with jurisdiction over stationary sources of air pollution in the non

- attainment area, following a public notice and a public hearing, pursuant to Section 110(a) of the Clean Air Act.

CTG/RACT APPLICABILITY DETERMINATION OVERVIEW

The NSAQMD performed an evaluation of the applicability of the 3 CTGs listed above to

sources located in the non

- attai nment area. The two main factors determining applicability are source type and potential VOC emissions. The NSAQMD identified the types of sources to which each CTG may apply and screened all permitted sources (which includes all sources known to be capa ble of emitting more than 1,000 pounds/year of any criteria pollutant). The NSAQMD also researched the telephone book yellow pages, the Chamber Of Commerce membership roster and the Internet to make sure no sources that a CTG may apply to had been

missed in the normal permitting process.

INDIVIDUAL CTG APPLICABILITY ANALYSES

Fiberglass Boat Manufacturing Materials The NSAQMD reviewed the CTG, which applies to facilities emitting at least 15 pounds per day (or 5,475 pounds per year) of VOCs.

There a re no boat manufacturing facilities under permit with the NSAQMD.SERVING THE COUNTIES OF NEVADA, PLUMAS AND SIERRA 3

The NSAQMD found no boat manufacturing facilities in the local phone book. However, one company performs repairs on fiberglass boats. This is Evergreen Marine at 530

- 477

- 5922. The NSAQMD contacted Evergreen Marine and spoke with Gene. He said that there are no fiberglass boat manufacturing facilities in Nevada County. He also said that his company performs minor repairs on approximately two or three fiberglass boats per year.

Just to m ake absolutely certain that there are no boat manufacturers in the non

- attainment area, the NSAQMD searched the Grass Valley/Nevada County Chamber of Commerce membership and the Internet, and found none.

Miscellaneous Industrial Adhesives The NSAQMD revie wed the CTG, which applies to facilities emitting at least 15 pounds per day (or 5,475 pounds per year) of VOCs. This translates to roughly 2 gallons of adhesives, priming & cleaning materials per day. At the time of issuance of the CTG, EPA had determin ed that

there were 180 facilities in ozone non

- attainment areas throughout the nation emitting more than the threshold quantity of VOCs. This determination was based on a search of the National Emissions Inventory for Source Classification Codes 40200701 (Adhesive Application), 40200706 (Adhesive: Solvent Mixing), 40200707 (Adhesive: Solvent Storage), 40200710 (Adhesive: General), 40200711 (Adhesive: Spray), and 40200712 (Adhesive: Roll

- on). None of these exist in Nevada County.

In order to determine if there are any sources in the Western Nevada County Non

- attainment Area that exceed the CTG’s applicability threshold, the NSAQMD performed a search of currently permitted sources, the local phone book, the Internet and the Chamber of Commerce membership ro ster. Based on these searches, the NSAQMD concludes that there are no types of facilities that the CTG applies to in the Non

- attainment Area with the potential to emit more than a tiny fraction of the threshold quantity of VOCs.

Automobile and Light

- Duty Truck Assembly Coatings The NSAQMD reviewed the CTG, which applies to facilities emitting at least 15 pounds per day (or 5,475 pounds per year) of VOCs. The CTG states, “The automobile and light

- duty truck assembly coatings product category under section 183(e) of the CAA includes the primary coatings that are applied to (1) new automobile or new light

- duty truck bodies, or body parts for new automobiles or new light

- duty trucks, and (2) other parts that are coated along with these bodies or body parts. The category also includes additional coatings applied during the vehicle assembly process. Automobile and light

- duty truck assembly coatings most commonly are applied at automobile or light

- duty truck assembly plants. However, this 183(e) category also includes coatings used in facilities that perform these coating operations on a contractual basis.”

The types of sources to which the CTG applies are high

- profile sources which tend to be well

known in a local community. In order to verify that there a re subject sources in the Western Nevada County Non

- attainment Area that exceed the CTG’s applicability threshold, theSERVING THE COUNTIES OF NEVADA, PLUMAS AND SIERRA 4

NSAQMD performed a search of currently permitted sources, the local phone book, the Internet and the Chamber of Commerce membership roste r. Based on these searches, the NSAQMD concludes that there are no types of facilities that the CTG applies to in the Non

- attainment Area.

NEGATIVE DECLARATION

-- STATEMENT OF ADOPTION

By adoption of this document, the Northern Sierra Air Quality Man agement District Board of Directors declares that, to the best of its knowledge and following a publicly noticed public hearing, there are no existing or anticipated sources in the Western Nevada County federal ozone

Non

- attainment Area to which any of the three Control Techniques Guidelines promulgated by EPA during 2008 and evaluated herein (Fiberglass Boat Manufacturing Materials, Miscellaneous Industrial Adhesives, and Automobile and Light

- Duty Truck Assembly Coatings) apply.

By adoption of this docume nt, the Northern Sierra Air Quality Management District Board of Directors further declares that RACT will be adopted and implemented, consistent with legal requirements, for all new and existing sources subsequently identified in the Western Nevada County Non

- attainment Area to which any federally promulgated CTGs (or amendments to the CTGs) apply in the future.