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 13450 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) 587-2623

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 Specialist

SERVING THE COUNTIES OF NEVADA, PLUMAS AND SIERRA

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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 Nonattainment” 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 Moderate 

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 would 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 nonattainment 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 other 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 emission 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 sources 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 “Control 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 that do not apply to sources located within the NSAQMD 

(mainly the plastic parts coating provisions).
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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 2008)

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. 

This 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-attainment 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-attainment 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 capable 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 are no boat manufacturing facilities under permit with the NSAQMD.
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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 make 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 reviewed 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 determined 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 roster. 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 wellknown in a local community. In order to verify that there are subject sources in the Western 

Nevada County Non-attainment Area that exceed the CTG’s applicability threshold, the 
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NSAQMD performed a search of currently permitted sources, the local phone book, the Internet 

and the Chamber of Commerce membership roster. 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 Management 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 document, 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.