UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX AIR DIVISION

Technical Support Document 

for 

Revisions to the California State Implementation Plan, 

Placer County Air Pollution Control District, 

Negative Declarations 

Adopted February 13, 2014 

Prepared by: Stanley Tong 

May 2014 
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RULE IDENTIFICATION -

Agency: Placer County Air Pollution Control District (PCAPCD) 

SIP Approved Version: There is no previous version of the 2014 negative declarations in 

the SIP, however PCAPCD previously adopted these negative 

declarations: 

 PCAPCD Negative Declarations 

 Adopted – October 7, 1997 

 Submitted – February 25, 1998 

 Approved – September 23, 1998 (63 FR 50766) 

Previous submittal: Adopted – December 14, 2006 

 Submitted – July 11, 2007 – Negative declarations submitted with 

PCAPCD’s Reasonably Available Control Technology SIP 

certification; not yet acted on by EPA

 

Subject of this TSD: PCAPCD Negative Declarations 

 Adopted – February 13, 2014 

 Submitted – April 14, 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 Placer County Air 

Pollution Control District (PCAPCD) falls under this requirement as it is classified as a severe 

ozone nonattainment area for the 1997 and 2008 8-hour national ambient air quality standard 

(“NAAQS”) for ozone (40 CFR 81.305). 

Under CAA § 182(b)(2) and (f), PCAPCD 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, areas may adopt a negative declaration 

documenting that the air district has no stationary sources or emitting facilities subject to the 

CTG documents. The negative declaration must go through the same public review 

requirements as any other SIP submittal. 

On October 7, 1997, PCAPCD adopted negative declarations for Aerospace Coatings; 

Industrial Waste Water Treatment; Plastic Parts Coating: Business Machines; Plastic Parts 

Coating: Other; Shipbuilding and Repair; Synthetic Organic Chemical Manufacturing, Batch 

Plants; and Synthetic Organic Chemical Manufacturing, Reactors. EPA approved these 

negative declarations into the SIP on September 23, 1998 (63 FR 50766). 
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To fulfill the RACT SIP requirements for the 1997 8-hour ozone standard, PCAPCD 

researched its sources and on December 14, 2006 adopted the negative declarations in Table 

1. EPA has reviewed the submitted materials but has not acted on PCAPCD’s RACT SIP 

(including the below negative declarations) pending resolution of issues related to scope of 

sources covered in PCAPCD’s RACT SIP. 

Table 1 – PCAPCD Negative Declarations for the 1997 8-hour Ozone Standard 

CTG Source Category Negative Declaration – CTG Reference Document 

Aerospace EPA-453/R-97-004 - Control of VOC Emissions from 

Coating Operations at Aerospace Manufacturing and 

Rework Operations 

Large Appliances EPA-450/2-77-034 - Control of Volatile Organic 

Emissions from Existing Stationary Sources, Volume 

V: Surface Coating of Large Appliances 

Magnet Wire EPA 450/2-77-033 - Control of Volatile Organic 

Emissions from Existing Stationary Sources, Volume 

IV: Surface Coating of Insulation of Magnet Wire 

Metal Furniture EPA-450/2-77-032 - Control of Volatile Organic 

Emissions from Existing Stationary Sources, Volume 

III: Surface Coating of Metal Furniture 

Ships 61 FR 44050 Shipbuilding and Ship Repair 

Operations (Surface Coating) 

Natural Gas/Gasoline EPA-450/2-83-007 - Control of VOC Equipment Leaks 

from Natural Gas/Gasoline Processing Plants 

Refineries EPA-450/2-77-025 - Control of Refinery Vacuum 

Producing Systems, Wastewater Separators, and 

Process Unit Turnarounds 

EPA-450/2-78-036 - Control of VOC Leaks from 

Petroleum Refinery Equipment 

Synthetic Organic 

Chemical 

EPA-450/3-84-015 - Control of VOC Emissions from 

Air Oxidation Processes in Synthetic Organic 

Chemical Manufacturing Industry 

EPA-450/4-91-031 - Control of VOC Emissions from 

Reactor Processes and Distillation Operations in 

SOCMI 

Pharmaceutical Products EPA-450/2-78-029 – Control of Volatile Organic 

Emissions from Manufacture of Synthesized 

Pharmaceutical Products 
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CTG Source Category Negative Declaration – CTG Reference Document 

Polyester Resin EPA- 450/3-83-008 - Control of VOC Emissions from 

Manufacture of High-Density Polyethylene, 

Polypropylene, and Polystyrene Resins 

EPA-450/3-83-006 - Control of VOC Fugitive 

Emissions from Synthetic Organic Chemical Polymer 

and Resin Manufacturing Equipment 

Rubber Tires EPA-450/2-78-030 - Control of Volatile Organic 

Emissions from Manufacture of Pneumatic Rubber 

Tires 

SUBMITTAL SUMMARY - 

PCAPCD analyzed its VOC sources and determined it did not have sources subject to 16 CTG 

categories. The District documented its findings in a staff report, 2014 Reasonably Available 

Control Technology State Implementation Plan Analysis, February 2014, "2014 RACT SIP 

Negative Declarations" and submitted the negative declarations to EPA as a SIP revision. 

 

PCAPCD reviewed its internal database of permitted sources, performed an internet search for 

key words, and reviewed City and County databases of businesses and conducted public 

outreach inviting public comment on the District's conclusion that there are no sources or 

reasonably foreseeable sources within the District which are subject to the CTGs in Table 2 

below. No comments were received by PCAPCD during the 30 day public comment period. 

On February 13, 2014, PCAPCD adopted the following negative declarations to support its 

RACT SIP for the 2008 8-hour ozone standard. 

Table 2 – PCAPCD Negative Declarations for the 2008 8-hour Ozone Standard 

CTG Source Category Negative Declaration – CTG Reference Document 

Aerospace EPA-453/R-97-004 - Control of VOC Emissions from 

Coating Operations at Aerospace Manufacturing and 

Rework Operations 

Automobile and Light-duty 

Truck Assembly Coatings 

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 

EPA 450/R-08-006 – Control Techniques Guidelines 

for Automobile and Light-duty Truck Assembly 

Coatings 
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CTG Source Category Negative Declaration – CTG Reference Document 

Dry Cleaning (Petroleum) EPA-450/3-82-009 – Control of Volatile Organic 

Compound Emissions from Large Petroleum Dry 

Cleaners 

Fiberglass Boat 

Manufacturing 

EPA 453/R-08-004 - Control Techniques Guidelines 

for Fiberglass Boat Manufacturing Materials 

Flexible Package Printing EPA-453/R-06-003 - Control Techniques Guidelines 

for Flexible Package Printing 

Large Appliances Surface 

Coatings 

EPA-450/2-77-034 - Control of Volatile Organic 

Emissions from Existing Stationary Sources, Volume 

V: Surface Coating of Large Appliances 

EPA 453/R-07-004 - Control Techniques Guidelines 

for Large Appliance Coatings 

Magnet Wire EPA 450/2-77-033 - Control of Volatile Organic 

Emissions from Existing Stationary Sources, Volume 

IV: Surface Coating of Insulation of Magnet Wire 

Metal Furniture Coatings EPA-450/2-77-032 - Control of Volatile Organic 

Emissions from Existing Stationary Sources, Volume 

III: Surface Coating of Metal Furniture 

EPA 453/R-07-005 - Control Techniques Guidelines 

for Metal Furniture Coatings 

Natural Gas/Gasoline EPA-450/2-83-007 - Control of VOC Equipment Leaks 

from Natural Gas/Gasoline Processing Plants 

Paper and 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 

Paper, Film, and Foil 

Coatings 

EPA 453/R-07-003 - Control Techniques Guidelines 

for Paper, Film, and Foil Coatings 

Pharmaceutical Products EPA-450/2-78-029 – Control of Volatile Organic 

Emissions from Manufacture of Synthesized 

Pharmaceutical Products 

Refineries EPA-450/2-77-025 - Control of Refinery Vacuum 

Producing Systems, Wastewater Separators, and 

Process Unit Turnarounds 

EPA-450/2-78-036 - Control of VOC Leaks from 

Petroleum Refinery Equipment 

Rubber Tires EPA-450/2-78-030 - Control of Volatile Organic 

Emissions from Manufacture of Pneumatic Rubber 

Tires 
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CTG Source Category Negative Declaration – CTG Reference Document 

Ships/Marine Coating EPA-453/R-94-032 Alternative Control Technology 

Document – Surface Coating Operations at 

Shipbuilding and Ship Repair Facilities and 

Ships 61 FR 44050 Shipbuilding and Ship Repair 

Operations (Surface Coating) 

Synthetic Organic 

Chemical 

EPA-450/3-84-015 - Control of VOC Emissions from 

Air Oxidation Processes in Synthetic Organic 

Chemical Manufacturing Industry 

EPA-450/4-91-031 – Control of VOC Emissions from 

Reactor Processes and Distillation Operations in 

SOCMI 

EPA EVALUATION AND RECOMMENDED ACTION 

In lieu of adopting RACT rules, Districts may adopt negative declarations for CTG source 

categories if there are no sources in the District covered by the CTG documents. 

To review PCAPCD’s negative declarations we looked at CARB’s emissions inventory web 

page1 and sorted the listing for all VOC sources greater than 2.2 tons/year2. We also reviewed 

EPA Region 9’s internal mapping program listing locations of VOC sources in Placer County, 

and performed an internet yellow pages search of sources that may be covered by the 

negative declarations. 

Based on our internet search, we identified one facility, Kracon Aircraft, that could be covered 

under the Aerospace CTG. Kracon Aircraft’s web page3indicates it refinishes aircrafts but we 

were unable to find Kracon Aircraft listed on CARB’s emissions inventory web page to 

determine if it were subject to the Aerospace CTG. PCAPCD’s investigation4revealed Kracon 

still refinishes aircrafts, but its emissions were well below the Aerospace CTG’s threshold of 25 

tpy and therefore is not subject to the CTG. 

We note that in 2006, PCAPCD adopted a negative declaration for the Polyester Resin 

category, but that this category did not appear in the current list of negative declarations in 

 

1

http://www.arb.ca.gov/app/emsinv/facinfo/faccrit.php?grp=1&dbyr=2012&all_fac=C&sort=ROGHi&co_=&ab_=&faci

d_=&dis_=PLA&city_=&fsic_=&fname_=&fzip_=&chapis_only=&CERR=&dd= 

2 The applicability threshold of several of the 2006-2008 CTGs is 2.7 tpy actual emissions, prior to emission 

controls. 

3 http://www.kracon.com/our.htm

4 Email dated 5/22/2014 from PCAPCD (Bruce Springsteen) to EPA Region IX (Stanley Tong), Re: PCAPCD Neg 

Decs – Q: Kracon Aircraft 
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Table 2. The District should submit a negative declaration for the following CTGs if there are 

no sources in the District subject to the CTGs. 

CTG Source Category Negative Declaration – CTG Reference Document 

Polyester Resin EPA- 450/3-83-008 - Control of VOC Emissions from Manufacture 

of High-Density Polyethylene, Polypropylene, and Polystyrene 

Resins 

EPA-450/3-83-006 - Control of VOC Fugitive Emissions from 

Synthetic Organic Chemical Polymer and Resin Manufacturing 

Equipment 

We agree with the District’s certification that there are no sources subject to the CTG 

categories in Table 2. EPA is approving these negative declarations submitted on April 14, 

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. Placer County Air Pollution Control District 2014 Reasonably Available Control Technology 

State Implementation Plan Update Analysis Staff Report, dated February 2014. 

2. Placer County Air Pollution Control District, Enclosure A, Negative Declarations. 

3. Placer County Air Pollution Control District, Board Resolution #14-02. 

4. 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"). 

5. Kracon Aircraft web page http://www.kracon.com/our.htm 

6. Email dated 5/22/2014 from PCAPCD (Bruce Springsteen) to EPA Region IX (Stanley 

Tong), Re: PCAPCD Neg Decs – Q: Kracon Aircraft