Feather River Air Quality Management District 

Staff Report 

2006 Reasonably Available Control Technology 

(RACT) Analysis for State Implementation Plan (SIP) 

November 2006 
Executive Summary

The U.S. Environmental Protection Agency (EPA) published the Final Rule to implement 

the 8-Hour Ozone National Ambient Air Quality Standard—Phase 2 on November 29, 

2005 (70 FR 71611). The Phase 2 Rule includes a new section which is the Code of 

Federal Regulations (40 CFR 51.912) that requires the nonattainment areas to submit a 

revision to the State Implementation Plan (SIP) to meet the Reasonably Available Control 

Technology (RACT) requirements for volatile organic compounds (VOC) and nitrogen 

oxides (NOx) in accordance with Sections 182(b) (2) and 182(f) of the federal Clean Air 

Act. This requirement is referred as the RACT SIP. Two parts of the FRAQMD are 

designated nonattainment for the national ambient air quality standard (NAAQS) for 8-

hour ozone: southern Sutter County as serious nonattainment and atop (>2,000 ft) of 

Sutter Butte as nonattainment. 

RACT requirements apply to all source categories for which the U.S. EPA has published 

a Control technique Guideline (CTG) document as well as all major sources of VOC and 

NOx. The District staff performed a RACT analysis on District permitted sources and 

District rules for all CTG categories and major sources of VOC and NOx. As a result of 

this analysis, Staff has determined that the District has fulfilled the requirements of 

RACT, as applicable to the 8-Hour ozone standard, for all CTG source categories. The 

District staff also determines that there is no major source in the nonattainment areas 

within the FRAQMD. 

Staff has prepared a revision to the Ozone SIP to satisfy the federal RACT requirements. 

The proposed SIP revisions includes: 1) negative declarations for major sources for 

which neither south Sutter nor atop of Sutter Buttes has such sources; 2) negative 

declaration for CTG source category for atop of Sutter Buttes for there is no any source; 

and 3) CTG source category analysis for gasoline service stations in south Sutter. 

The District staff reviewed FRAQMD Rules 3.8 Storage and Transfer of Gasoline and 

3.12 Benzene Airborne Toxic Control Measure—Retail Service Stations for their 

compatibility with RACT requirements for CTG source category and concluded: 1) both 

FRAQMD Rules 3.8 and 3.12 exempt low-use gasoline service stations; 2) both rules are 

compatible with CTG requirements for gasoline service stations; and 3) it is not 

necessary for the FRAQMD to amend Rule 3.12 to revoke exemptions on low-use 

gasoline service station due to its cost effectiveness. 

2
Introductions 

RACT SIP

The U.S. Environmental Protection Agency (EPA) published the Final Rule to implement 

the 8-Hour Ozone National Ambient Air Quality Standard—Phase 2 on November 29, 

2005 (70 FR 71611). The Phase 2 Rule includes a new section which is the Code of 

Federal Regulations (40 CFR 51.912) that requires the nonattainment areas to submit a 

revision to the State Implementation Plan (SIP) to meet the Reasonably Available Control 

Technology (RACT) requirements for volatile organic compounds (VOC) and nitrogen 

oxides (NOx) in accordance with Sections 182(b) (2) and 182(f) of the federal Clean Air 

Act. This requirement is referred as the RACT SIP. 

RACT SIP must be submitted to U.S. EPA by California Air Resources Board (ARB) on 

behalf of the local air districts and must fulfill 40 CFR 51 Appendix V completeness 

criteria. 

U.S. EPA’s letter to ARB, dated March 9, 2006, stated the following necessary 

components in the RACT SIP: 

• Describe efforts to identify all source categories within the District 

requiring RACT, including CTG sources (i.e., covered by an EPA Control 

Technique Guideline document) and major non-CTG sources. 

• Submit negative declarations where there are no facilities (major or minor) 

within the District subject to a CTG. 

• For all categories needing RACT, list the state/local regulation that 

implements RACT. It may also be helpful to list the date EPA approved 

thee regulations as fulfilling RACT. 

• Describe the basis for concluding that the regulations fulfill RACT. 

Documents useful in establishing RACT include CTGS, Alternative 

Control Techniques guidance (ACTs), Maximum Achievable Control 

Technology (MACT) standards, New Source Performance Standards 

(NSPS), California Suggested Control Measures (SCM) and RACT/Best 

Available Retrofit Control Technology (BARCT) determinations, 

regulations adopted in other Districts, and guidance and rules developed 

by other state and local agencies. 

• If Districts use CAPCOA’s September 2003, Potential All Feasible 

Measures (AFM) Report to help demonstrate RACT, the RACT SIP 

should certify that local regulations are equivalent to AFM, justify the 

assumption that the AFM fulfilled RACT in 2003, and include some sort 

of certification/demonstration that no additional control have become 

more reasonable available since then. 

Nonattainment Areas in the FRAQMD

Two parts of the FRAQMD are designated nonattainment for the national ambient air 

quality standard (NAAQS) for 8-hour ozone: southern Sutter County as serious 

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nonattainment and atop (>2,000 ft) of Sutter Butte as nonattainment. The southern Sutter 

County is bounded on the north by Subaco Road and Bear River, on the east by Placer 

County, on the south by Sacramento County, and on the west by Yolo County. The 

Feather River Air Quality Management District (FRAQMD) is located in Northern 

Sacramento Valley Air Basin which is bounded on the north and west by the Coastal 

Mountain Range and on the east by the southern portion of the Cascade Mountain Range 

and the northern portion of the Sierra Nevada Mountains. These mountain ranges reach 

heights in excess of 6000 feet with peaks rising much higher. This provides a substantial 

physical barrier to locally generated pollution as well as that transport northward on 

prevailing winds from the Sacramento Metropolitan area (NSVAB Air Quality 

Attainment Plan, 2003). The vast majority of FRAQMD’s population lives and works 

below 1000 feet sea level, which is often subjected to inversion layers that, coupled with 

geographic barriers and high summer temperatures, create a high potential for air 

pollution problem. 

Source Identification 

The FRAQMD staff reviewed the District’s master database for permitted facilities in 

order to identify existing sources in south Sutter and atop of Sutter Buttes. The staff 

identified 26 permitted stationary sources in south Sutter and no source atop of Sutter 

Buttes. Table 1 presents permitted facilities in south Sutter, their permit ID number, 

business type, and their potential emissions of ozone precursors. 

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Table 1. Permitted Facilities in South Sutter 

Facility 

ID 

Company Name Site City Source Type Potential THC 

Emission 

(TPY) 

Potential NOx 

Emission 

(TPY) 

2113 Hamar Associates 

LLC 

Akrnak Natural gas 

production 

0.12 0.1 

6003 Bianchi/Sills Dryer 

& Storage 

Elverta Rice dryer 0 0.1 

6005 Pacific International 

Rice Mills, Inc. 

Robbins Rice dryer 1 3 

6006 Catlett Warehouse Grove Rice dryer 0.05 1.16 

6007 El Centro Storage Grove Rice dryer 0.01 0.2 

6014 Sutter Basin Growers 

Cooperative 

Landing Rice/bean 

dryer 

0.03 0.95 

6017 Van Dyke’s Rice 

Dryer Inc. 

Grove Rice dryer 0.03 1.23 

6019 Dana Bins Nicolaus Rice scalping 0 0 

11037 Broesch Automotive Landing Auto body 1.4 0 

14052 Perozzi’s 99 North Nicolaus Gas retail 0.73 0 

16003 & 

36055 

Holt of California, 

Inc. 

Grove Various 

equipment 

5.75/0.02 5.81/0 

20013 Trichert Readymix Grove Concrete batch 0.02 0.66 

21016 Sutter Mutual Water 

Co. 

Kirkville Gas private 0.12 0 

21028 Sutter County—

Trowbridge 

Nicolaus Gas private 0.99 0 

23008 GTE-Robbins C.O.-

Verizon 

Robbins ICE genset 0.04 0.26 

23009 WorldCom 

(Sacramento 

Junction) 

Elverta ICE genset 0.25 1.75 

23014 360 Networks 

Robbins Amp Site 

Robbins ICE genset 0.03 0.28 

23017 Level 3 

Communications 

Robbins ICE genset 0.02 0.32 

23032 Verizon WirelessRobbins Robbins ICE genset 0 0 

23034 Verizon WirelessEast Nicolaus Nicolaus ICE genset 0.01 0.07 

23035 Sysco Food Services 

of Sacramento, Inc. 

Grove ICE genset 0.17 3.42 

23041 SBC/Pacific BellPleasant Grove Grove ICE genset 0.01 0.22 

23043 SBC/Pacific BellEast Nicolaus East Nicolaus ICE genset 0.04 0.55 

23071 Clear Channel Radio Grove ICE genset 0.08 1.04 

23100 Western Wood 

Fabricators 

Elverta ICE Fire pump 0 0.08 

23121 New Cingular 

Wireless PCS, LLC 

Nicolaus Emergency 

ICE 

0.02 0.05 

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Major Source Identification

According to the potential emissions demonstrated Table 1, there are no major sources 

existing in south Sutter. The FRAQMD Rule 10.1 D. 20 defines a major source as “a 

major source for the affected pollutant if it emits or has the potential to emit an affected 

pollutant in quantities equal to or exceeding any of the following thresholds: For the 

SFNA portion of the FRAQMD—25 tons per year of nitrogen oxides, 25 tons per year of 

reactive organic compounds, 100 tons per year of carbon monoxide, 100 tons per year of 

PM10, or levels specified in the federal Clean Air Act of 1990, Section 112 (a)(1).” 

CTG Category Source Identification

There are seven different categories of facilities presented in Table 1, which are natural 

gas production, grain dryer, auto body shop, gas service, concrete batch, internal 

combustion engines, and miscellaneous. Table 2 presents CTG categories for non-major 

sources and the source existence in south Sutter. According to Table 2, the only existing 

CTG category source in south Sutter is service stations (gasoline service stations). 

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Table 2. CTG Categories That Are Applicable to Minor Sources in South Sutter 

CTG Category CTG Date FRAQMD Rule (Most Recent 

Amendment) 

FRAQMD Rule 

Requirements and 

Exemptions 

Aerospace 

Manufacturing 

Dec. 1997 No source 

Automobile Coating May 1977 No source 

Cutback Asphalt 1977 No source 

Dry Cleaning 

(Petroleum Solvent) 

Sep. 1982 No source 

Gasoline Service 

Stations 

Nov. 1975 FRAQMD Rule 3.8 Storage and 

Transfer of Gasoline (amended 

06/1991) 

FRAQMD Rule 3.12 Benzene 

Airborne Toxic Control 

Measure—Retail Service 

Stations (amended 06/1991) 

Rule 3.8: 

Requirements are 

compatible with Phase 

I Vapor Recovery 

System for new 

sources (exempts 

low-use) 

Rule 3.12: 

Phase I Vapor 

Recovery System 

(exempts low-use 

retail gasoline service 

stations); Phase II 

Vapor Recovery 

System (exempts 

private and low use). 

Gasoline Tank Trucks 

and Bulk Plants 

Oct. 1977, 

Dec. 1977 and 

Dec. 1978 

No source 

Graphic Arts 

(Rotogravure) 

Dec. 1978 No source 

Graphic Arts 

(Flexographic) 

Dec. 1978 No source 

Large Appliance 

Coating 

1977 No source 

Magnetic Wire 

Coating 

Dec. 1977 No source 

Metal Can Coating May 1977 No source 

Metal Coil Coating May 1977 No source 

Metal Furniture 

Coating 

Dec. 1977 No source 

Metal Parts and 

Products Coating 

June 1978 No source 

Natural Gas/Gasoline 

Processing 

Dec. 1983 No source 

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Table 2. CTG Categories That Are Applicable to Minor Sources in South Sutter (Cont.) 

CTG Category CTG Date FRAQMD Rule (Most Recent 

Amendment) 

FRAQMD Rule 

Requirements and 

Exemptions 

Paper and Fabric 

Coating 

May 1977 No source 

Petroleum Liquid 

Storage Tanks 

Dec. 1977 and 

Dec. 1978 

No source 

Pharmaceutical 

Products 

Manufacturing 

Dec. 1978 No source 

Resin Manufacturing 

– High Density 

Polyethylene, 

Polypropylene, and 

Polystyrene 

Nov. 1983 and 

Mar. 1984 

No source 

Refineries Oct. 1977 and 

June 1978 

No source 

Rubber Tire 

Manufacturing 

Dec. 1978 No source 

Ship Coating Aug. 1996 No source 

Solvent Cleaning 

(Degreasers) 

Nov. 1977 No source 

Synthetic Organic 

Chemical 

Manufacturing 

Mar. 1984, Dec. 

1984 and Aug. 

1993 

No source 

Wood Coating (Flat 

Wood Paneling) 

June 1978 No source 

Wood Furniture 

Coating 

Apr. 1996 No source 

Rule Analysis 

The District Rules 3.8 Storage and Transfer of Gasoline (amended 06/1991, see 

Appendix A) and 3.12 Benzene Airborne Toxic Control Measure—Retail Service 

Stations (amended 06/1991, see Appendix B) are compatible with CTG requirements on 

Phase I Vapor Recovery System for both retail and private gasoline service stations. 

Both rules exempt low-use stations due to a high cost effectiveness. 

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Appendix A. 

FRAQMD RULE 3.8 

STORAGE AND TRANSFER OF GASOLINE

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RULE 3.8 - STORAGE AND TRANSFER OF GASOLINE

(Adopted 6/91)

a. Any person who installs any gasoline storage tank with a capacity of 250 gallons 

or more which is not equipped with a permanent submerged fill pipe or other 

equipment referred to in this Rule is guilty of a misdemeanor. This provision does 

not apply to any storage tank which is used primarily for the fueling of 

implements of husbandry, as such vehicles are defined in Division 16 

(commencing with Section 3600) of the Vehicle Code. 

TRANSFER OF GASOLINE INTO STATIONARY STORAGE CONTAINERS

b.

1. A person shall not transfer or permit the transfer of gasoline from any 

delivery vessel (i.e., tank truck or trailer) into any stationary storage 

container with a capacity of more than 250 gallons unless 90% by weight 

of the vapors displaced from such transfer are prevented from being 

released to the atmosphere. 

The provisions of this section shall be subject to the following exceptions: 

a. The transfer of gasoline into any stationary storage container used 

primarily for the fueling of implements of husbandry as such 

vehicles are defined in Division 16 (Section 3600 et seq.) of the 

California Vehicle Code. 

b. The transfer of gasoline into any stationary storage container in 

existence prior to date of adoption of this rule when such container 

is served by a delivery vessel exempted by the Air Pollution 

Control Officer pursuant to Section 3a of this Rule. 

c. The transfer of gasoline into any stationary storage container in 

existence prior to adoption of this regulation which is equipped 

with an offset fill pipe. 

d. The transfer of gasoline into any stationary storage container 

installed prior to the effective date of this regulation for which the 

total monthly throughput of the facility does not exceed 25,000 

gallons. 

2. No person shall store gasoline in or otherwise use or operate any gasoline 

vessel unless such vessel is designed to be vapor tight. Any delivery vessel 

into which gasoline vapors are required to be transferred shall be filled 

only at a loading facility that is equipped with a system that prevents at 

least 90% by weight of the gasoline vapors displaced from entering the 

atmosphere. 

3.

a. The owner or operator of any bulk loading facility which was in 

operation prior to the date of adoption of this Rule and for which 

the annual throughput to stationary storage containers that are not 

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exempted from Section 1a does not exceed 500,000 gallons, may 

petition the Air Pollution Control Officer to have the facility's 

delivery vessels and other independently owned gasoline delivery 

vessels which are exclusively serviced at such facility exempted 

from the provisions of Section 2. The owner and operator of such a 

facility must petition annually to renew such exemptions. 

b. A person shall not load gasoline into any delivery vessel from any 

loading facility granted an exemption pursuant to Section 3a of this 

Rule unless such delivery vessel is loaded through a submerged fill 

pipe. 

4.

a. For the purposes of the Rule, the term "gasoline" is defined as any 

petroleum distillate having a Reid Vapor pressure of 4 pounds or 

greater. 

b. For the purposes of this Rule "gasoline vapors" means the organic 

compounds in the displaced vapors including any entrained liquid 

gasoline. 

c. For the purposes of this Rule, the term "submerged fill pipe" is 

defined as any fill pipe, the discharge opening of which is entirely 

submerged when the liquid level is 6 inches above the bottom of 

the container. "Submerged fill pipe" when applied to a container 

which is loaded from the side is defined as any fill pipe the 

discharge opening of which is entirely submerged when the liquid 

level is 18 inches above the bottom of the container. 

TRANSFER OF GASOLINE INTO TANK TRUCKS, TRAILER, AND 

RAILROAD TANK CARS AT LOADING FACILITIES 

c.

1. A person shall not load gasoline into any tank truck, trailer, or railroad 

tank car from any loading facility having an annual throughput of 

5,000,000 gallons or more unless the loading facility is equipped with a 

vapor collection and disposal system or its equivalent approved by the Air 

Pollution Control Officer. Loading shall be accomplished in such a 

manner that all displaced vapor and air will be vented only to the vapor 

collection system. Measures shall be taken to prevent liquid from the 

loading device when it is not in use or to accomplish complete drainage 

before the loading device is disconnected. 

2. The vapor disposal portion of the vapor collection and disposal system 

shall process all vapors and reduce the emission of gasoline vapors by at 

least 90% by weight of uncontrolled emissions. 

STORAGE OF GASOLINE PRODUCTS AT TERMINALS AND LARGE 

BULK LOADING FACILITIES 

d.

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1. A person shall not place, store or hold in any stationary tank, reservoir or 

other container of more than 40,000 gallons capacity gasoline unless such 

tank, reservoir or other container is a pressure tank maintaining working 

pressures sufficient at all time to prevent gasoline vapor or gas loss to the 

atmosphere, or is designed and equipped with one of the following vapor 

loss control devices, properly installed, in good working order and in 

operation. 

a. A floating roof of an approved type. The Control equipment 

provided for in this paragraph shall not be used if the gasoline has 

a vapor press of 11.0 pounds per square inch absolute or greater 

under actual storage conditions. All tank gauging and sampling 

devices shall be gas tight except when gauging of sampling is 

taking place. 

b. A vapor recovery system, of efficiency equivalent to a floating 

roof meeting the requirements of a) above, consisting of a vapor 

gathering system capable of collecting the gasoline vapors and 

gases discharged, and a vapor disposal system capable of 

processing such gasoline vapors and gases so as to prevent their 

emissions to the atmosphere and with all tank gauging and 

sampling devices gas tight except when gauging or sampling is 

taking place. 

c. Other equipment of equal efficiency, provided such equipment is 

submitted to and approved by the Air Pollution Control 

Office(should have criteria to determine the efficiency). 

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Appendix B. 

FRAQMD Rule 3.12 

BENZENE AIRBORNE TOXIC CONTROL MEASURE - RETAIL SERVICE 

STATIONS 

13
RULE 3.12 - BENZENE AIRBORNE TOXIC CONTROL MEASURE - RETAIL 

SERVICE STATIONS

(Adopted 6/91) 

a. Phase I Vapor Recovery System Requirements: 

1. No owner or operator shall transfer, permit the transfer, or provide 

equipment for the transfer of gasoline, and no other person shall transfer 

gasoline from a delivery tank equipped with a vapor recovery system into 

a stationary storage tank at a retail service station unless an ARB Certified 

Phase I vapor recovery system is installed on the stationary storage tank 

and used during the transfer. 

2. The provisions of subsection a.1., shall not apply to: 

a. A transfer to a stationary storage tank with a capacity of less than 

1.0 cubic meter (260 gallons). 

b. A transfer to a stationary storage container used the majority of the 

time for the fueling of implements of husbandry as defined in 

Division 16, Chapter 1, of the Vehicle code. 

c. A transfer to a stationary storage tank used exclusively to fuel 

motor vehicles with a fuel capacity of five gallons or less. 

d. An existing retail service station with an annual station gasoline 

throughput from tanks or other than those described in subsections 

a.2.a), a.2.b.), and a.2.c)., of 480,000 or fewer gallons during the 

calendar year prior to district adoption of this rule. If during any 

calendar year thereafter the gasoline throughput from such tanks at 

the existing retail service station exceed 480,000 gallons, this 

exemption shall cease to apply commencing with the first day of 

the following calendar year. 

e. A transfer to a stationary storage tank at an existing retail service 

station which receives gasoline exclusively from delivery tanks 

that are not required to be equipped with vapor recovery systems. 

3. Notwithstanding subsection a.2.d)., at the time of tank replacement at an 

existing retail service station, ARB Certified Phase I vapor recovery 

systems shall be installed and used thereafter on all of the station facilities, 

except those which are exempt from the Phase I requirement by 

subsections a.2.a)., a.2.b)., and a.2.c)., or a.2.e). 

b. Phase II Vapor Recovery System Requirements: 

1. No owner or operator shall transfer, permit the transfer, or provide 

equipment for the transfer of gasoline from a stationary storage tank at a 

retail service station into a motor vehicle fuel tank unless an ARBcertified Phase II vapor recovery system is installed and used during the 

transfer. 

2. The provisions of subsection b.1. shall not apply to: 

a. A transfer of gasoline from a stationary storage tank which is 

exempt from Phase I under subsection a.2.a)., a.2.b)., or a.2.c). 

b. An existing retail service station which is exempt from Phase I 

requirements under subsection a.2.d). 

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3. Notwithstanding subsection b.2.b.)., at the time of tank replacement at an 

existing retail service station, ARB Certified Phase II vapor recovery 

system shall be installed and used thereafter on all of the station facilities, 

except those which are exempt from the Phase II requirement by 

subsection b.2.a.). 

c. Correction of Defects: No owner or operator shall use or permit the use of any 

Phase II system or any component thereof containing a defect identified in Title 

17, California Code of Regulations, Section 94006 until it has been repaired, 

replaced, or adjusted, as necessary to remove the defect, and, if required under 

Health and Safety Code Section 41960.2, district personnel have inspected the 

system or have authorized its use pending reinspection. Nothing in this subsection 

shall excuse compliance with subsection b.1. 

d. Compliance Schedule: For purposes of this rule, the following compliance 

schedule shall apply: 

1. The owner or operator of any new retail service station subject to this 

section shall comply with the provisions of this rule at the time gasoline is 

first sold from the station. 

2. The owner or operator of an existing retail service station without ARBCertified Phase I and II vapor recovery system shall notify the Air 

Pollution Control Officer in writing in advance of an intended tank 

replacement and secure all permits and other approvals necessary for 

installation of Phase I and II vapor recovery systems. The owner or 

operator of an existing retail service station shall comply with the 

provisions of this rule upon completion of the tank replacement. 

3. The owner or operator of an existing retail service station subject to this 

rule, who has not earlier complied in accordance with subsection d.2., 

shall within 15 months after district adoption of this rule secure all permits 

and other approvals necessary for installation of the equipment required by 

this rule. The owner or operator shall comply with the provisions of this 

rule within 24 months after district adoption of this rule. 

4. Excluding those existing retail service stations subject to this rule as a 

result of tank replacement, the owner or operator of a previously exempt 

stationary storage tank or retail service station where the operation or 

annual throughput has changed such that the exemption from either the 

Phase I or II requirements or both is no longer applicable, shall comply 

with the rule's provisions in accordance with subsection d.3., above, 

provided that the first day the retail service station or stationary storage 

tank is no longer exempt shall be considered as the date of district 

adoption of this rule. 

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