SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

FINAL STAFF REPORT

NEGATIVE DECLARATION FOR THE

CTG FOR CONTROL OF VOLATILE ORGANIC EMISSIONS FROM

MANUFACTURE OF PNEUMATIC RUBBER TIRES (EPA-450/2-78-030)

December 16, 2010

Prepared by: Anna Myers, Air Quality Specialist

Reviewed by: George Heinen, Ru le Development Supervisor Errol Villegas, Strategies and Incentives Manager Samir Sheikh, Director of Strategies and Incentives

I. SUMMARY

Sections 182(b)(2) and 182(f) of the federal Clean Air Act (CAA) require the San Joaquin Valley Unified Air Pollution Control District (District) to implement R easonably Available Control Technology (RACT) for each category of volatile organic compound (VOC) sources covered by a Control Tec hniques Guideline (CTG) document and for any major stationary source not covered by a CTG document. Alternatively, areas may adopt a negative declaration docum ent that the District has no stationary sources or emitting facilities subject to the Environmental Protection Agency (EPA) CTG

documents.

District Rule 4681 (Rubber Tire Manufacturing) is subject to RACT requirements of the CTG for Control of Volatile Organic Emission s from Manufacture of Pneumatic Rubber Tires (EPA-450/2-78-030) but cu rrently does not incorporate every CTG requirement. However, there are no stationar y sources or emitting facilitie s subject to the CTG in the Valley, and the District does not anticipate these sources in the future. As such, staff recommends the District Governing Board adopt a Negative Declaration for the CTG for Control of Volatile Organic Emissions from Manufacture of Pneumatic Rubber Tires (EPA-450/2-78-030).

II. DISCUSSION

The CAA requires certain sources in ozone non- attainment areas to implement control
methods called RACT. EPA defines RACT as the lowest emissi on limitation that a particular source is capable of meeting by the application of control technology (i.e., devices, systems, process modification, or ot her apparatus or techniques that reduce air

1 Final Draft Staff Report for Proposeg Negative DeclarationSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Negative Decl aration for the CTG for Control Of Volatile Organic Emissions Fr om Manufacture of Pneumatic

Rubber Tires December 16, 2010

2 Final Draft Staff Report with Appendices for Negative Declaration pollution) that is reasonably available considering technolog ical and economic feasibility.

The RACT requirement is meant to ensure that all moderate and above nonattainment areas, have in place RACT for all source categories covered by a CTG document and for major sources that are not subject to a CTG. The San Joaquin Valley Air Basin (Valley) has been classified by the EPA as an extreme nonattainment area for the

federal 8-hour oz one standard.

The District has reviewed its permit files and the emission inventory, and also

researched the other sources such as SIC Codes, telephone yellow pages, and the

internet and has determined that there are no stationary sources or emitting facilities for the aforementioned CTG category. The Distric t also does not anticipate these sources

in the future. Because there are no s ources within the Valley subject to the requirements of this CTG, the District Govern ing Board has two options to satisfy the CAA requirements.

1. Amend Rule 4681 to incorporate the CTG requirements to satisfy RACT for the source category, even though there would be no source subject to the rule.

2. Declare that there are no sources in the Valley subject to a RACT requirement through a formal “Negative Declaration”, ma king the requirement to adopt a rule for those sources no longer applicable.

A. Rule Amendment

District Rule 4681 (Rubber Tire Manufacturi ng) was adopted by the District Governing Board on May 16, 1991 and has subsequently amended two times, once in December

1992 and once in December 1993. As s upported by page 4-337 of the District 2009 RACT SIP Analysis “there are no existing r ubber tire manufacturing facilities currently operating in the District”.

To revise District Rule 4681 to incorporate CTG requirements would involve a year long process. This process requires many Distr ict resources including the time and energy of several staff members that could be spent working on projects that would further reduce air pollution emissions in the San J oaquin Valley Air Basin (Valley). Costs associated with a rule development proj ect include staffing, postage and handling of public noticing mail outs and fees for pub lications in local newspapers, and for

distribution of materials. District resources would better benefit the citizens of the Valley by having staff focus on projects which reduce harmful emissions.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Negative Decl aration for the CTG for Control Of Volatile Organic Emissions Fr om Manufacture of Pneumatic

Rubber Tires December 16, 2010

3 Final Draft Staff Report with Appendices for Negative Declaration B. Negative Declaration

States and air districts have the option to s ubmit negative declarations for those source categories for which they are not adopting CTG-based r egulations regardless of whether such negative declarations were m ade for an earlier State Implementation Plan (SIP). This is necessary since there ma y now be sources in the nonattainment area that previously did not exist, or in areas where the boundaries of th e nonattainment area have expanded, there may be sources in the new portion of the nonattainment area

which should not be overlooked.

As discussed above, there are no sources subjec t to the requirements of this CTG. If a new rubber tire manufacturing facility wants to operate in the District in the future, it will

be evaluated for Best Avail able Control Technology (BACT) and emission offset requirements pursuant to District Rule 22 01 (New and Modified Stationary Source Review). BACT is at least as stringent as RACT and is expected to go well beyond RACT requirements, therefor e would be in compliance with the CTG requirements.

III. RECOMMENDED ACTION

District staff recommends that the Dis trict Governing Board approve a negative

declaration for the CTG for the Control of Vo latile Organic Emissions from Manufacture of Pneumatic Rubber Tires. The Negative Declar ation is in the form of a Resolution that will accompany this Staff Report.

GUIDANCE DOCUMENT TITLE DOCUMENT

TYPE DOCUMENT

NUMBER Control of Volatile Organic Emissions from

Manufacture of Pneumatic Rubber Tires CTG EPA-450/2-78-030

IV. ENVIRONMENTAL IMPACTS / CEQA

There are no facilities within t he boundaries of the District that are affected by the CTG. The negative declaration for this CTG will no t result in new or revised District regulations. Therefore, adoptio n of this negative declaration is not a project as described in Section 15378(a) of the California Environmental Quality Act (CEQA) guidelines.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Negative Decl aration for the CTG for Control Of Volatile Organic Emissions Fr om Manufacture of Pneumatic

Rubber Tires December 16, 2010

4 Final Draft Staff Report with Appendices for Negative Declaration V. COST EFFECTIVENESS ANALYSIS, SOCIOECONOMIC IMPACT ANALYSIS,

AND RULE CONSISTENCY ANALYSIS

The negative declaration for CTG source ca tegories with no emission sources within

District boundaries will not result in new or re vised District regulations. Therefore, cost effectiveness analysis, socioeconomic impact analysis, and rule consistency analysis are not required for this project.

VI. RULE DEVELOPMENT PROCESS

The draft staff report for the negative declara tion for the CTG for Control of Volatile Organic Emissions from Manufacture of Pn eumatic Rubber Tires was published for a 30-day public commenting peri od in September 2010. No comments were received during the commenting period.

The notice of the public hearing for the amendments were published in general circulation newspapers in eac h of the eight Valley counties, and made available for
review on the District website. Comments received will be evaluated and, if appropriate, incorporated into the negative declaration.

VII. REFERENCES

2009 RACT SIP Analysis

Clean Air Act Control Techniques Guidelines for the Control of Volatile Organic Emissions from

Manufacture of Pneumatic Rubber Tires (EPA-450/2-78-030)