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, Rule 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 Reasonably 

Available Control Technology (RACT) for each category of volatile organic compound

(VOC) sources covered by a Control Techniques Guideline (CTG) document and for 

any major stationary source not covered by a CTG document. Alternatively, areas may 

adopt a negative declaration document 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 Emissions from Manufacture of Pneumatic Rubber 

Tires (EPA-450/2-78-030) but currently does not incorporate every CTG requirement. 

However, there are no stationary sources or emitting facilities 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 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 

1 Final Draft Staff Report for 

 Proposeg Negative Declaration
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Draft Staff Report: Negative Declaration for the CTG for Control 

Of Volatile Organic Emissions From Manufacture of Pneumatic 

Rubber Tires December 16, 2010 

 2 Final Draft Staff Report with Appendices for 

 Negative Declaration 

pollution) that is reasonably available considering technological 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 ozone 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 District also does not anticipate these sources 

in the future. Because there are no sources within the Valley subject to the 

requirements of this CTG, the District Governing 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”, making the requirement to adopt a rule 

for those sources no longer applicable. 

A. Rule Amendment 

District Rule 4681 (Rubber Tire Manufacturing) 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 supported by page 4-337 of the District 2009 

RACT SIP Analysis “there are no existing rubber 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 District 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 Joaquin Valley Air Basin (Valley). Costs 

associated with a rule development project include staffing, postage and handling of 

public noticing mail outs and fees for publications 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 Declaration for the CTG for Control 

Of Volatile Organic Emissions From 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 submit negative declarations for those source 

categories for which they are not adopting CTG-based regulations regardless of 

whether such negative declarations were made for an earlier State Implementation Plan 

(SIP). This is necessary since there may now be sources in the nonattainment area 

that previously did not exist, or in areas where the boundaries of the 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 subject 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 Available Control Technology (BACT) and emission offset 

requirements pursuant to District Rule 2201 (New and Modified Stationary Source 

Review). BACT is at least as stringent as RACT and is expected to go well beyond 

RACT requirements, therefore would be in compliance with the CTG requirements. 

III. RECOMMENDED ACTION 

District staff recommends that the District Governing Board approve a negative 

declaration for the CTG for the Control of Volatile Organic Emissions from Manufacture 

of Pneumatic Rubber Tires. The Negative Declaration 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 the boundaries of the District that are affected by the CTG. 

The negative declaration for this CTG will not result in new or revised District 

regulations. Therefore, adoption 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 Declaration for the CTG for Control 

Of Volatile Organic Emissions From 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 categories with no emission sources within 

District boundaries will not result in new or revised 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 declaration for the CTG for Control of Volatile 

Organic Emissions from Manufacture of Pneumatic Rubber Tires was published for a 

30-day public commenting period 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 each 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)