NORTHERN SIERRA AIR QUALITY MANAGEMENT DISTRICT GRETCHEN BENNITT, APCO 

 SERVING THE COUNTIES OF NEVADA, PLUMAS AND SIERRA 

NSAQMD MAIN OFFICE (530) 274-9360 / FAX: (530) 274-7546 

200 Litton Dr., Suite 320, Grass Valley, CA 95945 (Shipping Only)

P.O. Box 2509, Grass Valley, CA 95945 (Mail Only)

email: office@myairdistrict.com or www.myairdistrict.com

TRUCKEE FIELD OFFICE (530) 550-7872 / FAX: (530) 587-2623 

13450 Donner Pass Rd., Suite B, Truckee, CA 96161 (Shipping Only)

P.O. Box 9766, Truckee, CA 96162 (Mail Only)

email: ryan@myairdistrict.com

QUINCY FIELD OFFICE (530) 283-4654 / FAX: (530) 283-0699 

270 County Hospital Rd., Suite 127, Quincy, CA 95971 (Shipping Only) 

P.O. Box 3981, Quincy, CA 95971 (Mail Only)

email: george@myairdistrict.com

NSAQMD 

P.O. Box 2509 

Grass Valley, CA 95945 

May 3, 2011 

Mr. Michael Guzzetta 

Stationary Source Division 

California Air Resources Board 

PO Box 2815 

Sacramento, CA 95812 

Subject: State Implementation Plan Submittal, NSAQMD Rule 228 

Dear Mr. Guzzetta: 

Enclosed is the information necessary for submittal of Rule 228, Surface Coating of Metal Parts 

and Products, for revision to the State Implementation Plan. The Western Nevada County 

portion of the Northern Sierra AQMD is non-attainment for the 1997 federal 8-hour ozone 

standard (with a pending “Finding of Attainment” request because the most recent design value 

indicates ozone concentrations in the attainment range), but is not yet classified. Rule 228 was 

amended by the District’s Board of Directors on April 25, 2011, following a public hearing. 

The NSAQMD worked extensively (via more than 40 communications) with Adrianne Borgia of 

EPA during the revision process. A draft of amended Rule 228 was submitted to the California 

Air Resources Board (ARB). ARB staff recommended lowering the VOC content of some 

coatings beyond the limits set forth in the CTG, in order to make the rule as stringent in those 

respects as SCAQMD’s rule. However, since the rule only applies to one small stationary 

source (2009 VOC emissions of 0.64 tons) in the NSAQMD, and lowering the VOC content of a 

few coating categories would make little or no difference in emissions from that source, the 

NSAQMD decided to retain those recommended changes for consideration the next time the 

rule is visited. 

The main reason EPA found the former Rule 228 only partially approvable was that it contained 

a reference to District Rule 229, which is not approved into the SIP. Since the reference was 

unnecessary and applied to a technology that doesn’t even exist at the single source that is 

regulated by the rule, it was removed in the revision. The other main changes are 

improvements to the Definitions section; minor changes to improve enforceability; the addition of 

“etching fillers” to the acid content measurement section (5.5); and the inclusion of full and 

updated test method titles. None of the changes have any effect on emissions. 

All of the test methods in Rule 228 have been approved by EPA for use in SIPs, so they are not 

included with this submission. 

No workshops were held for the Rule amendment. 
SERVING THE COUNTIES OF NEVADA, PLUMAS AND SIERRA 

If you have any comments or questions, please contact me at (530) 274-9360 x106. 

Sincerely, 

Samuel F. Longmire, 

Air Pollution Control Specialist III 

(sent via e-mail) 

Attachments (in separate folders attached to email): 

1. SIP Completeness Checklist 

2. Rule Evaluation Form 

3. Final Version of Rule 

4. Strikeout-Underline Version of Rule 

5. Evidence of Public Notice 

6. Comments Received on Draft Rule 

7. Staff Report 

8. Board Adoption Resolution (Including Evidence of Public Hearing)