### 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 959 71 (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, NSAQM D 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 Implementat ion Plan. The Western Nevada County portion of the Northern Sierra AQMD is non-attainme nt for the 1997 federal 8-hour ozone standard (with a pending “Finding of Attainment” re quest because the most recent design value

indicates ozone concentrations in the attainment ra nge), but is not yet classified. Rule 228 was amended by the District’s Board of Directors on Apr il 25, 2011, following a public hearing.

The NSAQMD worked extensively (via more than 40 com munications) with Adrianne Borgia of EPA during the revision process. A draft of amende d Rule 228 was submitted to the California Air Resources Board (ARB). ARB staff recommended l owering 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 NSA QMD, and lowering the VOC content of a few coating categories would make little or no diff erence 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 appr oved 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 revisi on. The other main changes are improvements to the Definitions section; minor chan ges to improve enforceability; the addition of “etching fillers” to the acid content measurement s ection (5.5); and the inclusion of full and updated test method titles. None of the changes ha ve any effect on emissions.

All of the test methods in Rule 228 have been appro ved 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 conta ct 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)