SACRAMENTO METROPOLITAN 

AIR QUALITY MANAGEMENT DISTRICT 

STAFF REPORT 

Negative Declaration for 

Control Techniques Guidelines 

Coating Operations at Aerospace Manufacturing and Rework Operations 

September 19, 2011 

Prepared by: Jeffery Yang 

Assistant Air Quality Engineer

Reviewed by: Kevin J. Williams, Ph.D. 

 Program Coordinator 

 Aleta Kennard 

 Program Supervisor 

Approved by: Brigette Tollstrup 

 Division Manager 
Staff Report 

Aerospace Coating CTG Negative Declaration 

September 19, 2011, Page 2 

BACKGROUND 

The District is designated as a severe nonattainment area for the federal 8-hour ozone 

standard. The Federal Clean Air Act (CAA) specifies that State Implementation Plans (SIPs) for 

nonattainment areas must include “reasonably available control measures” (RACM), including 

“reasonably available control technology” (RACT), for sources of emissions1

. The CAA also 

provides that for nonattainment areas classified as “moderate” or worse, states must revise their 

SIPs to include RACT for sources of VOC emissions for each category of VOC sources covered 

by all Control Techniques Guidelines (CTG) documents issued after November 15, 1990, and 

prior to the area’s date of attainment2

. EPA defines RACT as “the lowest emission limitation 

that a particular source is capable of meeting by the application of control technology that is 

reasonably available considering technological and economic feasibility3

.” EPA periodically 

publishes information regarding available controls4

. In developing CTG documents, EPA 

evaluates, among other things, the sources of VOC emissions and the available control 

approaches for addressing these emissions, including the costs of such approaches. CTG 

documents establish the presumptive minimum recommendations for RACT. Areas may 

deviate from CTG requirements, if justified. 

As an alternative to adopting a RACT rule, a state or local agency may adopt a negative 

declaration documenting that it has no stationary sources or emitting facilities to which the CTG 

is applicable. The negative declaration must go through the same public review requirements 

as any other SIP submittal5,6. The negative declarations become part of California’s State 

Implementation Plan at Title 40 of the Code of Federal Regulations (CFR) Part 52, Section 

52.222. The Board has previously adopted negative declarations for 22 source categories. 

SUMMARY 

There are no sources within the District to which the 1997 CTG for Coating Operations at 

Aerospace Manufacturing and Rework Operations is applicable. The purpose of this staff report 

is to provide sufficient analysis to support the adoption of a negative declaration for this CTG. 

AEROSPACE COATING CTG DESCRIPTION 

Title: Control of Volatile Organic Compound Emissions from Coating Operations at 

Aerospace Manufacturing and Rework Operations. 

Reference: U.S. EPA Publication No. EPA-453/R-97-004, December 1997. 

The CTG applies to the manufacture or rework of commercial, civil, or military aerospace 

vehicles or components. A model rule is included in the CTG for states and local agencies to 

adopt. For severe nonattainment areas, the model rule applies to facilities with potentials to 

 

1

 Clean Air Act §172(c)(1). 

2

 Clean Air Act §182(b)(2)(A). 

3

 Federal Register Notice 44 FR 53761, September 17, 1979. 

4 Clean Air Act §108(b) and (c).

5

 Clean Air Act §110. 

6

 Title 40 Code of Federal Regulations §51.102. 
Staff Report 

Aerospace Coating CTG Negative Declaration 

September 19, 2011, Page 3 

emit 25 tons per year (tpy) or more of VOC. The CTG recommends the following VOC 

reduction measures: VOC content limits for coating operations; work practices for storage and 

handling of coatings; and work practices for the handling and use of cleaning materials. 

STAFF ANALYSIS 

Facilities that emit 25 tons per more of VOC are considered federal major sources in the District 

and require Title V permits. Staff has verified that none of the District’s Title V facilities, with the 

exception of Aerojet as discussed below, performs aerospace manufacturing and/or rework 

operations. 

There are five permitted sources in Sacramento County that perform aerospace manufacturing 

and/or rework operations that are within the scope of the CTG: These five facilities, and their 

potentials to emit for VOC, are Aerojet (17.4 tpy), AAR Composites (2.4 tpy), Cessna Aircraft 

(2.3 tpy), Composite Engineering (14.8 tpy), and Military Aircraft (0.42 tpy). AAR Composites 

manufactures polyester resin aerospace parts, and therefore falls within the scope of the CTG, 

but does not perform coating operations. 

The total potential to emit at Aerojet exceeds 25 tons per year. However, aerospace 

manufacture is just one of the business lines that operate at the Aerojet facility. For aerospace 

manufacturing and rework, Aerojet’s potential to emit is 17.4 tpy of VOC, below the CTG 

applicability threshold. 

Staff searched yellow pages and online business listings, and placed calls to business that 

might perform aerospace manufacturing or rework to identify additional, unpermitted facilities to 

which the CTG may apply. No additional facilities were found. 

ENVIRONMENTAL COMPLIANCE

Staff finds that the proposed rule is not subject to the California Environmental Quality Act 

because it is an activity that will not result in a direct or reasonably foreseeable indirect physical 

change in the environment. (Public Resources Code 21084(a) and Preliminary Review, Section 

15060(c)(2) State CEQA Guidelines). 

 
Staff Report 

Aerospace Coating CTG Negative Declaration 

September 19, 2011, Page 4 

CONCLUSION 

Staff’s analysis shows that there are no sources within the District to which the aerospace 

coating CTG applies. No aerospace manufacturing or rework operations large enough to 

exceed the CTG emissions threshold are anticipated in the future. A negative declaration is 

proposed for this source category. 

Pursuant to section 182(b) of the Clean Air Act, the District should adopt a negative declaration 

for the following CTG: 

Control of Volatile Organic Compound Emissions from Coating Operations at Aerospace 

Manufacturing and Rework Operations. U.S. EPA Publication No. EPA-453/R-97-004, 

December 1997.