United States Environmental Protection Agency

Air Division

Technical Support

For The

Placer County Air Pollution Control District

Rule 503 , Emiss ion Statement

Prepared by: Cynthia Allen

Reviewed by: Andrew Steckel

Ja nuary 2012- 2

-

AGENCY : Placer County Ai r Pollution Control District ( P CAPCD)

SIP Approved Rule: Not Applicable

Superseded Submittals: None

Subject of this TSD: Rule 503 , Emission Statement

Submitted

– December 7 , 2010

Amended

– August 10, 20 10

BACKGROUND Federal Clean Air Act (CAA) Section 182(a)(3)(B)(i) requires ozone nonattainment areas (regardless of classification) to require certified emission statement data from sources of volatile organic compounds (VOC) and oxides of nitrogen (NO x). Emission statements should be submitted by November 15, 1993 and annually thereafter. CAA Section 182(a)(3)(B)(ii) allows states to waive the requirement for emission statements for classes or categories of sources with less than 25 tons per year (typ) of actual plant

- wide NOx or VOC emissions if the State provides an inventory of emissions from the class or category based on the use of emission factors established by EPA or other methods acceptable to EPA. Emission Statements are intended to help the state report and analyze ambient

air emissions. The CAA also requires states to periodically compile and report a comprehensive, accurate and current inventory of all air contaminant sources.

RULE SUMMARY Rule 503 requires the owner or operator of any sta tionary source permitted by

the District with actual or potential emissions over 10 tpy to provide an annual statement of actual emissions or operational data so that the District can

calc ulate emissions . The emission s tatement must be in a format specifi ed by

the Air Pollution Control Officer (APCO) and must include the following

information : operational data necessary to compute actual emissions for the prior calendar year, information regarding diurnal or seasonal peaks in emissions, and

certification b y a res ponsible official that the statement is accurate. Failure to submit may result in the suspension of the source’s permit( s)

.

EPA E VALUATION The following criteria were used to evaluate the submitted rule:1. CAA Requirements: Section 182 (a)(3)(B ) and EPA’s draft “Guidance on the

Implementation of an Emission Statement Program,” July 1992.

2. Enforceability: The Bluebook ( Issues Relating to VOC Regulation Cutpoints,
Deficiencies, and Deviations , EPA, May 25, 1988) and the Little B luebook ( Guidance Document for Correcting Common VOC & Other Rule
Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate compliance with the CAA Section 110(a)(2)(A) requirement for enforceability.

The submitted rule complies with the r equirements found in CAA Section 182(a)(3)(B)

. The rule will have no direct effect on air pollution emissions although it may help improve compliance and enforceability of emission control requirements in other PCAPCD rules.

The rule requires that the emi ssion statements contain all of the information found

in the District’s Renewal Information Request . The CAA does not provide formatting requirements or specify timing beyond that reports must be submitted annually, and deference is given to the State to assure that all information needed to meet Federal reporting requirements is requested. To ensure consistency and accuracy of reporting, however, we recommend further details be included within

the rule as described in “Additional Recommendations for the N ext Rule Revision ”

below

. The rule requirements are clear and enforceable consistent with CAA Section 110(a)(2)(A).

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION

The following revisions are not currently the basis for rule disapproval, but are

re commended as improvements the next time the rule is revised.

 To ensure clarity and consistency in how emission estimates are generated, w e recommend that future revisions to the rule include a list of

minimum data element s require d in emission statements a s described in section 2.2.6, 2.27, and 2.28 of the guidance document “Guidance on the Implementation of an Emission Statement Program,” July 1992 or other details as required by federal reporting requirements.

EPA ACTION

EPA staff reco mmends approval of Placer County APCD Rule 503 under section 110(k) as meeting the requirements of section 110(a) and Part D of the Clean Air
Act, as amended in 1990.

REFERENCES

1. Issues Relating to VOC Regulation, Cutpoints, Deficiencies, and Deviations
(the “Blue Book” ) , U.S. EPA, OAQPS, May 25, 1988.2. Requirements for Preparation, Adoption, and Submittal of Implementation

Plans , U.S. EPA, 40 CFR Part 51.

3. State Implementation Plans for National Primary and Secondary Ambient
Air Quality Standards , Section 110 of the Clean Air Act, and Plan
Requirements for Nonattainment Areas , Title I, Part D of the Clean Air Act.

4. EPA’s draft “Guidance on the Implementation of an Emission Statement
Program,” Dated July 1992.