Antelope Valley 

Air Quality Management District 

Final 

Staff Report 

Amended 

Rule 109 – Recordkeeping for Volatile Organic 

Compound Emissions 

Amended on 

April 20, 2010 

43301 DIVISION ST., SUITE 206,

LANCASTER, CALIFORNIA 93535-4649 

PHONE (661) 723-8070 

FAX (661) 723-3450 
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AVAQMD Rule 109 TC-1

Final Staff Report 05/12/10 

STAFF REPORT 

TABLE OF CONTENTS 

Rule 109 – Recordkeeping for Volatile Organic Compound Emissions 

I. PURPOSE OF STAFF REPORT ...........................................................................................1 

II. EXECUTIVE SUMMARY....................................................................................................1 

III. STAFF RECOMMENDATION ............................................................................................1 

IV. LEGAL REQUIREMENTS CHECKLIST............................................................................2 

V. DISCUSSION OF LEGAL REQUIREMENTS ....................................................................3 

A. REQUIRED ELEMENTS/FINDINGS...........................................................................3 

1. State Findings Required for Adoption of Rules & Regulations ......................3 

a. Necessity ..............................................................................................3 

b. Authority..............................................................................................3 

c. Clarity...................................................................................................3 

d. Consistency..........................................................................................3 

e. Nonduplication.....................................................................................3 

f. Reference..............................................................................................4 

g. Public Notice & Comment, Public Hearing.........................................4 

2. Federal Elements (SIP Submittals, Other Federal Submittals) ..........................4 

a. Satisfaction of Underlying Federal Requirements .................................4 

b. Public Notice and Comment .................................................................4 

c. Availability of Document......................................................................4

d. Notice to Specified Entities .................................................................4 

e. Public Hearing.......................................................................................5 

f. Legal Authority to Adopt and Implement ............................................5 

g. Applicable State Laws and Regulations Were Followed.....................5 

B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS.........................................5 

C. ECONOMIC ANALYSIS ..............................................................................................5 

1. General.............................................................................................................5 

2. Incremental Cost Effectiveness.......................................................................5 

D. ENVIRONMENTAL ANALYSIS (CEQA) ..................................................................6 

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS .................................................6 

1. Potential Environmental Impacts.....................................................................6 

2. Mitigation of Impacts.......................................................................................6 

3. Alternative Methods of Compliance................................................................6 
TC-2 AVAQMD Rule 109 

Final Staff Report 05/12/2010

F. PUBLIC REVIEW ..........................................................................................................6 

VI. TECHNICAL DISCUSSION ................................................................................................7 

A. SOURCE DESCRIPTION .............................................................................................7 

B. EMISSIONS ...................................................................................................................7 

C. CONTROL REQUIREMENTS......................................................................................7 

D. PROPOSED RULE SUMMARY...................................................................................7 

E. SIP HISTORY.................................................................................................................8 

1. SIP History.......................................................................................................8 

2. SIP Analysis.....................................................................................................9 

Apendix A – Rule 109 – Recordkeeping for Volatile Organic Compound Emissions Iterated Version

.............................................................................................................................................A-1 

Appendix B - Public Notice Documents .....................................................................................B-1 

Appendix C - Public Comments and Responses .........................................................................C-1 

Appendix D - California Environmental Quality Act Documentation ........................................D-1 

Appendix E - Bibliography..........................................................................................................E-1 
AVAQMD Rule109 1

Final Staff Report 05/12/10

STAFF REPORT 

Rule 109 – Recordkeeping for Volatile Organic Compound Emissions 

I. PURPOSE OF STAFF REPORT 

A staff report serves several discrete purposes. Its primary purpose is to provide a summary and 

background material to the members of the Governing Board. This allows the members of the 

Governing Board to be fully informed before making any required decision. It also provides the 

documentation necessary for the Governing Board to make any findings, which are required by law to 

be made prior to the approval or adoption of a document. In addition, a staff report ensures that the

correct procedures and proper documentation for approval or adoption of a document have been 

performed. Finally, the staff report provides evidence for defense against legal challenges regarding

the propriety of the approval or adoption of the document. 

II. EXECUTIVE SUMMARY 

On July 1, 1997 the Antelope Valley Air Pollution Control District (AVAPCD) was created pursuant to 

statute (former H&S Code §40106, A.B. 266-Knight Ch. 542, statutes of 1996) and assumed all air 

pollution control responsibilities from the South Coast Air Quality Management District (SCAQMD) 

for the area of Los Angeles County outside the South Coast Air Basin (SCAB). The SCAQMD rules 

in effect within the jurisdiction of the AVAPCD remained in effect until the AVAPCD Governing 

Board superceded, amended or rescinded them. On January 1, 2002 the Antelope Valley Air Quality 

Management District (AVAQMD) was created pursuant to statute (H&S Code §41300 et seq.) to 

replace the AVAPCD. Once again the rules in effect at the time of the change remained in effect until

the AVAQMD Governing Board superceded, amended or rescinded them. The SCAQMD adopted 

Rule 109 on May 5, 1989 and subsequently amended it on March 6, 1992. The AVAPCD readopted 

Rule 109 by statute on July 1, 1997, the AVAQMD readopted Rule 109 by statute January 1, 2002, and 

subsequently amended the Rule May 17, 2005. The May 17, 2005 version is the version in the 

AVAQMD rulebook. 

The AVAQMD is proposing to amend Rule 109 to include an alternative recordkeeping method of 

addressing certain industry practices. The tracking and accounting of usage of many products in very 

small quantities on a daily basis is not cost-effective for the District or industry. This is a procedural 

change in reporting periods and protocol. There is no change in the quantity of product reported, or in 

emissions of VOC over time as a result of this change in reporting method. Proposed amendments also 

update the list of rules with Rule 109 applicability to account for revisions and amendments elsewhere

in the rulebook. 

III. STAFF RECOMMENDATION 

Staff recommends that the Governing Board of the Antelope Valley Air Quality Management District 

adopt the proposed amendments to Rule 109 – Recordkeeping for Volatile Organic Compound 

Emissions and approve the appropriate California Environmental Quality Act (CEQA) documentation. 

The Governing Board of the Antelope Valley Air Quality Management District amended Rule 109 – 

Recordkeeping for Volatile Organic Compound Emissions on April 20, 2010. 
2 AVAQMD Rule 109 

Final Staff Report 05/12/10

IV. LEGAL REQUIREMENTS CHECKLIST 

The findings and analysis as indicated below are required for the procedurally correct amendment of 

Rule 109 – Recordkeeping for Volatile Organic Compound Emissions. Each item is discussed, if 

applicable, in Section V below. Copies of documents are included in the appropriate Appendix. 

FINDINGS REQUIRED FOR 

RULES & REGULATIONS 

 X Necessity 

 X Authority 

 X Clarity 

 X Consistency 

 X Nonduplication 

 X Reference 

 X Public Notice & Comment 

 X Public Hearing 

REQUIREMENTS FOR STATE 

IMPLEMENTATION PLAN 

SUBMISSION (SIP): 

X Public Notice & Comment 

X Availability of Document 

X Notice to Specified Entities (State, 

Air Districts, USEPA, Other States) 

X Public Hearing 

X Legal Authority to adopt and 

implement the document. 

X Applicable State laws and 

regulations were followed. 

ELEMENTS OF A FEDERAL 

SUBMISSION 

X Elements as set forth in applicable 

Federal law or regulations. 

CALIFORNIA ENVIRONMENTAL 

QUALITY ACT REQUIREMENTS 

(CEQA):

N/A Ministerial Action 

 X Exemption 

N/A Negative Declaration 

N/A Environmental Impact Report 

 X Appropriate findings, if necessary. 

N/A Public Notice & Comment 

SUPPLEMENTAL ENVIRONMENTAL 

ANALYSIS (RULES & REGULATIONS 

ONLY): 

 X Environmental impacts of 

compliance. 

 N/A Mitigation of impacts. 

 N/A Alternative methods of compliance. 

OTHER: 

 N/A Written analysis of existing air 

pollution control requirements 

 N/A Economic Analysis 

 X Public Review 
AVAQMD Rule109 3

Final Staff Report 05/12/10

V. DISCUSSION OF LEGAL REQUIREMENTS 

A. REQUIRED ELEMENTS/FINDINGS 

This section discusses the State of California statutory requirements that apply to the 

amendment of Rule 109. These are actions, that need to be performed, and/or information, that 

must be provided in order to amend the Rule in a procedurally correct manner. 

1. State Findings Required for Adoption of Rules & Regulations: 

Before adopting, amending, or repealing a rule or regulation, the AVAQMD Governing 

Board is required to make findings of necessity, authority, clarity, consistency, nonduplication, and reference based upon relevant information presented at the hearing. The 

information below is provided to assist the Board in making these findings. 

a. Necessity: 

The AVAQMD is proposing to amend Rule 109 to include an alternative 

recordkeeping method of addressing certain industry practices. The tracking and 

accounting of usage of many products in very small quantities on a daily basis is 

not cost-effective for the District or industry. This is a procedural change in 

reporting periods and protocol. There is no change in the quantity of product 

reported, or in emissions of VOC over time as a result of this change in reporting 

method. 

 b. Authority: 

AVAQMD has the authority pursuant to California Health and Safety Code 

(H&S Code) §40702 to adopt, amend or repeal rules and regulations. 

c. Clarity: 

The amendments are clear in that they are written so that the persons subject to 

the Rule can easily understand the meaning. 

d. Consistency: 

The amendment of Rule 109 is in harmony with, and not in conflict with or 

contradictory to, any State law or regulation, federal law or regulation, or court 

decisions. 

e. Nonduplication: 

The amendment of Rule 109 does not impose the same requirements as an 

existing State or federal law or regulation because this is a procedural change in 

reporting periods and protocol. 
4 AVAQMD Rule 109 

Final Staff Report 05/12/10

f. Reference: 

AVAQMD has the authority pursuant to H&S Code §40702 to adopt, amend or 

repeal rules and regulations. 

g. Public Notice & Comment, Public Hearing: 

The public hearing to consider the amendment of Rule 109 was originally 

noticed for the 3/16/2010 Governing Board meeting. The 3/16/2010 meeting 

was cancelled and all items deferred to the next regularly scheduled meeting of 

04/20/2010. See Appendix “B” for a copy of the public notice. See Appendix C 

for copies of comments, if any, and AVAQMD responses. 

2. Federal Elements (SIP Submittals, Other Federal Submittals). 

Submittals to USEPA are required to include various elements depending upon the type 

of document submitted and the underlying Federal law which requires the submittal. 

The information below indicates which elements are required for the amendment of 

Rule 109 and how they were satisfied. 

a. Satisfaction of Underlying Federal Requirements: 

The amendments to Rule 109 are subject to all the requirements for a State 

Implementation Plan (SIP) submittal because Rule 109 will be included in the 

AVAQMD SIP. The criteria for determining completeness of SIP submissions 

are set forth in 40 CFR Part 51, Appendix V, 2.0. 

b. Public Notice and Comment: 

The public hearing to consider the amendment of Rule 109 was originally 

noticed for the 3/16/2010 Governing Board meeting. The 3/16/2010 meeting 

was cancelled and all items deferred to the next regularly scheduled meeting of 

04/20/2010. See Appendix “B” for a copy of the public notice. 

c. Availability of Document: 

Copies of the proposed amendment Rule 109 and the accompanying draft staff 

report were made available to the public on February 1, 2010 

d. Notice to Specified Entities 

Copies of the proposed amendments to Rule 109 and the accompanying draft 

staff report were mailed to all affected agencies, including but not limited to 

CARB and USEPA on February 1, 2010. 
AVAQMD Rule109 5

Final Staff Report 05/12/10

e. Public Hearing: 

The public hearing to consider the amendment of Rule 109 was originally 

noticed for the 3/16/2010 Governing Board meeting. The 3/16/2010 meeting 

was cancelled and all items deferred to the next regularly scheduled meeting of 

04/20/2010. 

f. Legal Authority to Adopt and Implement: 

The AVAQMD has the authority pursuant to H&S Code §40702 to adopt, 

amend, or repeal rules and regulations and to do such acts as may be necessary 

or proper to execute the duties imposed upon the AVAQMD. 

g. Applicable State Laws and Regulations Were Followed: 

Public notice and hearing procedures pursuant to H&S Code §§40725-40728 

have been followed. See Section (V)(A)(1) above for compliance with state 

findings required pursuant to H&S Code §40727. See Section (V)(B) below for 

compliance with the required analysis of existing requirements pursuant to H&S 

Code §40727.2. See Section (V)(C) for compliance with economic analysis 

requirements pursuant to H&S Code §40920.6. See Section (V)(D) below for 

compliance with provisions of the California Environmental Quality Act 

(CEQA). 

B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS 

H&S Code §40727.2 requires air districts to prepare a written analysis of all existing federal air 

pollution control requirements that apply to the same equipment or source type as the rule for 

modification by the district. There is no change in the quantity of product reported, or in 

emissions of VOC over time as a result of this change in reporting method. Therefore the 

preparation of a written analysis of existing pollution control requirements that apply to the 

same equipment or source type is not required. 

C. ECONOMIC ANALYSIS 

1. General 

No economic impacts are anticipated from the adoption of the amendments to Rule 109. 

 

2. Incremental Cost Effectiveness 

Pursuant to H&S Code §40920.6, incremental cost effectiveness calculations are 

required for rules and regulations which are adopted or amended to meet the California 

Clean Air Act requirements for Best Available Retrofit Control Technology (BARCT) 

or “all feasible measures” to control volatile compounds, oxides of nitrogen or oxides of 
6 AVAQMD Rule 109 

Final Staff Report 05/12/10

sulfur. The amendment of Rule 109 is not subject to incremental cost effectiveness 

calculations because this rule does not impose BARCT or “all feasible measures”. 

D. ENVIRONMENTAL ANALYSIS (CEQA) 

Through the process described below, it was determined that a Notice of Exemption would be 

the appropriate CEQA process for the amendment of Rule 109. The amendment of Rule 109 

meets the CEQA definition of "project." They are not "ministerial" actions. 

1. The amendment of Rule 109 meets the CEQA definition of "project." They are 

not "ministerial" actions. 

2. The amendment of Rule 109 is exempt from CEQA review because this is a 

procedural change in reporting periods and protocol. There is no change in the quantity 

of product reported, or in emissions of VOC over time as a result of this change in 

reporting method and there is not potential that the amendments might cause the release 

of additional air contaminants or create any adverse environmental impacts, a Class 8 

categorical exemption (14 Cal. Code Reg. §15308) applies. 

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS 

1. Potential Environmental Impacts 

There are no potential adverse environmental impacts of compliance with the 

amendment of Rule 109. This is a procedural change in reporting periods and protocol. 

There is no change in the quantity of product reported, or in emissions of VOC over 

time as a result of this change in reporting method and there is not potential that the 

amendments might cause the release of additional air contaminants or create any 

adverse environmental impacts. 

2. Mitigation of Impacts 

N/A 

3. Alternative Methods of Compliance 

N/A 

F. PUBLIC REVIEW 

See Staff Report Section (V)(A)(1)(g) and (2)(b), as well as Appendix B. 
AVAQMD Rule109 7

Final Staff Report 05/12/10

VI. TECHNICAL DISCUSSION 

A. SOURCE DESCRIPTION 

The provisions of this rule shall apply to an owner or operator of a stationary source within the 

District conducting operations, which include the use of adhesives, coatings, solvents, and/or 

graphic arts materials, when records are required to determine a District rule's applicability or 

source's exemption from a rule, rule compliance, or specifically as a Permit to Operate or 

Permit to Construct condition. 

B. EMISSIONS 

There is no change in the quantity of product reported or in emissions of VOC over time as a 

result of this change in reporting method and there is not potential that the amendments might 

cause the release of additional air contaminants or create any adverse environmental impacts. 

C. CONTROL REQUIREMENTS 

The amendment of Rule 109 does not change any control requirements. The amendment will 

include an alternative recordkeeping method of addressing certain industry practices. This is a 

procedural change in reporting periods and protocol. 

D. PROPOSED RULE SUMMARY 

This section gives a brief overview of the proposed amendments to Rule 109. 

The provisions of this rule shall apply to an owner or operator of a stationary source within the 

District conducting operations, which include the use of adhesives, coatings, solvents, and/or 

graphic arts materials, when records are required to determine a District rule's applicability or 

source's exemption from a rule, rule compliance, or specifically as a Permit to Operate or 

Permit to Construct condition. 

The Rule has been reformatted to standard District format, and rule citations have been updated 

as necessary. 

Section (A)(2)(b) has been updated to reflect current district rules requiring recordkeeping as 

outlined by District Rule 109. 

Definitions (B)(2) for Facility and (B)(6) for South Coast Air Quality Management District 

have been added. 

Section(C)(1)(d) was added to allow for alternative recordkeeping methods of addressing 

certain industry practices. 

Section(C)(1)(f) was changed for consistency with (C)(1)(d). 
8 AVAQMD Rule 109 

Final Staff Report 05/12/10

Section (C)(1)(h) was modified to clarify that oven records are only necessary when otherwise 

required by the rule. 

Section (D)(4) was added to allow for use of approved alternative test methods. 

Section (D)(5) was added pursuant to USEPA comment letter. 

Section (E)(1) was added to make it applicable for all substrates. 

E. SIP HISTORY 

1. SIP History. 

Prior to 1975, the original air district for the Antelope Valley region was the Los 

Angeles County APCD that had jurisdiction covering the entire county of Los Angeles. 

In 1975, the Southern California Air Pollution Control District (So. Cal. APCD) was 

created. The So. Cal. APCD was created by a Joint Powers Agreement (JPA) between 

Los Angeles, Orange, Riverside and San Bernardino Counties to replace the previous 

countywide air pollution control districts for those counties. On 02/01/77, pursuant to 

statute (Cal. Stats. 1976, Ch 324 p. 815) the South Coast Air Quality Management 

District (SCAQMD) was created with an initial jurisdiction that only included areas of 

Los Angeles, Orange, Riverside and San Bernardino Counties contained within the 

South Coast Air Basin (SCAB). Outlying areas remained under the So. Cal. APCD 

(The legislation was thereafter amended to allow non SCAB areas to “opt in”. Los 

Angeles County exercised this option, and thus the Antelope Valley became a part of 

SCAQMD). Also on 02/01/77 the California Air Resources Board (CARB) issued 

Executive Order G-73 (1977) which adopted a “rule book” for those non-SCAB areas of 

Los Angeles, Riverside and San Bernardino Counties. CARB submitted the G-73 

rulebook on behalf of the “county” districts. 

By its terms Executive Order G-73 (1977) was only effective until the non-SCAB areas 

took other action. On 02/22/77 the JPA forming the So. Cal. APCD was formally 

dissolved. By the terms of the JPA upon dissolution each county would regain its 

county air pollution control district with a jurisdiction of the non-SCAB areas of the 

county and the applicable rules being the So. Cal. APCD’s rules in effect upon the date 

of dissolution. On 07/01/97 the Antelope Valley Air Pollution Control District 

(AVAPCD) replaced the SCAQMD as the agency with jurisdiction over the Los 

Angeles County portion of the Mojave Desert Air Basin (MDAB). On 01/01/02 the 

AVAPCD was replaced by the AVAQMD. Pursuant to both statutory changes, the rule 

and regulations of the predecessor district were retained until the Governing Board 

adopted, amended or rescinded them. At the first meeting of both the AVAPCD and the 

AVAQMD, the respective Governing Boards reaffirmed all the rules and regulations in 

effect at the time the agency changed. 

The jurisdiction of the AVAPCD and the AVAQMD were specified in the statutes as 

the portion of the Los Angeles County contained within the MDAB. The MDAB was 

formerly known as the Southeast Desert Air Basin (SEDAB). In 1997 the SEDAB was 
AVAQMD Rule109 9

Final Staff Report 05/12/10

split into the MDAB and the Salton Sea Air Basin. Descriptions of these air basins can 

be found in 17 Cal. Code Regs. §§60109 and 60144. Since USEPA adopts SIP 

revisions in California as effective within jurisdictional boundaries of local air districts, 

when the local air district boundaries change the SIP as approved by USEPA for that 

area up to the date of the change remains as the SIP in that particular area. Thus, upon 

creation of the AVAPCD on 07/01/97 the AVAPCD acquired the SIP applicable to the 

Antelope Valley portion of the SCAQMD that was effective as of 06/30/97. Likewise 

the AVAQMD acquired the SIP that was effective in the jurisdiction of the AVAPCD as 

of 12/31/01. Therefore, the SIP history for this region is based upon the rules adopted, 

effective, and approved for the Antelope Valley by SCAQMD. 

Rule 109 was originally adopted on 05/05/89 by the SCAQMD. This rule submission 

was given limited approval and limited disapproval at 58 FR 45444, 08/30/1993. Rule 

109 was subsequently amended by SCAQMD on 03/06/92 and approved into the SIP at 

60 FR 18751, 04/13/95. Rule 109 was readopted by statute by the AVAPCD on 

07/01/97, and again readopted by statute by the AVAQMD on 01/01/02. The 

AVAQMD subsequently amended Rule 109 on 05/17/05 to provide administrative 

cleanup necessary to remove inaccurate references, remove or amend references which 

were no longer valid, and to create harmony and avoid conflict with other AVAQMD 

rules. This amendment was submitted for inclusion in the SIP on 03/10/06 and has not 

been acted upon at this time. The 03/06/92 SCAQMD version of Rule 109 is in the SIP 

for the AVAQMD. 

2. SIP Analysis. 

The District is requesting CARB to submit Rule 109 to replace the SIP version in effect 

for the AVAQMD. 

Since there is a previously existing SIP rule for this category in the AVAQMD, the 

District is requesting that it be superseded. In order to replace existing SIP rules the 

District is required to show that the amendments are not less stringent than the 

provisions currently in the SIP. 

The amendments to AVAQMD Rule 109 are primarily a procedural change in reporting 

periods and protocol. There is no change in the quantity of product reported, or in 

emissions of VOC over time as a result of this change in reporting method. Rule 109 

also provides cleanup necessary to update the list of rules with Rule 109 applicability. 

These administrative changes do not result in the amendment of Rule 109 being less 

stringent than the current version of the rule in the SIP. 

AVAQMD Rule 109 A-1

Final Staff Report 05/12/10

APPENDIX "A"

Rule 109 – Recordkeeping for Volatile Organic Compound Emissions 

Iterated Version 

The iterated version is provided so that the changes to an existing rule may be easily found. The manner 

of differentiating text is as follows: 

1. Shaded text identifies new or revised language. 

2. Lined out text identifies language which is being deleted. 

3. Normal text identifies the current language of the current rule which will remain unchanged by the 

adoption of the proposed amendments. 

4. Italicized text identifies explanatory material that is not part of the proposed language. 
A-2 AVAQMD Rule 109 

Final Staff Report 05/12/10

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(Adopted: 5/5/89; Amended: 3/6/92; Readopted by Statute:

07/01/97; Readopted by Statute: 01/01/02; Amended: 5/17/05; 

Amended: mm/dd/yy) 

AVAQMD RULE 109 109 -1 

Recordkeeping for VOC Emissions d2, 02/18/10 

RULE 109 

Recordkeeping For for Volatile Organic 

Compound Emissions 

(A) General Applicability [reformatted to reflect current district rule format]

(1) Purpose 

(a) The purpose of this rule is to ensure that adequate records of volatile organic 

compound use are made and maintained.

(2) Applicability

(a1) The provisions of this rule shall apply to an owner or operator of a stationary 

source within the District conducting operations, which include the use of 

adhesives, coatings, solvents, and/or graphic arts materials, when records are 

required to determine a District rule's applicability or source's exemption from a 

rule, rule compliance, or specifically as a Permit to Operate or Permit to 

Construct condition. 

(b2) District rules requiring recordkeeping as outlined by District Rule 109 include, 

but are not limited to, the following: 

 442 - Usage of Solvents

1102 - Petroleum Solvent Dry Cleaners

1104 - Wood Flat Stock Coating Operations, 

1107 - Coating of Metal Parts and Products, 

1122 - Solvent Cleaners (Degreasers), 

1124 - Aerospace Assembly and Component Coating Operations, 

1128 - Paper, Fabric, and Film Coating Operations, 

1130 - Graphic Arts, 

1130.1 - Screen Printing Operations [added pursuant to Rule 1130.1(c)(5)] 

1136 - Wood Products Coatings, 

1145 - Plastic, Rubber, and Glass Coatings and Adhesives, 

1151 - Motor Vehicle and Mobile Equipment Non-Assembly Line Coating 

Operations,

1162 - Polyester Resin Operations
109-2 AVAQMD RULE 109 

Recordkeeping for VOC Emissions d2, 02/18/10 

1164 - Semiconductor Manufacturing, 

1168 - Control of Volatile Organic Compound Emissions from Adhesive 

Applications.

1171 – Solvent Cleaning Operations

(B) Definitions 

(1) Exempt Compounds - Any compound listed in 40 CFR 51.100(s)(1). 

(2) Facility - Any permit unit, group of permit units, non-permitted equipment or any 

combination thereof which emits or may emit an Air Pollutant; and belongs to a single 

major industrial group in the Standard Industrial Classification manual; and is located 

on a single parcel of land or on contiguous property within the District; and which is 

owned or operated by the same person or by persons under common control.[derived 

from AVAQMD Rule 1124 (B)(23)]

(23) Graphic Arts Materials - Any inks, coatings, adhesives, fountain solutions, thinners 

retarders, or cleaning solutions used in printing or related coating or laminating 

processes.

(34) Low Solids Adhesive, Adhesive Primer, or Stain - An adheasive, adhesive primer or 

stain which has less than one pound of solids per gallon of material. 

(45) Permit Unit - Any article, machine, equipment, or other contrivance, or combination 

thereof, which may cause the issuance or control the issuance of air contaminants, and 

which: 

(a) requires Requires a written permit pursuant to the provisions of District Rules 

201 and/or 203; or 

(b) is Is in operation pursuant to the provisions of District Rule 219.

(6) South Coast Air Quality Management District (SCAQMD) – The air quality district 

created pursuant to Division 26, Part 3, Chapter 5.5 of the California Health & Safety 

Code (commencing with §40400). [derived from AVAQMD Rule 1124 (B)(59)]

(57) Stationary Source - Any permit unit or grouping of permit units or other air 

contaminant-emitting activities which are located on one or more contiguous properties 

within the District, in actual physical contact or separated solely by a public roadway or 

other public right-of-way, and are owned or operated by the same person (or by persons 

under common control). Such above-described groupings, if non-contiguous, but 

connected only by land carrying a pipeline, shall not be considered one stationary 

source. 
AVAQMD RULE 109 109-3 

Recordkeeping for VOC Emissions d2, 02/18/10 

(68) Volatile Organic Compound (VOC) - Any volatile compound of carbon, excluding 

carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, 

ammonium carbonate, and exempt compounds as defined in subsection (B)(1) above. 

(C) Daily Recordkeeping Requirements 

(1) An owner or operator of a stationary source using adhesives, coatings, solvents, and/or 

graphic arts materials and subject to this rule shall maintain daily records of operations 

for the most recent two (2) year period. The records shall be retained on the premises of 

the affected operation for a period of not less than two (2) years. Said records shall be 

made available to the District upon request. The records shall include, but not be 

limited to, the following: 

(a) each Each applicable District rule number pertinent to the operation for which 

records are being maintained; 

(b) a A list of the permit units involved in the operation(s) using adhesives, 

coatings, solvents, and/or graphic arts materials; 

(c) the The method of application and substrate type; 

(d) the The amount and type of adhesive, coating (including catalyst and reducer), 

solvent, and/or graphic arts material used in each permit unit or dispensing 

station (when permitted equipment is not involved), including exempt 

compounds (use of amountscontainers of one pint per week or less may be 

recorded in an alternative manner including but not limited to assuming full 

consumption on day of first use and/or calculating an average daily consumption 

by determining the number of operating days a single pint container of material 

was in active use at a facility);[added to allow for additional period and 

protocol]

(e) the The VOC content in each adhesive, coating (including catalyst and reducer), 

solvent, and/or graphic arts material; 

(f) the The amount of diluent, surface preparation, clean-up, or wash-up solvent 

(including exempt compounds) used and the VOC content of each (use of 

amountscontainers of one pint per week or less may be recorded in an alternative 

manner); [changed for consistency with (C)(1)(d) above]

(g) where Where applicable, the vapor pressure of solvents used as surface cleaners;

and 

(h) Where applicable, oven temperature (for coating operations). [To clarify that 

these records are only necessary when otherwise required by rule.]
109-4 AVAQMD RULE 109 

Recordkeeping for VOC Emissions d2, 02/18/10 

(DE) Test Methods

(21) VOC content shall either be calculated using a percent solids basis (less water and 

exempt solvents) for adhesives, coatings, and inks; or testing shall be done using 

USEPA Reference Method 24 (Determination of Volatile Matter Content, Water 

Content, Density Volume Solids, and Weight Solids of Surface Coatings, Code of 

Federal Regulations Title 40, Part 60, Appendix A, 7/1/85 edition). Analysis done 

according to USEPA Method 24 shall utilize Procedure B of ASTM Method D-2369, 

referenced within USEPA Method 24. The exempt solvent content shall be determined 

using SCAQMD Test Methods 302 and 303 (SCAQMD "Laboratory Methods of 

Analysis for Enforcement Samples" manual). Alternatively, the VOC content may be 

determined using SCAQMD Test Methods 302, 303, and 304. The test method shall be 

documented. The VOC content may be supplied by a Material Safety Data Sheet 

(MSDS) or data sheet provided the test methods described above are used and specified 

on the MSDS or data sheet. 

(32) VOC content and density of rotogravure publication inks shall be determined by 

USEPA Reference Method 24A (Determination of Volatile Matter Content and Density 

of Printing Inks and Related Coatings, Code of Federal Regulations Title 40, Part 60, 

Appendix A, 7/1/85 edition). The exempt solvent content shall be determined using 

SCAQMD Test Methods 302 and 303 (SCAQMD "Laboratory Methods of Analysis for 

Enforcement Samples" manual). Alternatively, the VOC content may be determined 

using SCAQMD Test Methods 302, 303, and 304. 

(43) VOC content for low solid adhesive, adhesive primer, or stain shall be calculated by the 

method used to calculate the "Grams of VOC per Liter of Material" as specified in 

District Rules 1136 and 1168.

(4) Any applicable alternative test method may be used so long as such method has been 

approved by USEPA, CARB and the APCO.[derived from AVAQMD Rule 

1124(E)(3)(f)]

(5) When more than one test method or set of methods are specified for any testing, 

noncompliance with any requirement of this rule established by any one of the specified 

test methods or set of test methods shall constitute a violation of this rule. [derived from 

SCAQMD Rule 109 (g)(8). Pursuant to EPA comment.]

The following classes of compounds: cyclic, branched, or linear, completely fluorinated 

alkanes; cyclic, branched, or linear, completely fluorinated ethers with no unsaturations; cyclic, 

branched, or linear, completely fluorinated tertiary amines with no unsaturations; and sulfurcontaining perfluorocarbons with no unsaturations and with sulfur bonds only to carbon and 

fluorine, will be analyzed as exempt compounds, only at such time as manufacturers specify 

which individual compounds are used in the coating formulations and identify the test methods, 

which, prior to such analysis, have been approved by the USEPA and the District, that can be 

used to quantify the amounts of each exempt compound. 
AVAQMD RULE 109 109-5 

Recordkeeping for VOC Emissions d2, 02/18/10 

(E) Exemptions

(1) The provisions of this rule shall not apply to the application of materials that contain 

less than 20 g/l of VOC.[derived from AVAQMD Rule 1124(G)(13). Added to make it 

applicable to all substrates.]

[SIP: Submitted as amended mm/dd/yy on mm/dd/yy; Approved: 4/13/95, 60 FR 18751, 40 CFR 

52.220(c)(189)(i)(A)(6); Limited Approval/Disapproval 8/30/95, 58 FR 45444, 40 CFR 

52.220(c)(182)(i)(A)(2)] 
109-6 AVAQMD RULE 109 

Recordkeeping for VOC Emissions d2, 02/18/10 

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AVAQMD Rule 109 B-1

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APPENDIX "B" 

PUBLIC NOTICE DOCUMENTS

1. Proof of Publication for Notice of Public Hearing – Antelope Valley Press 
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AVAQMD Rule 109 B3

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B-4 AVAQMD Rule 109 

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AVAQMD Rule109 C-1

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APPENDIX "C" 

PUBLIC COMMENTS AND RESPONSES

1. Lockheed e-mail 02/09/10. 

2. USEPA comment letter 02/18/10. 

3. ARB comment letter 02/25/2010. 
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AVAQMD Rule109 C-3

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Comment Letter 1 
C-4 AVAQMD Rule 109 

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District response to Lockheed e-mail comment. 

1. No comment required. 
AVAQMD Rule109 C-5

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1

Comment Letter 2 
C-6 AVAQMD Rule 109 

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District response to USEPA comment letter. 

1. Added new rule section (D)(5) pursant to USEPA comment. 
AVAQMD Rule109 C-7

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Comment Letter 3 
C-8 AVAQMD Rule 109 

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District response to ARB comment letter. 

1. No response required. 
AVAQMD Rule 109 D-1

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APPENDIX "D" 

CALIFORNIA ENVIRONMENTAL QUALITY ACT 

DOCUMENTATION

(to be included as available) 

1. Notice of Exemption, Los Angeles County. 
D-2 AVAQMD Rule 109 

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D-4 AVAQMD Rule 109 

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AVAQMD Rule 109 E-1

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APPENDIX "E" 

BIBLIOGRAPHY

The following documents were consulted in the preparation of this staff report and the amendments to 

Rule 109. 

1. 57 FR 3976-01, 02/03/92 

2. 58 FR 45444, 08/30/93 

3. 60 FR 18750, 04/13/95 

4. AVAQMD Rule 1124 - Aerospace Assembly And Component Manufacturing Operations 

(03/20/07) 
E-2 AVAQMD Rule 109 

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