# Antelope Valley Air Quality Management District

Final 

# Staff Report

Amended 

# Rule 109 – Recordkeeping for Volatile Organic

Compound Emissions

Amended on April 20, 2010

43301 D IVISION 

### S T 

### ., S UITE 

### 206, L ANCASTER 

### , C ALIFORNIA 

### 93535-4649 P HONE 

### (661) 723-8070 FAX (661) 723-3450This page intentionally left blank.AVAQMD Rule 109 TC- 1

Final Staff Report 05/12/10 

### STAFF REPORT TABLE OF CONTENTS Rule 109 – Recordkeeping for Volatile Organic Compo und 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 Rule s & 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 Fede ral Submittals) ..........................4 a. Satisfaction of Underlying Federal Requireme nts .................................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 F ollowed.....................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...........

................................................... ..6TC- 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 O rganic 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 D ocumentation ....................................... .D-1

Appendix E - Bibliography..........................

................................................... .............................E-1AVAQMD Rule109 1

Final Staff Report 05/12/10 

### STAFF REPORT Rule 109 – Recordkeeping for Volatile Organic Compo und Emissions

I. PURPOSE OF STAFF REPORT
A staff report serves several discrete purposes. I ts 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 docu ment. In addition, a staff report ensures that the correct procedures and proper documentation for app roval or adoption of a document have been performed. Finally, the staff report provides evid ence for defense against legal challenges regarding the propriety of the approval or adoption of the do cument.

II. EXECUTIVE SUMMARY
On July 1, 1997 the Antelope Valley Air Pollution C ontrol 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 C oast Air Quality Management District (SCAQMD) for the area of Los Angeles County outside the Sout h Coast Air Basin (SCAB). The SCAQMD rules in effect within the jurisdiction of the AVAPCD rem ained in effect until the AVAPCD Governing Board superceded, amended or rescinded them. On Ja nuary 1, 2002 the Antelope Valley Air Quality Management District (AVAQMD) was created pursuant t o 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 r escinded 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 rea dopted Rule 109 by statute January 1, 2002, and subsequently amended the Rule May 17, 2005. The Ma y 17, 2005 version is the version in the AVAQMD rulebook.
The AVAQMD is proposing to amend Rule 109 to includ e an alternative recordkeeping method of addressing certain industry practices. The trackin g and accounting of usage of many products in very small quantities on a daily basis is not cost-effec tive for the District or industry. This is a proce dural 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 chan ge in reporting method. Proposed amendments also update the list of rules with Rule 109 applicabilit y to account for revisions and amendments elsewhere in the rulebook.

III. STAFF RECOMMENDATION
Staff recommends that the Governing Board of the An telope Valley Air Quality Management District adopt the proposed amendments to Rule 109 – Recordk eeping for Volatile Organic Compound Emissions and approve the appropriate California En vironmental Quality Act (CEQA) documentation.

The Governing Board of the Antelope Valley Air Qual ity Management District amended Rule 109 – Recordkeeping for Volatile Organic Compound Emissio ns 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 re quired for the procedurally correct amendment of Rule 109 – Recordkeeping for Volatile Organic Compo und Emissions. Each item is discussed, if applicable, in Section V below. Copies of document s 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 ReviewAVAQMD Rule109 3

Final Staff Report 05/12/10 V. DISCUSSION OF LEGAL REQUIREMENTS

A. REQUIRED ELEMENTS/FINDINGS

This section discusses the State of California stat utory requirements that apply to the amendment of Rule 109. These are actions, that nee d to be performed, and/or information, that must be provided in order to amend the Rule in a pr ocedurally correct manner.

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

Before adopting, amending, or repealing a rule or r egulation, the AVAQMD Governing Board is required to make findings of necessity, au thority, clarity, consistency, nonduplication, and reference based upon relevant info rmation presented at the hearing. The information below is provided to assist the Board i n making these findings.

a. Necessity:

The AVAQMD is proposing to amend Rule 109 to includ e 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. T his 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 res ult of this change in reporting method.

b. Authority:

AVAQMD has the authority pursuant to California Hea lth and Safety Code (H&S Code) §40702 to adopt, amend or repeal rules a nd regulations.

c. Clarity:

The amendments are clear in that they are written s o that the persons subject to the Rule can easily understand the meaning.

d. Consistency:

The amendment of Rule 109 is in harmony with, and n ot in conflict with or contradictory to, any State law or regulation, fede ral 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 §4070 2 to adopt, amend or repeal rules and regulations.

g. Public Notice & Comment, Public Hearing:

The public hearing to consider the amendment of Rul e 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 re gularly scheduled meeting of 04/20/2010. See Appendix “B” for a copy of the pub lic notice. See Appendix C for copies of comments, if any, and AVAQMD response s.
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 la w 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 r equirements for a State Implementation Plan (SIP) submittal because Rule 10 9 will be included in the AVAQMD SIP. The criteria for determining completen ess 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 Rul e 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 re gularly scheduled meeting of 04/20/2010. See Appendix “B” for a copy of the pub lic notice.

c. Availability of Document:

Copies of the proposed amendment Rule 109 and the a ccompanying draft staff report were made available to the public on Februar y 1, 2010

d. Notice to Specified Entities

Copies of the proposed amendments to Rule 109 and t he 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 Rul e 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 re gularly 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 su ch acts as may be necessary or proper to execute the duties imposed upon the AV AQMD.

g. Applicable State Laws and Regulations Were Follo wed:

Public notice and hearing procedures pursuant to H& S Code §§40725-40728 have been followed. See Section (V)(A)(1) above fo r compliance with state findings required pursuant to H&S Code §40727. See Section (V)(B) below for compliance with the required analysis of existing r equirements pursuant to H&S Code §40727.2. See Section (V)(C) for compliance w ith economic analysis requirements pursuant to H&S Code §40920.6. See Se ction (V)(D) below for compliance with provisions of the California Enviro nmental 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 sa me equipment or source type as the rule for modification by the district. There is no change i n the quantity of product reported, or in emissions of VOC over time as a result of this chan ge in reporting method. Therefore the preparation of a written analysis of existing pollu tion 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 adopti on of the amendments to Rule 109.

2. Incremental Cost Effectiveness

Pursuant to H&S Code §40920.6, incremental cost eff ectiveness calculations are required for rules and regulations which are adopte d or amended to meet the California Clean Air Act requirements for Best Available Retro fit Control Technology (BARCT) or “all feasible measures” to control volatile comp ounds, oxides of nitrogen or oxides of6 AVAQMD Rule 109 Final Staff Report 05/12/10 sulfur. The amendment of Rule 109 is not subject t o incremental cost effectiveness calculations because this rule does not impose BARC T or “all feasible measures”.

D. ENVIRONMENTAL ANALYSIS (CEQA)

Through the process described below, it was determi ned that a Notice of Exemption would be the appropriate CEQA process for the amendment of R ule 109. The amendment of Rule 109 meets the CEQA definition of "project." They are no t "ministerial" actions.

1. The amendment of Rule 109 meets the CEQA definit ion of "project." They are not "ministerial" actions.

2. The amendment of Rule 109 is exempt from CEQA re view 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 ti me as a result of this change in reporting method and there is not potential that th e amendments might cause the release of additional air contaminants or create any advers e environmental impacts, a Class 8 categorical exemption (14 Cal. Code Reg. §15308) ap plies.

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS

1. Potential Environmental Impacts

There are no potential adverse environmental impact s 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 repor ted, 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 ai r 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), a s 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 u se of adhesives, coatings, solvents, and/or graphic arts materials, when records are required t o 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 repor ted 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 contr ol requirements. The amendment will include an alternative recordkeeping method of addr essing 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 u se of adhesives, coatings, solvents, and/or graphic arts materials, when records are required t o 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 curre nt district rules requiring recordkeeping as outlined by District Rule 109.

Definitions (B)(2) for Facility and (B)(6) for Sout h 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 approv ed 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 An telope 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 Cont rol 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 C ounties to replace the previous countywide air pollution control districts for thos e 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 juris diction that only included areas of Los Angeles, Orange, Riverside and San Bernardino C ounties contained within the South Coast Air Basin (SCAB). Outlying areas remai ned under the So. Cal. APCD (The legislation was thereafter amended to allow no n 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 Resou rces Board (CARB) issued Executive Order G-73 (1977) which adopted a “rule b ook” 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 e ffective 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 dissolutio n each county would regain its county air pollution control district with a jurisd iction 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 Ai r Pollution Control District (AVAPCD) replaced the SCAQMD as the agency with jur isdiction over the Los Angeles County portion of the Mojave Desert Air Bas in (MDAB). On 01/01/02 the AVAPCD was replaced by the AVAQMD. Pursuant to bot h statutory changes, the rule and regulations of the predecessor district were re tained until the Governing Board adopted, amended or rescinded them. At the first m eeting 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 wit hin the MDAB. The MDAB was formerly known as the Southeast Desert Air Basin (S EDAB). In 1997 the SEDAB wasAVAQMD 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 jurisdi ctional boundaries of local air districts, when the local air district boundaries change the S IP as approved by USEPA for that area up to the date of the change remains as the SI P in that particular area. Thus, upon creation of the AVAPCD on 07/01/97 the AVAPCD acqui red the SIP applicable to the Antelope Valley portion of the SCAQMD that was effe ctive as of 06/30/97. Likewise the AVAQMD acquired the SIP that was effective in t he jurisdiction of the AVAPCD as of 12/31/01. Therefore, the SIP history for this r egion 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 s tatute by the AVAPCD on 07/01/97, and again readopted by statute by the AVA QMD 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 avo id 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 t his category in the AVAQMD, the District is requesting that it be superseded. In o rder to replace existing SIP rules the District is required to show that the amendments ar e not less stringent than the provisions currently in the SIP.

The amendments to AVAQMD Rule 109 are primarily a p rocedural change in reporting periods and protocol. There is no change in the qu antity of product reported, or in emissions of VOC over time as a result of this chan ge 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 a mendment of Rule 109 being less stringent than the current version of the rule in t he SIP.AVAQMD Rule 109 A- 1

Final Staff Report 05/12/10 

### APPENDIX "A" Rule 109 – Recordkeeping for Volatile Organic Compo und Emissions Iterated Version

The iterated version is provided so that the change s to an existing rule may be easily found. The man ner of differentiating text is as follows:

1. Shaded text identifies new or revised language.

2. Lined out text identifies language which is bei ng deleted.

3. Normal text identifies the current language of t he current rule which will remain unchanged by the adoption of the proposed amendments.

4. Italicized text

identifies explanatory material that is not part o f the proposed language.A-2 AVAQMD Rule 109 Final Staff Report 05/12/10 This page intentionally left blank.( 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 forma t]

(1) Purpose

(a) The purpose of this rule is to ensure that adeq uate records of volatile organic compound use are made and maintained.

(2) Applicability

( a 1 ) The provisions of this rule shall apply to an own er or operator of a stationary source within the District conducting operations, w hich include the use of adhesives, coatings, solvents, and/or graphic arts materials, when records are required to determine a District rule's applicabili ty or source's exemption from a rule, rule compliance, or specifically as a Permit to Operate or Permit to Construct condition.

( b 2 ) District rules requiring recordkeeping as outline d 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 Ope rations, 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 Adhe sives, 1151 - Motor Vehicle and Mobile Equipment Non-Assem bly Line Coating Operations, 1162

- Polyester Resin Operations109-2 AVAQMD RULE 109 Recordkeeping for VOC Emissions d2, 02/18/10 1164 - Semiconductor Manufacturing, 1168 - Control of Volatile Organic Compound Emissio ns 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 uni ts, 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 C lassification manual; and is located on a single parcel of land or on contiguous propert y 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)]

( 2 3 ) Graphic Arts Materials - Any inks, coatings, adhesives, fountain solution s, thinners retarders, or cleaning solutions used in printing o r related coating or laminating
processes.
( 3 4 ) Low Solids Adhesive, Adhesive Primer, or Stain - An adhe a sive, adhesive primer or stain which has less than one pound of solids per gallon of material.

( 4 5 ) Permit Unit - Any article, machine, equipment, or other contri vance, or combination thereof, which may cause the issuance or control th e issuance of air contaminants, and which:

(a) requires Requires a written permit pursuant to the provisions of Dist rict 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 (SC AQMD) – 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)]

( 5 7 ) Stationary Source - Any permit unit or grouping of permit units or o ther air contaminant-emitting activities which are located o n 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 operate d by the same person (or by persons under common control). Such above-described groupi ngs, if non-contiguous, but connected only by land carrying a pipeline, shall n ot be considered one stationary

source.AVAQMD RULE 109 109-3

Recordkeeping for VOC Emissions d2, 02/18/10 ( 6 8 ) Volatile Organic Compound (VOC) - Any volatile compound of carbon, excluding carbon monoxide, carbon dioxide, carbonic acid, met allic 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 usi ng adhesives, coatings, solvents, and/or graphic arts materials and subject to this rule sha ll maintain daily records of operations for the most recent two (2) year period. The recor ds shall be retained on the premises of the affected operation for a period of not less tha n two (2) years. Said records shall be made available to the District upon request. The r ecords shall include, but not be limited to, the following:

(a) each Each applicable District rule number pertinent to the op eration 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 cat alyst 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 amounts containers 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 singl e 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 ca talyst and reducer), solvent, and/or graphic arts material;

(f) the The amount of diluent, surface preparation, clean-up, o r wash-up solvent (including exempt compounds) used and the VOC conte nt of each ( use of
amounts containers 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 req uired by rule.]109-4 AVAQMD RULE 109 Recordkeeping for VOC Emissions d2, 02/18/10 

### ( DE ) Test Methods

( 2 1 ) VOC content shall either be calculated using a pe rcent solids basis (less water and exempt solvents) for adhesives, coatings, and inks; or testing shall be done using USEPA Reference Method 24 (Determination of Volatil e Matter Content, Water Content, Density Volume Solids, and Weight Solids o f 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 Procedur e B of ASTM Method D-2369, referenced within USEPA Method 24. The exempt solv ent content shall be determined using SCAQMD Test Methods 302 and 303 (SCAQMD "Labo ratory Methods of Analysis for Enforcement Samples" manual). Alterna tively, 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 M aterial Safety Data Sheet (MSDS) or data sheet provided the test methods desc ribed above are used and specified on the MSDS or data sheet.

( 3 2 ) VOC content and density of rotogravure publicatio n inks shall be determined by USEPA Reference Method 24A (Determination of Volati le Matter Content and Density of Printing Inks and Related Coatings, Code of Fede ral Regulations Title 40, Part 60, Appendix A, 7/1/85 edition). The exempt solvent co ntent shall be determined using SCAQMD Test Methods 302 and 303 (SCAQMD "Laboratory Methods of Analysis for Enforcement Samples" manual). Alternatively, the V OC content may be determined using SCAQMD Test Methods 302, 303, and 304.

( 4 3 ) VOC content for low solid adhesive, adhesive prim er, or stain shall be calculated by the method used to calculate the "Grams of VOC per Lite r 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 method s are specified for any testing, noncompliance with any requirement of this rule est ablished by any one of the specified test methods or set of test methods shall constitut e a violation of this rule. [derived from SCAQMD Rule 109 (g)(8). Pursuant to EPA comment.]

The following classes of compounds: cyclic, branch ed, or linear, completely fluorinated alkanes; cyclic, branched, or linear, completely fl uorinated ethers with no unsaturations; cyclic, branched, or linear, completely fluorinated tertiar y amines with no unsaturations; and sulfurcontaining perfluorocarbons with no unsaturations a nd with sulfur bonds only to carbon and fluorine, will be analyzed as exempt compounds, onl y 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 b y the USEPA and the District, that can be used to quantify the amounts of each exempt compoun d.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 mak e it applicable to all substrates.]

[SIP: Submitted as amended mm/dd/yy on mm/dd/yy; A pproved: 4/13/95, 60 FR 18751, 40 CFR 52.220(c)(189)(i)(A)(6); Limited Approval/Disapprov al 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 This page intentionally left blankAVAQMD Rule 109 B- 1

Final Staff Report 05/12/10 

### APPENDIX "B" PUBLIC NOTICE DOCUMENTS

1. Proof of Publication for Notice of Public Hearing – Antelope Valley PressB-2 AVAQMD Rule 109 Final Staff Report 05/12/10 This page intentionally left blank.AVAQMD Rule 109 B3

Final Staff Report 05/12/10B-4 AVAQMD Rule 109 Final Staff Report 05/12/10 This page intentionally left blankAVAQMD Rule109 C- 1

Final Staff Report 05/12/10 

### 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.C-2 AVAQMD Rule 109 Final Staff Report 05/12/10 This page intentionally left blank.AVAQMD Rule109 C- 3

Final Staff Report 05/12/10 Comment Letter 1C-4 AVAQMD Rule 109 Final Staff Report 05/12/10 District response to Lockheed e-mail comment.

1. No comment required.AVAQMD Rule109 C- 5

Final Staff Report 05/12/10

1 Comment Letter 2C-6 AVAQMD Rule 109 Final Staff Report 05/12/10 District response to USEPA comment letter.

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

Final Staff Report 05/12/10 Comment Letter 3C-8 AVAQMD Rule 109 Final Staff Report 05/12/10 District response to ARB comment letter.

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

Final Staff Report 05/12/10 

### APPENDIX "D"

CALIFORNIA ENVIRONMENTAL QUALITY ACT

DOCUMENTATION (to be included as available)

1. Notice of Exemption, Los Angeles County.D-2 AVAQMD Rule 109 Final Staff Report 05/12/10 This page intentionally left blank.AVAQMD Rule 109 D3

Final Staff Report 05/12/10D-4 AVAQMD Rule 109 Final Staff Report 05/12/10 This page intentionally left blankAVAQMD Rule 109 E-1

Final Staff Report 05/12/10 

### APPENDIX "E" BIBLIOGRAPHY

The following documents were consulted in the prepa ration 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 Oper ations (03/20/07)E-2 AVAQMD Rule 109 Final Staff Report 05/12/10 This page intentionally left blank.