UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA ’ s Direct Final Rulemaking

for the California State Implementation Plan

Antelope Valley Air Qualit y Management

Rule 1174 Control o f Volat ile Organic Compound Emissions

f rom the Ignition o f Barbecue Charcoal

Prepared by: Stanley Tong

August 2013 2



RULE IDENTIFICATION

-

Agency: Antelope Valley Air Quality Management District ( AV AQMD)

SIP Approved Rule: Rule 1174

– Control o f Volatile Organic Compound

Emissions f rom the Ignition o f Barbecue Charcoal

A dopted

– October 5, 1990

Submitted

– May 13, 1991 EPA Approved

– October 4, 1994 ( 59 FR 50498 )

Subject of this TSD: Rule 1174

– Control o f Volatile Organic Compound

Emissions from the Ignition o f Barbecue Charcoal

Rescinded

– November 20, 2012

Submitted

– April 22, 2013

BACKGROUND

– On July 1, 1997 the Antelope Valley Air Pollution Control District (AVAPCD) was formed and assumed all air pollution control responsibilities from the South Coast Air Quality Management District (SCAQMD) for the areas of Los Angeles County outside the South Coast Air Basin. 1 All SCAQMD rules in effect at the time, including Rule 1174 , remained in effect under the newly formed AVAPCD. On January 1, 2002, the Antelope Valley Air Quality Management District (AVAQMD) replaced the

AVAPCD.

On October 5, 1990, the SCAQMD adopted Rule 1174

, Control of Volatile Organic Compound Emissions from the Ignition of Barbecue Charcoal

. The rule applies to manufacturers, distributors, and/or retailers of charcoal lighter materials. On October 4

, 19 94 (5 9 FR 50498 ) we approved SCAQMD Rule 1174 into the state implementation plan ( SIP )

. When Antelope Valley was formed in 1997, the requiremen ts in SCAQMD Rule 1174 became a part of Antelope Valley's SIP until such time the Antelope Valley amended or rescinded the rule and those amendments were approved into the SIP. Neither South Coast nor Antelope Valley AQMDs have amended Rule 1174 since it

w as adopted.

Shortly after SCAQMD adopted R ule 1174, the California Air Resources Board (CARB) adopted nearly identical VOC standards for charcoal lighter materials that would be applicable in all areas of California except in the S CAQMD

. CARB's rule appl ied to any person who sold, supplied, offered for sale, or manufactured consumer products for use

in the state of California.

In 1998 EPA promulgated a national consumer products rule which included nearly identical requirements as Antelope Valley Rule 11 74 and CARB's regulations for

1 Antelope Valley Air Quality Management District, Final Staff Repo rt, Rescission of Rule 1174

– Control of Volatile Organic Compound Emissions from the Ignition of Barbecue Charcoal, Adopted on November 20,

2012 , page 1. 3



charcoal lighter materials. The rule applie d to manufacturers, importers and distributers. (See 40 CFR 59 subpart C)

RULE SUMMARY

– Rule 1174 prohibits any person from supplying, selling, or offering for sale, any material an d/or method used to ignite barbecue charcoal unless the VOC emissions are less than or equal to 0.02 pounds of VOC per start.

PURPOSE OF RULE RESCISSION

– Antelope Valley is rescinding Rule 1174 because

CARB and EPA have adopted similar regulations coveri ng VOC standards for charcoal lighter materials. AVAQMD's staff report states Rule 1174 can be rescinded as it is duplicative of state and federal regulations and places a redundant regulation on this

source.

EPA EVALUATION

– There will be no e ffect on ai r pollution from rescinding Rule 1174

since sources would still be subject to both CARB's SIP approved consumer products

rule and EPA's national rule . CARB's and EPA's rules co ntain additional provisions beyond those found in A VAQMD Rule 1174 , including in itial notifications and product labelling requirements . While CARB's and EPA's Consumer Products rules contain an exemption which allows l ow vapor pressure (LVP) compounds to be excluded from a consumer product's VOC limit , the two rules clarify that th is LVP exemption does not apply to t he charcoal lighter material category

. 2

EPA ACTION

- EPA staff recommends approval of the rescission of AVAQMD Rule

1174 pursuant to CAA §110( k)(3) and §301(a).

REFERENCES

- 1

. AV AQMD Rule 1174 , Con trol of Volatile Org anic Compound Emissions from the Ignition of Barbecue Charcoal, a dopted October 5, 1990

, submitted on May 13,

1991

.

2

. 40 CFR 59 Subpart C

— National Volatile Organic Compound Emission

S tandards for Consumer Products (7/1/2012 edition)

3

. California Code o f Regulations, Title 17, Division 3, Chapter 1, Subchapter 8.5,

Article 2. Consumer Products (Hearing September 24, 2009, amended August 6, 2010, SIP approved February 13, 2012 77 FR 7535

.

2 CARB's Consumer Products Rule

– Section 94509(h)(2)(A) states "The provisions relating to

LVP

- VOC i n sections 94508(a) [ Definitions ] and 94510(d) [ LVP exemption ] shall not apply to any charcoal lighter material subject to the requirements of sections 94509(a) [ Table of Standards Percent Volatile Organic Compound by Weight ] and (h) [ Requirements for char coal lighter

materials ].

For EPA 's national Consumer Products Rule

, 40 CFR 59. 203(f) states the VOC content limits in

table 1 of the Consumer Products rule shall not include any VOC that has a vapor pressure less than 0.1 millimeters of mercury at 20 deg rees Celsius. The VOC limit for charcoal lighter material

is not part of table 1 of the national rule, but is found in 40 CFR 59.208(e)(2).