UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA ’ s Direct Final Rulemaking

for the California State Implementation Plan

PLACER COUNTY AIR POLLUTION CONTROL DISTRICT

Rule 229, Fiberboard Manufacturing

Rule 230, Plastic Products and Materials

– Paper Treating Operations

Prepared by: Arnold Lazarus Reviewed by: Andy Steckel

April 2014 2



RULE IDENTIFICATION

Agency: Placer County Air Pollution Control District ( PC APCD )

SIP Approved Rule : Rule 229

- Fiberboard Manufacturing

A dopted

- June 28, 1994

Submitted

- July 13, 1994

E PA Approved

- June 8, 2001 ( 66 FR 30815)

Rule 230

- P lastic Products and Materials

- Paper Treating Operations Adopted

- June 28, 1994

Submitt ed

- July 13, 1994 EPA Approved

- December 14, 1994 ( 59 FR 64336 )

Subject of this TSD: Rule 229

- Fiberboard Manufacturing

R escinded

- April 12, 2012

Submitted

- February 12, 2014

Rule 230

- P lastic Products and Materials

- Paper Treating Operation

Rescinded

- April 12, 2012

Submitted

- February 12, 2014

BACKGROUND

Rule 229: Fiberboard Manufacturing Placer County Air Pollution Control District (PCAPCD or “District” ) adopted Rule 229

to satisfy a Federal Clean Air Act (CAA) section 182 requirement that Districts adopt regulations for major source s of volatile organic compounds (VOC) using Reasonably

Available Control Technology (RACT). At the time of adoption, there was only one

source i n the District subject to R ule 229

, SierraPine

, that manufactured medium density

fiberboard

. The purpose of the rule was to control VOC emissions from the plant and set minimum VOC control efficiencies for various operations used in fiberboard manufacture.

Rule 230: Plastic Products and Materials

– Paper Treating Operations PCAPCD similarly adopted Rule 230 to satisfy CAA RACT requirements. At the time of adoption, there was only one source in the District subject to Rule 230

, Formica, a paper

treatment o peration. The rule applies to paper treating operations involving the application of melamine and phenol resins to paper substrates which have a potential to emit 25 tons or more of VOC per year. The purpose of the rule was to limit emissions through use o f

low

- VOC compounds, or through the use of control equipment to destroy VOC before being emitted to the atmosphere. 3



PURPOSE OF RULE RESCISSION

– PCAPCD rescinded Rule 229 and Rule 230 because the two major sources, SierraPine Fiberboard and Formica resp ectively

, shut down their operations subject to these rules in the following ma nner as stated in the

PCAPCD Staff Report , April 12, 2012

.

1. SierraP ine has shut down the fiberboard manufacturing equipment , surrendered the fiberboard manufacturing permits and is selling off the emission reduction credits. They do not expect to operate again at this location. There are no current sources subject to Rule 229 in Placer County.

2. Formica shut down all operations at the facility in June 2006 and obtained

Emission Red uction Credits for the shutdown emissions.

EPA EVALUATION

– EPA staff have reviewed the District’s staff report associated

with these rescissions and, o n March 31, 2014 , discussed the rescissions with PCAPCD management. EPA concurs with the District’s determination that : (a) currently there are no major sources in Placer County that emit VOCs as Rules 229 and 230 regulate; and (b)

a new facility would have to obtain a new permit that would have more stringent requirements and that the District would need to write new rules conforming to the current RACT and other CAA requirements. 1 As a result, we concur with the District that there is

no further need for these rules at this time.

EPA ACTION

– EPA staff rec ommends that the rescission of Rules 229 and 230 be approved

.

REFERENCES

1. PCAPCD Rule 229

, Fiberboard Manufacturing

, a dopted June 28, 1994

, submitted on July13, 1994

. 2. PCAPCD Rule 230, Plastic Products and Materials

- Paper Treating Operations, adopted June 28, 1994

, submitted on July13, 1994

. 3. PCAPCD Staff Report, April 12, 2012

1 Telephone Conference Call, Arnold Lazarus and Nancy Levin

, EPA Region 9

, and Todd Nishikawa,

PCAPCD

, March 31, 2014

.