UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for EPA’s Proposed Rulemaking

for the

California State Im plementation Plan

San Joaquin Valley Air Pollution Control District, Rule 4606, Wood Products and Flat Wood Paneling Product Coating Operations

Prepared by: Nicole Law Reviewed by: Andrew Steckel

June 2009- 2 - RULE IDENTIFICATION -

Agency: San Joaquin Valley Air Pollution Control District (SJVAPCD)

SIP Approved Rule: Rule 4606 – Wood Products and Flat Wood Paneling Products Coating Adopted – December 20, 2001; Submitted – February
20, 2002 EPA Approved – June 26, 2002 (67 FR 42999)

Superseded Submittals: Adopted – September 20, 2007; Submitted – March 7,

2008

Subject of this TSD: Rule 4606 – Wood Products and Flat Wood Paneling Products Coating Amended – October 16, 2008; Submitted – December
23, 2008

RULE SUMMARY - SJVAPCD Rule 4606, Wood Products and Flat Wood Paneling Products Coating, is a rule designed to limit volatile organic compound (VOC) emissions from facilities engaged in coating of wood products and flat wood paneling. It also limits VOC emissi ons from organic solvent cleaning and storage and disposal of solvents and wast e solvent materials associated with such coating. The rule describes related administrative requirements for recording and measuring emissions. Changes from the approved SIP rule

include:

1. Changed the applicability to include flat wood paneling.

2. Added several definitions in Se ction (3.0) and made numerous other editorial changes to improve clarity.

3. Added requirements for flat w ood paneling which include VOC limits, control efficiencies, and work practice standards.

4. Exemption in Section (4.5) regardi ng incineration devices was removed.

5. Added capture and control effici ency equations under test methods.

6. Lowered VOC limits for organic solvent s used in cleaning operations to 25 grams of VOC per liter of material.

EPA EVALUATION - The following criteria were used to evaluate the submitted

rule.

1. Enforceability - The Bluebook ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations , EPA, May 25, 1988), the Little- 3 - Bluebook ( Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001) and State Implementation Plans, General Preamble for the Implement ation of Title I of the Clean Air

Amendments of 1990 (57 FR 13498, April 16, 1992) were used to help evaluate compliance with the CAA § 110(a)(2)(A) requirement for enforceability.

2. RACT – EPA’s Control Technique Gui delines (CTGs) titled, “Control of Volatile Organic Compound Emissions fr om Wood Furniture Manufacturing Operations” (EPA-453/R- 96-007, April 1996), “Control Techniques Guidelines for Flat Wood Paneling Coatings” (EPA-453/R-06-004, September 2006), SJVAPCD’s 2009 RACT SIP Demonstration (April 16, 2009), “Preamble, Final Rule to Implement the 8-hour Ozone National Ambient Air Quality Standard: (70 FR 71612 November 29, 2005), Letter from William T. Hartnett to Regional Air Division Directors, “RACT Qs & As – Reasonable Available Control Technology (RACT) Questions and Answers” (May 18, 2006), and other stat e and local rules for this category were used to help evaluate the RACT requirements of CAA § 182(b)(2).

3. SIP Relaxation - Where previous ve rsions of rules have been SIP approved, new submittals must comply with CAA § 110(l) and § 193 regarding SIP

relaxations.

On April 16, 2009, SJVAPCD adopted its “2009 RACT SIP,” which provides the District’s demonstration that RACT is implemented for all appropriate activities. This includes several pages discussing Rule 4606 (cover and applicable pages attached). In summary, SJVAPCD found that:

- Rule 4606 satisfies RACT because it is consistent with the requirements in the 1996 CTG, “Wood Furniture Manufac turing Operations” and the 2006 CTG, “Flat Wood Paneling Coatings.”

- Rule 4606 is as stringent as other rules in other large California

nonattainment areas.

We concur with SJVAPCD’s conclusion that Rule 4606 implements RACT for reasons including:

- EPA’s 2006 CTG, “Flat Wood Paneling Coatings,” generally defines presumptive RACT for this activity nat ionwide as VOC limits in coatings of 250 grams of VOC/liter of coating and 350 grams of VOC/gram of solids. SJV Rule 4606 contains the VOC limits and work practices recommended in

this 2006 CTG.

- The requirements in Rule 4606 ar e generally more stringent than EPA’s 1996 CTG, “Wood Furniture Manufacturing O perations.” While Rule 4606- 4 - exempts refinishing, replacement, and custom replica furniture operations from VOC control requirements and t he CTG does not, only two sources in the district fall under this categor y, and both have VOC emissions well

below the CTG threshold of 10 t ons/year of VOC per facility.

- Most requirements in Rule 4606 ar e equivalent or more stringent than requirements in analogous rules in other large California nonattainment areas. While a few requirements are more stringent in other areas, the variations are not significant and ar e generally offset by other more stringent requirements in Rule 4606.

- SJVAPCD, SCAQMD and the other large California nonattainment agencies generally have among the most stringent stationary source requirements nationwide, and we ar e not aware of other reasonably available technological or operational c ontrols likely to significantly reduce additional emission from this activity.

Therefore, we believe Rule 4606 meets RACT requirements. In addition, recordkeeping and other compliance provis ions in the rule ensure that the requirements are adequately enforceable. Las tly, the submitted rule is more stringent than the version previously approved into the SIP, so the submitted rule does not relax the SIP and comp lies with CAA §110(l) and §193.

RULE DEFICIENCIES – We have identified no deficiencies with Rule 4606 sufficient for EPA to propose less than full approval.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION - The following revisions are not currently the basis for rule disapproval, but are

recommended for the next time the rule is amended.

1. Consistent with the CTG for Emissi ons from Wood Furniture Manufacturing Operation” (EPA-453/R-96- 007, April 1996), we recommend the addition of an operator training program to work practices.

2. We recommend adding VOC limits for refinishing, replacement, and custom replica furniture operations. For example, please see SMAQMD Rule 463 Section (303) and VCPCD Rule 74.30 Section (B.2).

3. We recommend full titles of ARB test methods be added to Section (6.8).

EPA ACTION - The revised Rule 4606 mainly incorporates new requirements for coating operations of flat wood panels, strengt hening the SIP. SJVAPCD projects no significant emission impacts from t hese changes, as there are no coating operations for flat wood panels in the district. The rule fulfils the relevant CAA §110 and part D requirements. EPA sta ff recommends approval of Rule 4606
pursuant to CAA § 110(k)(3).- 5 - ATTACHMENTS – 1. SJVAPCD Rule 4606, Wood Products and Flat Wood Paneling Products Coating Operations, as subm itted on December 23, 2008. 2. SJVAPCD Rule 4606, Wood Products Coating Operations, as approved into the SIP on June 26, 2002. 3. “Control of Volatile Organic Co mpound Emissions from Wood Furniture Manufacturing Operations,” EPA-453/R-96-007, April 1996. http://www.epa.gov/ttn/naaqs/ozone/ctg_act/199604_voc_epa453_r-96- 007_wood_furniture_manufacturing.pdf4. “Control Techniques Guidelines for Flat Wood Paneling Coatings,” EPA453/R-06-004, September 2006. http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200609_voc_epa453_r-06- 004_wood_panel_coatings.pdf 5. “Reasonably Available Control Technology (RACT) Demonstration for Ozone State Implementation Plans (SIP)” SJVAPCD, April 16, 2009.

ADDITIONAL REFERENCES - 1. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

2. “Guidance Document for Corre cting Common VOC & Other Rule Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001. 3. Portions of the proposed post- 1987 ozone and carbon monoxide policy that concern RACT, 52 FR 45044, November 24, 1987. 4. “State Implementation Plans, Gener al Preamble for the Implementation of

Title I of the Clean Air Amendments of 1990” 57 FR 13498, April 16, 1992. 5. “Preamble, Final Rule to Implement the 8-hour Ozone National Ambient Air Quality Standard” 70 FR 71612; Nov. 29, 2005.

6. Letter from William T. Hartnett to Regional Air Division Directors, “RACT Qs & As – Reasonable Available Control Technology (RACT) Questions and Answers,” May 18, 2006.