UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

Ventura County Air Pollution Control District, Rule 74.2, Architectural Coatings

Prepared by: David Grounds

Reviewed by: Andrew Steckel

February 14 , 2011RULE IDENTIFICATION

Agency: Ventura County Air Pollution Control District (VCAPCD)

SIP Approved Rule : Rule 74.2

– Architectural Coatings Adopted

– November 13, 2001
Submitted

– March 15, 2002 EPA Approved

– January 2, 2004 (69 FR 34)

Subject of this TSD : Rule 74.2

– Architectural Coatings
Amended

– January 12, 2010
Submitted

– July 20, 2010

RULE SUMMARY

– VCAPCD Rule 74.2, Architec tural Coatings is a rule designed to reduce volatile organic compound (VOC) emissions from the coating of structures and their
appurtenances , mobile homes, portable buildings, pavements, or curbs. Architectural coatings are formulated with a variety of com ponents including pigments, resins, solvents, and different additives such as driers, anti

- skinning agents, anti

- sag agents, dispersing agents, defoaming agents, preservatives and fungicides. The primary source of air emissions from architectural coatings is the solvent component in solvent

- based coatings and the co

- solvents from waterborne coatings. Rule 74.2 is applicable to any person who supplies, sells, offers for sale, or manufactures, blends, or repackages any architectural coating for use within th e VCAPCD, as well as any person who applies or solicits the application of any architectural coating within the
VCAPCD.

The rule development is based on the Suggested Control Measure (SCM) adopted by the California Air Resources Board (ARB) on October 26, 2007. The SCM is a model rule which seeks to provide statewide consistency for the regulation of architectural coatings. The SCM was developed for districts that need additional emission reductions for the attainment or maintenance of state or federal ambient air quality standards. CARB amended the SCM to lower the VOC limits, improve definitions for coatings, and to promot e consistency and uniformity among district rules. Based on population factors, VCAPCD estimates it emits 2.1 tons per day (tpd) VOC and the estimated emission reduction from this proposed rule revision is about 0.5 tpd.

VCAPCD regulates a serious ozone n onattainment area for the 8

- hour ozone national ambient air quality standard (NAAQS)(40 CFR 81), and VCAPCD designed Rule 74.2 partly to address the requirements for ozone non

- attainment areas as described in Clean Air Act (CAA) section 182.Changes to t he SIP approved rule include:

Lowered VOC content for 19 architectural coatings. Deleted 15 coating categories. Added 10 new coating categories. Deleted Averaging Provision option.

EPA EVALUATION CRITERIA

- 1. Enforceability

– Section 110(a)(2)(A) of the CA A requires that regulations submitted to EPA for incorporation into the SIP must be clear and legally enforceable.

2. Stringency

- – VCAPCD regulates an ozone nonattainment area and is required to meet RACT (Reasonably Available Control Technology)

. We have compared Rule 74.2 against analogous rules in other areas and relevant national guidance including EPA’s Control Technique Guidelines (CTG) titled, “Industrial Cleaning Sol vents” (EPA

- 453/R

- 06

- 001, 9/06); “Control of Volatile Organic Emissions from Existin g Stationary Sources, Volume I: Control Methods for Surface Coating Operations” (EPA

- 450/2

- 76

- 028, 11/76 ); EPA’s national rule for architectural coating manufacturers, “National VOC Emission Standards for Architectural Coatings” (40 CFR 59 Subpart D, 9/11/ 98); a nd other state and local rules for this category were used to help evaluate the RACT requirements of CAA §182.

3. SIP Relaxation

– Where previous versions of rules have been SIP approved, new submittals must comply with CAA §110(l) and §193 regarding SIP relaxations.

EPA EVALUATON

– The submitted V CAPCD Rule 74.2 is more stringent than the approved SIP, largely because of the lowered VOC content limits for architectural coatings. The current SIP submittal generally contains sufficient testing and recordkeeping requirements to satisfy enforcement requirements. The stringency of requirements in submitted Rule 74.2 is also generally consistent with relevant national guidance and analo gous rules in other areas

.

RULE DEFICIENCIES

- We have identified no deficiencies with Rule 74.2 sufficient for EPA to

propose less than full approval.

RECOMMENDATIONS

– We recommend lowering the VOC content for Flat Coatings to 50 g/l to match CARB’s
200 7 SCM. We recommend lowering the VOC content for Primers, Sealers, and Undercoaters to
100 g/l to match CARB’s 2007 SCM. In Section J, Definitions, we recommend adding ‘Manufacturer’s Maximum Thinning
Recommendations’ to match CARB’s 2007 SCM.EPA ACTION

– Rule 74.2 largely fulfills the relevant CAA §110 and part D requirements. EPA

staff recommends full approval of Rule 74.2 pursuant to CAA §110(k)(3) and §301(a).

REFERENCES

– VCAPCD Rule 74.2, Architectural Coatings, Amended January 12, 2010.
V CAPCD S taff Report, November 10, 2009. EPA Rule Review Comments, December 16, 2009.