UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for EPA’s Direct Final Rulemaking

for the California State Implementation Plan

FEATHER RIVER AIR QUALITY MANAGEMENT DISTRICT

Rule 3.20

, Wood Products Coating Operations

Prepared by: Arnold Lazarus Reviewed by: Andy Steckel

October 20142

RULE IDENTIFICATION

Agency: Feather River Air Quality Management District (FRAQMD)

SIP Approved Rule: There are no versions of FRAQMD Rule 3.20 which have been SIP approved.

Subject of this TSD: Rule 3.20

- Wood Products Coating Operations

A dopted

- August 1 , 20 11
Submitted

- February 10, 2014

RULE BACKGROUND

–

Under Section 107(d) of the Clean Air Act (CAA), EPA designated portions of Yuba and Sutter counties nonattainment for the following three National Ambient Air Quality Standards (NAAQS): 1

- hour ozone, 1997 8

- hour ozone and 2008 8

- hour ozone . These areas are regulated by the Feather River Air Quality Management District (FRAQMD).

FRAQMD Rule 3.20 is a new rule to the federally approved State Implementation Plan (SIP) that was adopted by FR AQMD to establish limits on the emission of volatile organic compounds (VOC) from coating and strippers used on wood products. According to the associated FRAQMD Staff report, “ Feather River Air Quality Management District (District) is a Bi

- County agency that administers local, state, and federal air quality management programs for Yuba and Sutter Counties. ” 1 On August 18, 2014, FRAQMD adopted Resolution #2014

- 10 adopting a RACT Analysis and Negative Declaration Staff Report declaring “there are no major sources of ozone precursors and that the District’s rules are as stringent as the CTG’s for the applicable source type.” 2 The CTGs cited for which FRAQMD adopt ed a Negative Declaration

include : 1. Control of Vol atile Organic Compound Emission from Wood Furni ture Operations

EPA

- 453/R

- 96

- 007 1996/04

. 2. Control Technique Guidelines for Flat Wood Paneling Coatings EPA

- 453/R

- 06

- 004 2006/09

.

R ULE SUMMARY

- FRAQMD Rule 3.20, Wood Products Coating Operations (WPCO)

, is a rule designed to establish limits on the emission of VOC from coatings and strippers used on wood products . According to the Staff Report, it was based on Sacramento Metropolitan A ir Q uality M anagement D istrict (SMAQMD) Rule 463, “Wood Products

1 FRAQMD Final Staff Report, “Rule 3.14 : Surface Preparation and Clean

- up, Rule 3.19: Vehicle and Automotive Coating Operations, Rule 3.20: Wood Products Coating Operations. Rule 1.1 Definitions” June 6, 2011, p.1.

2 Letter of Declaration, Feather River AQMD to California Air Resources Board, August 18, 2014.3

Coat ings

. ” 3 Rule 3.20 includes the following major requirements:

1. Th e rule applies to any person who uses, manufactures, blends, sells, repackages, distributes, or specifies the use of wood products coatings and/or strippers for use within the District.

2. Wood coating products may only be applied when using one of the listed application methods in section D.1

.

3. The rule established VOC content limits for wood coatings of various categories

in sections D. 2 and D. 3. There are also VOC content limits for strippers in

section D. 4

.

4. As an alternative to using compliant coatings, a person may use emission control equipment, provided the equipment achieves an equivalent or greater level of VOC reductions as using comp liant coatings. The requirements are outlined in

section D. 5.

5. Another alternative to using compliant coatings is the averaging provision

described in section D.6

.

6. The rule established various administrative requirements outlining labeling, vapor

pressur e calculations, VOC content calculations, and operation and maintenance plan requirements, recordkeeping, records retention, and test methods used in

sections F and G

.

EPA EVALUATION CRITERIA

– The following criteria were used to evaluate the

submitted ru le.

1. Enforceability

- The Bluebook ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations , EPA, May 25, 1988) and The Little Bluebook ( Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate compliance with the CAA §110(a)(2)(A) requirement for enforceability.

2. Stringency

– Rule 3.20 is not subject to RACT because FRAQMD has submitted a “negative declaration” stating that there are no major sources or sources subject to EPA’s CTG emitting VOC in the District. However, we are comparing

Rule 3.20 to SMAQMD Rule 463

, Ventura County A ir P ollution C ontrol D istrict (VCAPCD) Rule 74.30, San Joaquin Vall e y A ir P ollution C ontrol D istrict (SJVAP CD) Rule 4606 a nd the relevant CTG 4 in case RACT is required in the

future.

3 FRAQMD Staff Report, “ Rule 3.20, Wood Products Coating Operations ” August 30, 2005, p.2.

4 “Control of Volatile Organic Compound Emissions from Wood Furniture Operations” (EPA

- 453/R

- 06

- 007, April 1996)4

3. SIP Relaxation

- CAA § 110(l) prohibits EPA from approving any SIP revision that would interfere with any applicable requirement concerning attainment and reasonable further progress (RFP) or any other applicable requirement of the CAA. In addition, CAA § 193 prohibits the modifi cation of any SIP

- approved control requirement in effect before November 15, 1990, in a nonattainment area.

EPA EVALUATION

1. The rule requirements and applicability are clear, and the monitoring, recordkeeping, reporting and other provisions sufficiently e nsure that affected sources and regulators can evaluate and determine compliance with Rule 3.20 consistently. Therefore, we determine that the rule adequately fulfils the enforceability requirements summarized in paragraph #1 above.

2. The submitted rule has almost identical VOC content limits and similar administrative requirements as SMAQMD Rule 463 , VCAPCD Rule 74.30,

SJVAPCD Rule 4606 and is generally more stringent than the CTG. However, several provisions discussed below in the recommendations section may need to be addressed in order to determine that this rule implements RACT should that

be needed in the future.

3. W e propose to determine that our approval of the submittal would comply with

CAA §§ 110(l) and 193 because (1) the proposed SIP revision would not interfere

with the on

- going process for ensuring that requirements for RFP and attainment of the NAAQS are met, and (2) the emission limits and other requirements in the

submitted rule clearly strengthen the SIP because there are currently no requirements specifically pertaining to WPCO currently in the FRAQMD portion

of the SIP

.

RULE DEFICIENCIES

– We have identified no deficiencies with Rule 3.20 sufficient for EPA to propose less than full approval at this time

.

EPA ACTION

- Rule 3.20 satisfies relevant CAA §110 and part D requirements. Therefore, EPA staff recommends full approval of this rule into the SIP.

EPA RECOMMENDATIONS

The following revisions are not currently the basis for rule disapproval but are

recommended for the next time the rule is amended.

1. Sources using less than 55 gallons per year of wood product coatings and/or strippers are exempt from the requirements of t his rule. B ay A rea A ir Q uality

M anagement D istrict (BAAQMD) Rule 8

- 32, SJVAPCD Rule 4606, and Santa Barbara County Air Pollution Control District (SBAPCD) Rule 351 limit this exemption to 20 gallons per year. We recommend revising Rule 3.20 consistent5

with these other district r equirements

.

2. The VOC limit for “High

- Solid Stain” in Section D .2 is 350 g/l. SJVAPCD Rule 4606, SBAPCD Rule 351, and VCAPCD Rule 74

- 30 all have a limit of 240 g/l for this category. We recommend revising Rule 3.20 consistent with these other

district rules.

3. The VOC limit for “Sealer” in Section D .2 is 275 g/l. V C APCD Rule 74

. 30 has a limit of 240 g/l for this category. We recommend revising Rule 3.20 consistent

with V C APCD Rule 74

- 30.

4. Consiste nt with the CTG for Emissions from Wood Furniture Manufacturing Operation” (EPA

- 453/R

- 96

- 007, April 1996), we recommend the rule add an operator training program to work practices. See, e.g.

, Appendix B of the cited

CTG (B.5 (b) ) , “Operator Training Cours e.”

5. We recommend removing “Stencil Coatings when used to comply with U.S. Military Specifications” from “Exemptions” (Section B.1.e.) to be consistent with
SMAQMD Rule 463

.

6. We recommend full titles of ASTM test methods and the appropriate year be

added to Section G

.

7. We recommend removing exemption B.1. c

. SBAPCD Rule 351

, VCAPCD Rule

74.30 and SJVAPCD Rule 4606 do not have an exemption for flat paneling.

8. We recommend removing the Emissions Averaging Plan option in section E.3, or revising it consistent with EPA’s Economic I ncentive Policy guidance 5 and the

CTG. 6 This likely includes, for example, allowing averaging only for section D.3 (Refinishing, Repairing, Preserving or Restoring Wood Products)

, limiting averaging to a maximum of 20 ga llo ns per year and ensuring an environmental benefit of the averaging option.

5 Improving Air Quality with Economic Incentive Programs , EPA

- 452/R

- 01

- 001, January 2001.

6 Control Techniques Guidelines, EPA 453

- R

- 96

- 007 Control of VOC Emission from Wood Furniture Manufacturing Operations, April 1996, Section 7, P.4.6

R EFERENCES

1. FRAQMD Rule 3.20

- Wood Products Coating Operations , amended August 1,

2011.

2. The Bluebook ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and

Deviations , EPA, May 25, 1988)

. 3. The Little Bluebook ( Guidance Document for Correcting Common VOC & Other

Rule Deficiencies, EPA Region 9, August 21, 2001)

. 4. SMAQMD Rule 463, Wood Products Coatings

, a mended September 25, 2008

. 5. SBAPCD Rule 351 , Surface Coating of Wood Products, amended August 20,

1998

. 6. SJVAPCD Rule 4606 , Wood Products and Flat Wood Paneling Products Coating Operations , Amended October 16, 2008.

7. VCAPCD Rule 74.30, Wood Products Coatings, amended June 27 , 2006.

8. BAAQMD Rule 8.32, Wood Products Coatings, amended December 20, 1995.

9. Control Techniques Guidelines, EPA 453

- R

- 96

- 007 Control of VOC Emission from Wood Furniture Manufacturing Operations, April 1996.

10. Control Technique Guidelines for Flat Wood Paneling Coatings EPA

- 453/R

- 06

- 004 , S eptember 2006