Technical Support Document

For The

• Antelope Valley Air Quality Management District

Rule 107, Certification of Submissions and Emission Statements

Prepared by: Cynthia Allen

Reviewed by: Andrew Steckel

October 2012
V Adopted — May 15, 2012

BACKGROUND

Federal Clean Air Act (CAA) Section 1 82(a)(3)(B)(i) requires ozone nonattainment

areas (regardless of classification) to require certified emission statement data from

sources of volatile organic compounds (VOCs) and oxides of nitrogen (NOx). Emission

statements should be submitted by November 15, 1993 and annually thereafter. CAA

Section 1 82(a)(3)(B)(ii) allows states to waive the requirement for emission statements

for classes or categories of sources with less than 25 tons per year (tpy) of actual plantwide NOx or VOC emissions if the State provides an inventory of emissions from the

class or category based on the use .of emission factors established by EPA or other

methods acceptable to EPA. Emission Statements are intended to help the state report

and analyze ambient air emissions. The CAA also requires states to periodically

compile and report a comprehensive, accurate and current inventory of all air

contaminant sources.

RULE SUMMARY

Rule 107 requires the owner or operator of a stationary sources emitting VOC or NOX

to provide AVAQMD with an annual statement of actual emissions. The emission

statement must contain the information described in the California Air Resources Board

(CARB) Emission Inventory Guidelines. The statement must also contain a certification

signed and dated by a responsible official of the company, which attests that the

information contained in the submitted documents are accurate to the best knowledge

of the individual certifying the submission. The APCO may waive the emission

statement requirement for sources which emit less than 25 tpy if AVAQMD providesGARB with an emission inventory of sources emitting greater than 10 tpy of VOC or

NOx using emission factors acceptable to CARB and U.S. EPA..

Rule 107 is an administrative rule, and will have no effect on emission or emission limits

and will merely specify certification of documents and submission requirements of

emission statements.

EPA EVALUATION

The following criteria were used to evaluate the submitted rule:

1. CM Requirements: Section 1 82(a)(3)(B) and EPA’s draft “Guidance on the

Implementation of an Emission Statement Program,” July 1992.
enforceability of emission control requirements in other ICAPCD rules.

The rule requires that the emission statements contain all of the information found in thethe CARB Emission Inventory Guidelines, which are currently updated annually to meet

State and Federal reporting requirements. The CAA does not provide formatting

requirements or specify timing beyond that reports must be submitted annually, and

deference is given to the State to assure that all information needed to meet Federal’

reporting requirements is requested. To ensure consistency and accuracy of reporting,however, we recommend further details be included within the rule as described in

“Additional Recommendations for the Next Rule Revision” below.

The rule requirements are clear and enforceable consistent with CAA Section

I 10(a)(2)(A).

EPA ACTIONEPA staff recommends approval of AVAQMD Rule 107 under section 110(k) as

meeting the requirements of section 110(a) and Part D of the Clean Air Act, as

amended in 1990.

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

recommended as improvements the next time the rule is revised.

• To ensure clarity and consistency in how emission estimates are generated, we

recommend that future revisions to the rule include a list of minimum data

elements required in emission statements as described in section 2.2.6, 2.27,and 2.28 of the guidance document “Guidance on the Implementation of an

Emission Statement Program,” July 1992 or other details as required by federal

reporting requirements.

REFERENCES

1. Issues Relating to VOC Regulation, Cutpoints, Deficiencies, and Deviations (the

“Blue Book”), U.S. EPA, OAQPS, May 25, 1988.

2. Requirements for Preparation, Adoption, and Submittal of Implementation Plans,

U.S. EPA, 40 CFR Part 51.