# Air Pollution Control Board

San Diego County Air Pollution Control

District



### AGENDA ITEM Governing Body

GREG COX

First District

DIANNE JACOB

Second District

PAM SLATER

- PRICE

Third District

RON ROBERTS

Fourth District

BILL HORN

Fifth District

Documentum Version 3.1 DATE: November 9, 2011 

# AP02

TO: Air Pollution Control Board

SUBJECT: NOTICED PUBLIC HEARING

– ADOPTION OF AMENDMENTS TO

RULE 67.4

– METAL CONTAINER, METAL CLOSURE

, AND METAL

COIL COATING OPERATIONS (D ISTRICT : All )

SUMMARY:

Overview

T he Air Pollution Control Board is request ing to adopt proposed amendments to

Rule 67.4

, limiting emissions of volatile organic compounds from the application of coatings to metal containers, closures, and coils and related cleaning activities . Volatile organic compounds emitted into the atmosphere contribut e to the formation of ozone, which at elevated levels can impact public health

. Despite substantial air quality improvement over the past two decades, San Diego County does not yet attain s tate and

federal air quality standards for ozone.

The amendment s, if adopted, will reduce the allowable amount of volatile organic compounds in cleaning materials used in affected coating operations, consistent with existing requirements of several air districts in California. The amendments help fulfill

federal and state requirements in ozone nonattainment areas to update rules as necessary to reflect the current state of air pollution control technology.

Recommendation(s)

AIR POLLUTION CONTROL OFFICER

1. Find that the adoption of amended Rule 67.4 is categorically exempt from the provisions of the California Environmental Quality Act pursuant to California Code of Regulations, Title 14, Section 15308, as an action taken to assure the protection of the environment, where the regulatory process involves procedures for protection of the environment, and pursuant to California Code of Regulations Title 14, Section 15061(b)(3), since it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment.

2. Adopt the resolution entitled Resolution Amending Rule 67.4

– Metal Container, Metal Closure and Metal Coil Coating Operations into Regulation IV of the Rules and Regulations of the San Diego County Air Po llution Control District.SUBJECT: NOTICED PUBLIC HEARING

– ADOPTION OF AMENDMENT TO RULE

67.4

– METAL CONTAINER, METAL CLOSURE

, AND METAL COIL COATING OPERATIONS (District: All)

- 2

- Fiscal Impact

The proposed amendments to Rule 67.4 will not have a fiscal impact on the Air

Pollution Control District. The rule will be implemented and enforced with existing

Air Pollution Control District staff.

Business Impact Statement Adopting the proposed amendments to Rule 67.4 will not adversely impact the business community. The companies subject to the rule already use cleaning materials that comply with the proposed amendments.

Advisory Board Statement At its meeting on April 14

, 2011, with a quorum present, the Air Pollution Control District Advisory Committee support ed the Air Pollution Control District’s

recommendations.

BACKGROUND: San Diego County does not currently meet the National and State Ambient Air Quality Standards

for ozo ne and therefore is classified as an ozone nonattainment area. Both federal and s tate laws require the San Diego County Air Pollution Control District (District) to implement rules that regulate emissions of ozone precursors

– volatile organic compounds (VOCs) and oxides of nitrogen.

Existing Rule 67.4 regulates VOC emissions from metal container, metal closure

, and metal coil coating operations. The rule was adopted in 1979 and last revised in 1996

. The major goal in amending Rule 67.4 is to make the VOC emission limits consistent with those in other districts

and to reflect the greater level of control actually achieved by the two companies subject to the

rule , in compliance with federal and s tate requirements

. Following its adoption, p roposed

amende d Rule 67.4 will be submitted to the U.S. Environmental Protection Agency to replace existing Rule 67.4 in the State Implementation Plan

.

The proposed amendments reduce the VOC content limit for cleaning materials to 25 grams per liter unless specified cl eaning and emission control equipment is used ; include a new section to require the use of high transfer efficiency coating application equipment ; clarify record keeping requirements ; and update definitions of terms used in the rule. In addition, the prop osed

amend ments update the test methods for determining the content of VOC and exempt compounds in coatings and cleaning materials and the overall efficiency of emission control

systems.

There are two facilities subject to Rule 67.4 in San Diego County. One facility currently uses

water

- based coatings with a very low VOC content and water as a cleaning material, and has negligible VOC emissions. The other facility currently uses low VOC content coatings and acetone (an exempt compound) as a cleaning ag ent. The total VOC emissions from this facility are about 3.6 tons/year. Both companies already comply with all proposed rule amendments.SUBJECT: NOTICED PUBLIC HEARING

– ADOPTION OF AMENDMENT TO RULE

67.4

– METAL CONTAINER, METAL CLOSURE

, AND METAL COIL COATING OPERATIONS (District: All)

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- Socioeconomic Impact Assessment Section 40728.5 of the State Health and Safety Code requires the District to assess the socioeconomic impacts when adopting, amending, or repealing a rule that will significantly affect air quality or emission limitations. While the amendments to Rule 67. 4 require using cleaning materials with a lower VOC content for coating operations, th e proposed emission limits are already being achieved by the facilities subject to this amended rule. The cleaning materials used by these facilities are now in complian ce. Accordingly, th is requirement will not adversely affect facilities subject to the rule , and the adoption of the amendments to Rule 67.4 will not significantly affect air quality or emission limitations and does not require a Socioeconomic Impact Asses sment.

Environmental Statement The adoption of amended Rule 67.4 is exempt from the California Environmental Quality Act (CEQA) pursuant to California Code of Regulations, Title 14, Section 15308, as an action taken to assure the protection of the environm ent, where the regulatory process involves procedures for protection of the environment. In this case, this action is being taken in response to federal and

s tate requirements to reduce emissions of VOCs in order to achieve ambient air quality

standards. Additionally, this action is also exempt pursuant to California Code of Regulations Title 14, Section 15061(b)(3), since it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environm ent. The two facilities subject to the amended rule are already operating in compliance with the amended requirements, and will not be required to change their operations.

Linkage to the County of San Diego Strategic Plan The County's five

- year strategic plan includes an Environment Initiative to ensure environmental preservation and enhance quality of life. The proposed amendments to Rule 67.4 will codify the use of materials with a very low content of VOCs that contribute to ozone formation, without

neg atively impacting the local business community. The rule balances air quality preservation, public health protection, and economic development needs.SUBJECT: NOTICED PUBLIC HEARING

– ADOPTION OF AMENDMENT TO RULE

67.4

– METAL CONTAINER, METAL CLOSURE

, AND METAL COIL COATING OPERATIONS (District: All)

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- ATTACHMENT S

A ttachment A

– Resolution Amending Rule 67.4

– Meta l Container, Metal Closure and M etal

Coil Coating Operations of Regulation IV of the Rules and Regulations of the San Diego County Air Pollution Control District

Attachment B

– Comparative Analysis

Attachment C

– Incremental Cost Effectiveness Analysis

Attachment D

– Workshop Report

Atta chment E

– Change CopySUBJECT: NOTICED PUBLIC HEARING

– ADOPTION OF AMENDMENT TO RULE

67.4

– METAL CONTAINER, METAL CLOSURE

, AND METAL COIL COATING OPERATIONS (District: All)

AGENDA ITEM INFORMATION SHEET

REQUIRES FOUR VOTES : [] Yes [ X ] No

WRITTEN DISCLOSURE PER COUNTY CHARTER SECTION 1000.1 REQUIRED
[] Yes [ X ] No

PREVIOUS RELEVANT BOARD ACTIONS: May 15, 1996 (APCB #2), Amendment of Rule 67.4

– Metal Container, Metal Closure and Metal Coil Coating Operations.

BOARD POLICIES APPLICABLE:

N/A

BOARD POLICY STATEMENTS:

N/A

MANDATORY COMPLIANCE : N/A

ORACLE AWARD NUMBER(S) AND CONTRACT AND/OR REQUI SITION NUMBER(S): N/A

ORIGINATING DEPARTMENT: Air Pollution Control District

OTHER CONCURRENCE(S ): N/A

CONTACT PERSON(S):

ROBERT J. KARD

Name Name (858) 586

- 2700

Phone Phone (858) 586

- 2701

Fax Fax

O

- 176

Mail Station Mail Station
Robert.Kard@sdcounty.ca.gov

E

- mail E

- mail