UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

For

EPA’s Direct Final Rulemaking

For the

California State Implementation Plan

Antelope Valley Air Quality Management District, 

Rule 109, Recordkeeping for Volatile Organic Compound Emissions

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

December, 2011
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Agency: Antelope Valley Air Quality Management District

(AVAQMD)

SIP Approved Rule: Rule 109 – Recordkeeping for Volatile Organic 

Compound Emissions

Adopted – May 5, 1989

Readopted by Statute – July 1, 1997

Readopted by Statute - January 1, 2002

Amended – May 17, 2005

Submitted – March 10, 2006

EPA Approved – September 2, 2008 (73 FR 51226)

Subject of this TSD: Rule 109 – Recordkeeping for Volatile Organic 

Compound Emissions

Amended – April 20, 2010

Submitted – July 20, 2010

RULE SUMMARY - AVAQMD Rule 109, Recordkeeping for Volatile Organic 

Compound Emissions, was revised as summarized below. Most of these 

revisions are minor procedural changes. The most primary change is 

summarized in #5 below and allows alternative recordkeeping to address certain 

industry practices. 

1. Added Subsection (A) (1), Purpose.

2. Added rules 442, Usage of Solvents, 1102, Petroleum Solvent Dry 

Cleaners, 1130.1, Screen Printing Operations, 1162, Polyester Resin 

Operations and 1171, Solvent Cleaning Operations to the list of rules to 

which rule 109 applies in subsection (A)(2)(b).

3. Added “Facility” and “South Coast Air Quality Management District” to 

definitions in section (B).

4. Changed section (C) heading from “Requirements” to “Daily 

Recordkeeping Requirements. 

5. Changed subsection (C) (d), as follows:

“ ...The records shall include, but not be limited to, the following: 

(d) the amount and type of adhesive, coating (including catalyst 

and reducer), solvent, and/or graphic arts material used in each 

permit unit or dispensing station (when permitted equipment is 

not involved) including exempt compounds (use of one pint per 

week or less may be recorded in an alternative manner);”

(containers of one pint or less may be recorded in an 

alternative manner including but not limited to assuming 

full consumption on day of first use and/or calculating an 

average daily consumption by determining the number of 

operating days a single pint container of material was in 

active use in the facility;”

6. Added to testing methods, subsections (D) (4) which allows for the use of 

applicable test methods approved by USEPA, CARB and the APCO and 

(D) (5) which states the multiple test caveat.
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7. Added Section (E), exempting materials containing less than 20 

grams/liter VOC.

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 

Bluebook (Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies, EPA Region 9, August 21, 2001), and State Implementation 

Plans, General Preamble for the Implementation 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. Stringency –The EPA’s CTG titled Miscellaneous Industrial Adhesives (EPA 

453/R-08-005,September 2006) and other districts’ analogous rules for this 

category were used as the basis for evaluating recordkeeping stringency

including: South Coast Air Quality Management District (SCAQMD) Rule 

109, Recordkeeping for Volatile Organic Compound Emissions, amended 

May 2, 2003, Ventura County Air Pollution Control District (VCAPCD) Rule 

74.12 Surface Coating of Metal Parts and Products amended April 8, 2008, 

Mojave Desert Air Quality Management District (MDAQMD) Rule 442,

Usage of Solvents amended February 27, 2006.

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 modification of 

any SIP-approved control requirement in effect before November 15, 1990, 

in a nonattainment area.

Enforceability - The recordkeeping requirements and test methods generally 

ensure that the submitted rule can be enforced. However, the exempt amount of 

one pint per week was changed to containers of one pint or less over an undefined 

period. We do not believe this alternative recordkeeping method adds clarity but 

neither do we feel that it significantly detracts from the overall enforceability. 

Stringency – Rule 109 establishes recordkeeping requirements to support in other 

rules. It does not, in itself, control emissions, and, therefore, we are not evaluating 

it for RACT or other levels of control. However, the recordkeeping requirements of 

Rule 109 are generally consistent with analogous requirements in other 

neighboring districts and with relevant national guidance.

SIP Relaxation – The District has not included any provision in the proposed rule 

that significantly relaxes emission requirements. While the recordkeeping 

requirement for containers of one pint or smaller now can span a time frame longer 

than one week, using averaging to obtain a daily usage, this is not a significant 
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relaxation, but rather, accommodates industry that use small amounts of VOCcontaining solvents, coatings or adhesives.

EPA ACTION - EPA staff recommends a full approval of Rule 109 pursuant to 

CAA §110(k) (4) and §301(a). 

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION –

The District should edit subsection (C) (1) (d) to add missing parenthesis. To 

improve enforceability, consider adding a statement that the District needs to 

approve any “alternative manners of recording” allowed in subsections (C) (1) (d) 

and (C) (1) (f). 

ADDITIONAL REFERENCES -

1. AVAQMD Rule 109, Recordkeeping for VOC Emissions, as submitted on 

July 20, 2010.

2. AVAQMD Rule 109, Recordkeeping for VOC Emissions, amended May 17, 

2005.

http://www.avaqmd.ca.gov/Modules/ShowDocument.aspx?documentid=906

3. SCAQMD Rule 109, Recordkeeping for VOC Emissions, amended May 2, 

2003, 2008

http://www.aqmd.gov/rules/reg/reg01/r109.pdf

4. VCAPCD Rule 74.12, Surface Coating of Metal Parts and Products,

amended April 8, 2008

http://www.vcapcd.org/Rulebook/Reg4/RULE%2074.12.pdf

5. MDAQMD Rule 442, Usage of Solvents, amended February 27, 2006

http://www.mdaqmd.ca.gov/Modules/ShowDocument.aspx?documentid=296

4. “Control Techniques Guidelines for Miscellaneous Industrial Adhesives,”

EPA 453/R-08-005,September 2006

http://www.epa.gov/ttnnaaqs/ozone/ctg_act/200809_voc_epa453_r-08-

005_miscellaneous_industrial_adhesives.pdf

5. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and 

Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf

6. “Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001.

http://www.epa.gov/region9/air/sips/littlebluebook2001.pdf