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 1 09

, Recordkeeping for Volatile Organic Compound Emissions

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

December

, 201 12

Agency: Antelope Valley Air Quality Management District ( AV AQM D)

SIP Approved Rule : Rule 1 09

– Recordkeeping for Volatile Organic Compound Emissions

A dopt ed

– 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 1 09

– Recordkeeping for Volatile Organic Compound Emissions

Amended

– April 20

, 20 10

Submitted

– July 20 , 201 0

RULE SUMMARY

- AV AQM D Rule 1 09

, 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 “Fa cility” and “South Coast Air Quality Management District” to definitions in section (B)

. 4. Changed section (C) heading from “Requirements” to “Da ily 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 exe mpt 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 calculati ng 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.3

7. Added Section (E), exempti ng 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 Regul ation 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

- 0 8

- 00 5 ,September 2006 ) and other district s’ analogous rules for this category were used as the basis for evaluating recordkeeping stringency including: South Coast Air Quality Management Dist r ict (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 ( MD AQM D ) Rule 442

, Usage of Solvent

s a mend ed February 27

, 20 0 6

.

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.

Enforceability

- The recordkeeping requirements and test methods generally

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

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

. We do not believe th is alternative recordkeeping method adds clarity but

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

.

Stringency

– Rule 1 09 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 long er than one week

, using averaging to obtain a daily usage, this is not a significant4

relaxation

, but rather

, accommodates industry that us e small amounts of VOC

containing solvents, coatings or adhesives.

EPA ACTION

- EPA staff recommends a full approval of Rule 1 09 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 subsec tion s (C) (1) (d)

and (C) (1) (f)

.

ADDITIONAL REFERENCES

-

1. AV AQMD Rule 1 09

, Recordkeeping for VOC Emissions , as submitted on July 20, 2010

.

2. AV AQMD Rule 1 09

, Recordkeeping for VOC Emissions

, a mend ed May 17

, 2005

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

3. S C AQMD 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

- 0 8

- 00 5 ,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 2 5, 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