### United States Environmental Protection Agency, Region IX

Air Division

Technical Support Document

For

EPA’s Notice of Proposed Rulemaking

For the

California State Implementation Plan

South Coast Air Quality Management District

Rule 1186, PM 10 

### Emissions f rom Paved and Unpaved Roads and Livestock

Operations

Christine Vineyard

August 2, 2011Agency: South Coast Air Quality Management District

Rule 1186: PM 10 Emissions from Paved and Unpaved Roads, and Livestock Operations

SCAQMD Adoption: July 11, 2008

California Air Resources Board (CARB) Submittal: May 17, 2010

EPA Completeness Finding: April 20, 2009

Rule Summary

Rule 1186 controls emissions of particulate matter (PM) from paved and unpaved public roads,

and livestock operations. Under existi ng Rule 1186, street sweeper manufacturers are required

to certify their equipment pick up efficiency is at least 80 percent. It has been more than five

years since any certification testing has been conducted and there was a need to ensure that

the overa ll performance of the sweepers can still demonstrated in the event the manufacturer

changes parts suppliers and/or modifies any sweeper specification from that on the originally

configured models. The amended rule requires submission of data to demonstrat e that the

sweeper performance has not been affected by these changes and also establishes a process

that aftermarket parts suppliers may quality to sell replacement parts while maintaining the

original equipment certification.

Changes from the SIP Rule

T he following changes were made to SCAQMD Rule 1186:

(d) Requirements

(d)(3)

– clarified that the use of replacement parts that have been determined by the

Executive Officer to be substantially similar to the original equipment

manufacturer (OEM) p art is not a violation of this requirement.

(e) Street Sweeper Testing and Certification Procedures

(e)(1)(A)(i)

– adds requirement for manufacturers to provide a complete description of

the equipment’s dust collection system when requesting certificat ion of new

equipment.

(f) Street Sweeper Performance Characteristics was added to the rule. This new section

requires:

1. Manufacturers of street sweepers previously certified under the provisions of this

rule are to submit a complete description of the sweepers dust collection and

suppression systems as configured during certification testing

.
2. A List of t he minimum information on the description of dust collection and

suppression systems that must be provided to the SCAQMD.3. Manufac turers to notify the SCAQMD for approval prior to substitution of spare parts are in

order for the sweeper to maintain its certification status.

4. S treet sweeper supp liers selling replacement parts to demonstrate the replacement part is

similar to the original equipment manufacturer part.

5. Entities submitting a plan under paragraphs (f)(3) or (f)(4) are subject to the plan submittal

requirements and applicable fee under Rule 306.

6. Any plan submitted under (f)(3) and (f)(4) will be approved, condi tionally approved, or

disapproved in writing within 120 days.

Rule E valuation

a. Rule Stringency

– SCAQMD is a serious PM10 nonattainment area and subject to CAA § 189

PM requirements regard in g Reasonably and Best Available Control Measures (RACM and

BACM)

. The SIP

- approved version of this rule was determined to meet the BACM provisions

.
T he requirement s to insure continued compliance added in this revision further strengthens

the SIP.

b. Enforceability

– CAA § 110(a)(2)(A) states that regulation s submitted to EPA for SIP approval

must be clear and legally enforceable. The requirements for submission of data on dust

collections and suppression systems and certification are clear and enforceable.

c. Anti

- Backsliding

– CAA § 110(I) and § 193 res trict SIP revisions from relaxing existing

requirements. The submitted rule 1186 strengthens the SIP rule by requiring that the overall

performance of the street sweepers can still be demonstrated in the event the manufacturer

changes parts suppliers and/ or modifies any sweeper specification from that on the originally

configured model. This insure s continued effective PM emission controls using certified street

sweepers.

Recommendation

The submitted rule strengthens the SIP and fulfills the requiremen ts of enforc eability, SIP

relaxations, and RACM/BACM. Therefore, submitted Rule 1186 should be given full approval.

Attachments

1. SCAQMD Rule 1186

– PM 10 Emissions from Paved and Unpaved Roads, and Livestock

Operations, amended July 11, 2008.

2. SIP

- Approved SCAQMD Rule 1186

- PM 10 Emissions from Paved and Unpaved Roads, and

Livestock Operations, adopted 2, 2004.3. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” USEPA, May 28,

1988 (cover only).

4. Staff Report for P roposed Amendments to SCAQMD Rule 1186, PM 10 Emissions from Paved

and Unpaved Roads, and Livestock Operations, July 2008.