UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA ’ s Direct Final Rulemaking

for the California State Implementation Plan

Eastern Kern Air Pollution Control District
Rule 410.9, Wood Products Surface Coating Operations

P re pared by: Arnold Lazarus Reviewed by: Andrew Steckel

April 2016Agency: Eastern Kern Air Pollution Control District (EK A PC D)

SIP Approved Rule: No other versions of EK A PC D Rule 4 10.9 have been SIP approved.

Subject of this TSD: Rule 410.9

– Wood Products Surface Coating Operations Adopted

– March 13, 2014

Submitted

– July 25

, 2014

BACKGROUND

– Rule 410.9 is a new rule designed to reduce volatile organic compound (VOC) emissions from wood product coatings, and from the cleaning, storage, and disposal of organic solvents and waste solvent materials associated with the use of wood product coatings. Rule 410.9 also provide s administrative requirements for recording an d measuring VOC emissions. EK A PC D is in marginal non

- attainment for the 8

- hour ozone national ambient air quality standard (NAAQS, see 40 CFR 81). According to the District’s Staff Report

associated with this rule

, EKAPCD Rule 410.9 is modelled after San J oaquin Valley Unified Air Pollution Control District (SJV U APCD) Rule 4 606

, “Wood

Products and Flat Wood Panel Product Coating Operations” which has been approved into the State Implementation Plan (SIP) most recently in 2009

. 1 The District Staff Report also explain s that the staff reviewed other SIP approved rules

– Antelope Valley Air Quality Management District (AVAQMD) Rule 1136

, and

South Coast Air Quality Management District ( SC AQMD) Rule 1136

— to maintain consistency. 2

RULE SUMMARY

- EKAPCD Rule 4 10.9 limit s the amount of VOC contained in various wood product coatings. It also controls VOC emissions by establishing operational requirements on wood products coatings as well as solvent cleaning operations and storage and disposal of solvents and was te solvent materials associated with such coating. The rule also describes related administrative requirements for recording and measuring emissions.

Rule 410.9 is organized in to the following sections:

1. Purpose

2. Applicability

3. Definitions

4. Exemptions

5. Requirement

6 Administrative Requirements

7

. Test Methods

1 EKAPCD Rule 410.9 , Wood Products Surface Coating Operations Final Staff Report March 13,

2014. p2

2 Ibid.

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−8

. Compliance Schedule

EVALUATION CRITERIA

- 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) and the Little Bluebook ( Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate compliance with the federal Clean Air Act ( CAA ) § 110(a)(2)(A) requirement for enforceability.

2. Stringency

- SIPs must require Reasonably Available Control Technology (RACT) for each category of sources covered by a Control Technique Guideline (CTG) document as well as each major source in ozo ne nonattainment areas (see CAA §§ 182(b)(2) and 182(f)). EPA ’ s Control Technique Guideline (CTG) titled, “ Control of Volatile Organic Compound

Emission from Wood Furniture Manufacturing Operations ” (EPA

- 453/R

- 96

- 007

, April 1996)

, EPA ’ s CTG titled, “ Control Technique s Guideline s for

FWPC ” (EPA

- 453/R

- 06

- 004, September 2006), SJV UA PCD Rule 4606

,

“ Wood Products and Flat Wood Paneling Products Coating Operations,”

and SCAQMD Rule 1136

, “Wood Products Coating ,” were used to help evaluate the RACT requirements of CAA § § 182(b)(2) and § 182(f).

3. SIP Relaxation

- CAA § 110(l) prohibits EPA from approving any SIP revision that would interfere with any applicable requirement concerning

attainment and reasonable fur ther 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.

EPA EVALUATION

1. Enforceability

- The rule requirements and applicability are clear, and the monitoring, recordkeeping, reporting and other provisions sufficiently ensure that affected sources and regulators can evaluate and determine compliance with Rule 410.9 consistentl y.

2. Stringency

- Regarding wood furniture manufacturing, w e have determined

that the submitted Rule 410.9 satisfies RACT because Rule 410.9 requirements are at least as stringent as the 1996 CTG and more stringent

than SIP

- approved SJV U APCD Rule 4606 because it has no exemptions for refinishing coatings and some of the VOC limits are lower than those of

Rule 4606

. Regarding flat wood paneling coating (FWPC), some limits are

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−less stringent that those in EPA’s 2006 CTG . However, District staff 3

confirm that there are no FWPC operations in EKAPCD, and therefore

RACT is not needed for FWPC

. A review of industries doing wood products coating in the EK A PC D using the California Air Resources Board ’s (CARB) Facility Search Tool by Standard Industrial C lassification (SIC) codes did not reveal any sources of VOC emission due to the coating of wood products

. 3. SIP Relaxation

- We propose to determine that our approv al of the submittal would comply with CAA §§ 110(l) and 193 because (1) the proposed SIP

revision would not interfere with the on

- going process for ensuring that requirements for RFP and attainment of the NAAQS are met, and (2) the

emission limits in the submitted rule will ensure equivalent or great er emission reductions of VOCs

.

RULE DEFICIENCIES

– We have identified no deficiencies with Rule 410.9 for EPA to propose less than full approval.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION

– EPA

has the following recommendations if Rule 410.9 is amended.

1. Consistent with the 1996 CTG, we recommend the addition of an operator training program for work practices.

2. EPA recommends that Rule 410.9 establish VOC content limits for FWPC

consistent with EPA ’ s 2006 CTG and SJVUAPCD Rule 4606

, “ Table 3

VOC Content Limits for Flat Wood Paneling Products Coating Operation

. ”

EPA ACTION

- The rule fulfils the relevant CAA § 110 and part D requirements. Therefore, EPA

staff recommends a full approval of Rule 410.9.

3 Verified by a telephone conversation between Arnold Lazarus (EPA) and Cherita Young ( EKAPCD) on 10/30/14.

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−REFERENCES

1. EKAPCD Rule 410.9

, “ Wood Products Surface Coating Operations ,” adopted March 13, 2014.

2. EKAPCD Rule 410.9

, “ Wood Products Surface Coating Operations ,” Final Staff Report March 13, 2014.

3. SJV U APCD Rule 4606

, “ Wood Products and Flat Wood Panelling Products Coating Operations ,” EPA Approved

- October 15

, 2009 (74 FR 52894)

. 4. Control Techniques Guidelines “ Control of Volatile Organic Compo und

Emission s from Wood Furniture Manufacturing Operations ” (EPA

- 453/R

96

- 007

, April 1996 )

. 5. Control Technique s Guideline s “ Control Technique s Guideline s for Flat Wood Paneling Coatings” (EPA

- 453/R

- 06

- 004, September 2006)

. 6

. “ Issues Relating to VOC Regulation Cutpoints, Deficiencies, and
Deviations, ” (a.k.a., Bl uebook) EPA OAQPS, May 25, 1988.

7

. “ Guidance Document for Correcting Common VOC & Other Rule Deficiencies, ” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001 ( http://www.epa.gov/region09/air/sips/littlebluebook2001.pdf ).

8

. “ Determinations of Attainment b y t he Attainment Date, Extensions of the Attainment Date, and Reclassification of Several Areas Classified as Marginal for the 2008 Ozone National Ambient Air Quality Standards ” 80 FR 51992, ” August 27, 2015.

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