UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA ’ s Rulemaking

for the California State Implementation Plan

Repeal/Rescission of San Diego County Air Pollution Control District Rule 67.0 Architectural Coatings

Prepared by: Arnold Lazarus Reviewed by: Andrew Steckel

July 20161 RULE IDENTIFICATION

-

Agency San Diego Air Pollution Control District (SD C APCD)

SIP Approved

Rule Rule 67.0

- Architectural Coatings Adopted

- December 12, 2001

Submitted

- March 7, 2003 EPA Approved

– June 20

, 2013 (78 FR 37130)

Subject of this

TSD Rule 67.0

- Architectural Coatings Repealed / Rescinded

- June 24 , 201 5

Submitted

- November 13, 2015

Effective

- January 1, 2016 Completeness Finding Determination of Completeness L etter : January 1 9 , 2016

BACKGROUND

– SD C APCD regulates air quality in San Diego County , which is

classified as a “ moderate” nonattainment area for the 2008 8

- hour ozone National

Ambie nt Air Quality Standard (NAAQS). 1 The Clean Air Act (CAA) requires that for

areas classified as m oderate nonattainment or greater , the State must submit provisions to the State Implementation Plan (SIP) to require implementation of reasonably available control technology (RACT) ( see section s 182( b )(2)

. There is

no Control Techniques Guidance (CTG) for a rchitectural c oatings and

architectural co ating sources are considered to be “area sources

, ” not major

sources, and therefore RACT requirements do not apply to th is rule.

According to Robert J. Kard , air pollution control officer for SD C APCD, “If adopted, Rule 67.0.1 will replace existing Rule 67.0, which was last updated in 2001. Since 2001, coating manufacturers have developed new architectural coatings that contain less VOC while meeting appearance, durability and other performance needs. P roposed Rule 67.0.1 reflects the development of new, lower VOC content coatings and is based on a Suggested Control Measure (SCM) developed in 2007 by the California Air Resources Board that is designed to further reduce VOC emissions and encourage consist ency in the regulation of architectural coatings across the State. Several air districts throughout California have already adopted the requirements found in the SCM and as a result complying coatings are now readily available. ” 2

RULE SUMMARY

- SD C APCD Rule 67.0 controls volatile organic compound (VOC) emissions from architectural coatings by establishing VOC limits on manufacture, distribution and use of various coatings. The rule has been

amended several times since its initial adoption

. Rule 67.0 was repealed in

SD C APCD effective January 1, 2016

, and Rule 67.0.1 became effective on that

same date

.

1 40 CFR 81.305

. 2 L etter from Robert J. Kard, Air Pollution Control Officer of the SD C APCD to the San Diego Air
Pollution Control Board, June 24, 2015

, p1.2 PURPOSE OF RULE REPEAL

– SD C APCD repealed Rule 67.0 because it was replaced by the more stringent Rule 67.0.1 “Architectural Coatings

. ” Rule 67.0.1

was adopted on June 24, 2015 and became effective on January 1, 2016.

SD C APCD estimated a reduction of VOC emission from AC in San Diego County from replacing Rule 67.0 with Rule 67.0.1 will be approximately 840 tons per year.

EPA EVALUATION

– EPA s taff hav e reviewed the SD C APCD’s supporting documents as well as the replacement Rule 67.0.1 and concur with the SD C APCD

t hat repeal Rule 67.0 of complies w ith relevant CAA requirements, including sections 110(l) and 193, because Rule 67.0.1 replaces and improves Rule 67.0

, and will strengthen the SIP.

EPA ACTION

– EPA s taff recommends approval of CARB’s request to rescind

Rule 67.0 from the SIP.

REFERENCES

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

2. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21,

2001.

3. SD C APCD Rule 67.0 “Architectural Coatings” adopted on December

12, 2001, submitted on March 7, 2003 and approved into the SIP on
June 20, 2013 (78 FR 37130).

4. “Suggested Control Measure for Architectural Coatings,” CARB,

October 2007.

5. L etter from Robert J. Kard, Air Pollution Control Officer of the

SD C APCD to the San Diego County Air Pollution Control Board,
June 24, 2015.