UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Proposed Rulemaking

for the

California State Implementation Plan

Antelope Valley Air Quality Management District, Rule 1124, 

Aerospace Assembly and Component Manufacturing Operations

Prepared by: Vanessa Graham

Reviewed by: Andrew Steckel

August 2015
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RULE IDENTIFICATION

Agency: Antelope Valley Air Quality Management District (AVAQMD)

SIP-Approved Rule: South Coast Air Quality Management District (SCAQMD) Rule 

1124 - Aerospace Assembly and Component Manufacturing

Operations

Adopted – January 13, 1995

Submitted – February 10, 1995

Approved – May 6, 1996 

Superseded Submittal: AVAQMD Rule 1124 - Aerospace Assembly and Component 

Manufacturing Operations

Adopted - March 20, 2007

Submitted - May 17, 2010

Subject of this TSD: AVAQMD Rule 1124 - Aerospace Assembly and Component 

Manufacturing Operations

Adopted – August 20, 2013

Submitted – May 13, 2014

BACKGROUND – Prior to July 1, 1997, the area regulated by AVAQMD was contained within 

the SCAQMD boundaries. On July 1, 1997, the Antelope Valley Air Pollution Control District 

(AVAPCD) was created and took over responsibilities for the jurisdiction of the Los Angeles 

County portion of the Mojave Desert Air Basin. Rules and regulations of the SCAQMD were 

retained until the AVAPCD governing board adopted, rescinded or amended these rules. 

Therefore, SCAQMD Rule 1124, adopted by SCAQMD in January 1995 and approved by EPA 

in May 1996 became part of the AVAPCD SIP in July 1997. On January 1, 2002, the Antelope 

Valley Air Quality Management District (AVAQMD) was created to replace AVAPCD.

The current SIP-approved version of Rule 1124 in AVAQMD’s portion of the California SIP is 

the January 13, 1995 version of the rule. On March 20, 2007, AVAQMD adopted amendments to 

Rule 1124 and submitted them to EPA on May 17, 2010. This submittal was superseded by the 

May 13, 2014 submittal. Although we can only act on the most recent version of the submitted 

rule, we have reviewed previously submitted versions. 

 

RULE SUMMARY – Rule 1124 limits volatile organic compound (VOC) emissions from 

aerospace primers, coatings, adhesives, maskants and lubricants and from cleaning, stripping, 

storing and disposal of organic solvents and waste solvent materials associated with the use of 

aerospace coatings and adhesives. This rule also provides administrative requirements including 

those for recordkeeping and for the measurement of VOC emissions.

RULE EVALUATION CRITERIA – We primarily used the following criteria to evaluate the 

submitted rule:
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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 CAA §110(a)(2)(A) 

requirement for enforceability. 

2. Rule Stringency – AVAQMD regulates a non-attainment area that is classified as severe 

nonattainment for the 2008 eight-hour Ozone standard (see 40 CFR 81.305). CAA section 

182(b)(2), ozone nonattainment areas classified as moderate or above must implement

RACT for all VOC sources covered by a Control Techniques Guidelines (CTG) 

document and for all major coating categories of VOCs. EPA’s CTG titled Control of 

Volatile Organic Compound Emissions from Coating Operations at Aerospace

Manufacturing and Rework Operations (EPA-453/R-97-004, December 1997) (hereinafter 

“Aerospace CTG”) covers sources regulated under Rule 1124.

3. SIP Revisions – CAA section §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 

section 193 prohibits the modification of any SIP-approved control requirement in effect 

before November 15, 1990, in a nonattainment area.

In applying these criteria to the submitted rule, we referred to the following guidance and policy 

documents:

• State Implementation Plans; General Preamble for the Implementation of Title I of the 

Clean Air Act Amendments of 1990, 57 FR 13498 (April 16, 1992); 57 FR 18070 (April 

28, 1992).

• Final Rule To Implement the 8-Hour Ozone NAAQS – Phase 2, 70 FR 71612 (Nov. 25, 

2005).

• CTG-EPA-453/R-97-004, Control of Volatile Organic Compound Emissions from 

Coating Operations at Aerospace Manufacturing and Rework Operations, December 

1997.

• Maximum Achievable Control Technology (MACT) Standard for Aerospace 

Manufacturing and Rework Facilities (40 CFR 63 Subpart GG, commencing with 

§63.741).

EPA EVALUATION

A summary of our evaluation of the three criteria as follows:

Enforceability – The recordkeeping requirements for coatings and control system parameters, 

test methods and other requirements generally ensure that the submitted rule can be enforced. 

Stringency – Presumptive RACT requirements for the aerospace industry is generally defined by 

the Aerospace CTG. The Aerospace CTG applies to sources in moderate, serious or severe ozone 

nonattainment areas that have the potential to emit greater than or equal to 25 tons per year of 
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VOC’s.1 Our review of CARB’s emissions inventory web site indicates that AVAQMD has no 

aerospace facilities with emissions that exceed the CTG’s applicability threshold for aerospace 

coating operations. Therefore, we conclude that AVAQMD has no sources subject to the 

Aerospace CTG. Nonetheless, we evaluated AVAQMD’s August 20, 2013 amendments against

requirements outlined the Aerospace CTG as well as the rules of other air districts. 

Rule 1124 VOC limits are generally as or more stringent as those specified in Mojave Desert Air 

Quality Management District (MDAQMD) Rule 1118 Aerospace Vehicle Parts and Products 

Coating Operations, San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD)

Rule 4605 Aerospace Assembly and Component Coating Operations and SCAQMD Rule 1124 

Aerospace Assembly and Component Manufacturing Operations. Relatively minor exceptions 

are noted in Additional Recommendations below. All VOC limits were also evaluated against 

the relevant MACT and the proposed National Emission Standards for Aerospace Manufacturing 

and Rework Facilities Risk and Technology, and were generally as or more stringent.

SIP Revisions – The 2007 amendments improve on the 1995 version of the SIP approved rule by 

removing unused definitions, updating several definitions for consistency with the CTG and

adjusting some VOC limits. AVAQMD’s staff report states that the proposed 2007 amendments 

were designed such that there was no overall emissions increase from Rule 1124. EPA did not 

act on the 2007 amendments and in 2013, the District further amended Rule 1124.

The primary purpose of the August 20, 2013 rule amendments was to incorporate several 

specialty coating categories from the Aerospace CTG that were omitted from the March 20, 2007 

amendments. In analyzing the economic impact of its amendments, the District’s staff report 

states that primers, adhesives, sealants, maskants, lubricants and “other” coatings should be 

reasonably available in commerce and should not cause additional usage of the products 

themselves, or of cleaning solvents.2

We therefore propose to determine that our approval of the submittal would comply with CAA 

sections 110(l) and 193 because the submitted SIP rule: (1) will insure equivalent or greater 

emission reductions of VOCs, and (2) will not interfere with the on-going process for ensuring 

that requirements for RFP and attainment of the NAAQS are met.

RULE DEFICIENCIES – We have identified no deficiencies in submitted Rule 1124 sufficient 

for EPA to propose less than full approval. 

 

1 Control of Volatile Organic Compound Emissions from Coating Operations at Aerospace 

Manufacturing and Rework Operations (EPA-453/R-97-004, December 1997)page 5-2, section 5.2 

http://www.epa.gov/groundlevelozone/SIPToolkit/ctg_act/199712_voc_epa453_r-97-004_aerospace_rework.pdf

2 Final Staff Report - Amendment of Rule 1124 – Aerospace Assembly and Component 

Manufacturing Operations, Adopted on August 20, 2013, page 8.
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ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION – The 

following recommended lower limits are not currently the basis for rule disapproval, but we 

encourage AVAQMD to consider them the next time the rule is amended. 

1. Lower Adhesion Promoter Coating limit from 850 g/l, consistent with, e.g., SCAQMD

Rule 1124 limit of 250 g/l.

2. Lower Chemical Agent Resistant Coating limit from 550 g/l, consistent with, e.g., 

MDAQMD Rule 1118 limit of 500g/l.

3. Lower Flight-Test Coating (All other) limit from 840 g/l, consistent with, e.g., SJVAPCD

Rule 4605 limit of 600 g/l.

4. Lower Non-Autoclavable limit from 850 g/l, consistent with, e.g., MDAQMD Rule 1118 

limit of 700 g/l.

5. Add a 600 g/l limit for Sprayable Sealant consistent with the CTG

6. Break-out and capitalize “Topcoat” similar to “PRIMERS” and “ADHESIVES”

7. Primers and Fuel-Tank Coating have a “general” limit, Topcoat and Sealants have an 

“other” limit, Flight-Test Coating has an “all other” limit, and Adhesives and Maskants

have no similar catch-all limit. We recommend using consistent terminology throughout 

the table of limits.

EPA ACTION – The submitted Rule 1124 adequately addresses the relevant CAA criteria for 

the reasons discussed above. As a result, EPA staff recommends a full approval of Rule 1124

pursuant to CAA section 110(k)(3). 

ADDITIONAL REFERENCES

• SJVUAPCD Rule 4605 - Aerospace Assembly and Component Coating Operations, 

adopted June 16, 2011; 76 FR 70886 approved November 16, 2011.

• AVAQMD Rule 1124 - Aerospace Assembly and Component Manufacturing Operations, 

amended March 20, 2007.

• MDAQMD Rule 1118 - Aerospace Vehicle Parts and Products Coating Operations 

adopted October 28, 1996; 63 FR 43884 approved August 17, 1998.

• SCAQMD Rule 1124 – Aerospace Assembly and Component Manufacturing Operations 

adopted September 21, 2001 approved August 13, 2002 67 FR 52611

• USEPA Proposed Rule for National Emission Standards for Aerospace Manufacturing 

and Rework Facilities Risk and Technology Review; 80 FR 8391 proposed February 17, 

2015.