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

, Aerospac e Assembly and Component Manufacturing Operations

Prepared by: Vanessa Graham Reviewed by: Andrew Steckel

August 20151 RULE IDENTIFICATION

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

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Superseded Submittal : AVAQM D Rule 1124

- Aerospace Assembly an d Component Manufacturing Operations Adopted

- March 20, 2007

Submitted

- May 17, 2010

Subject of this TSD: AVAQM D Rule 1124

- Aerospace Assembly and Component Manufacturing Operations Adopted

– August 20, 2013

Submitted

– May 13, 2014

BACKGROUND

– Pri or 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

Co unty 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 Rules and regulations of the SCAQMD were retained until the AVAPCD governing board adopted, rescinded or amended these rules.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 SI P 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 This submittal was superseded by the May 13, 2014 submittal.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 v ersion 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,

s toring 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:2 1. Enforceability

– The Bluebook ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations , EPA, May 25, 1988) and the Little Bluebook ( G uidance 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 ar ea that i s classified as s evere 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 Techniq ues 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) (herein after “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 r ule, 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 Co ntrol 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 requirement s for coatings and control system parameters, test methods and other requirements generally ensure that the submitted rule can be enforced.

Stringency

– Presumptive RACT requiremen ts for the aerospace industry is generally defined by

the A erospace CTG. The A erospace 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 of3 VOC’s. 1 Our review of CARB’s emissions inventory web site indicates that AVAQMD ha s 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 am endments against requirements outlined the A erospace CTG as well as the rules of other air districts.

Rule 1124 VOC l imits are generally as or more stringent as those specified in Mojave Desert Air Quality Management District (MDAQMD) Rule 1118 Aerospac e Vehicle Parts and Products Coating Operations, San Joaquin Valley Unified Air Pollution Control District (SJVU APCD ) Rule 4605 Aerospace Assembly and Component Coating Operations and SCAQMD Rule 1124 Aerospace Assembly and Component Manufacturing Operatio ns

. Relatively minor e xceptions

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 amendmen ts 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

amendment s

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

st ates 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

emi ssion reductions of VOCs, and (2 ) will not interfere with the on

- going process for ensuring that requireme nts 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 8.4 ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION

– The following r ecommend ed lower limits are not currently the basis for rule di sapproval, 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 500 g/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

- Autocla vable limit from 850 g/l , consistent with, e.g., MDAQMD Rule 1118

limit of 700 g/l

. 5. A d d a 600 g/l limit for Spray able Sealant consistent with the CTG

6. Break

- out and capitalize “Topcoat” similar to “PRIMERS ” and “ADHESIVES”

7. Primers and Fuel

- T ank Coating have a “general” l imit, Topcoat and Sealants have an “other” limit, Flight

- Test Coating has an “all other” limit, and Adhesives and Maskant s 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).

A DDITIONAL REFERENCES

• SJVUAPCD Rule 4 605

- Aeros pace 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 Product s 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

.