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									United States Environmental Protection Agency
                 Air Division




        Technical Support Document

                  For The

Ventura County Air Pollution Control District

     Rule 74.30, Wood Products Coatings




              Cynthia G. Allen
                 May 2008
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AGENCY:               Ventura County Air Pollution Control District

Submittal Date:       October 5, 2006
Adoption Date:        June 27, 2006
Completeness Date:    October 24, 2006

Submitted Rule:       Rule 74.30, Wood Products Coatings

Applicable SIP:       Submitted on April 26, 2005 (adopted on November 11, 2003) and
                      approved on October 25, 2005 (70 FR 61561).


Rule Summary:

Ventura Rule 74.30 applies to commercial operations specifying or using coatings on wood
products. Emissions from these operations are reduced by limiting the Reactive Organic
Compound (ROC) content of coatings and cleaning materials and requiring certain application
methods.

Changes to Rule 74.30

The ROC content limits for surface preparation and cleanup are reduced to those included in the
November 7, 2003, revision to South Coast Air Quality Management District Rule 1171, Solvent
Cleaning Operations. These revisions were adopted to comply with the state requirement for
“all feasible measures,” as specified in Health and Safety Code Section 40914(b)(2). They
generally limit ROC content for surface preparation and cleanup material to 25 grams per liter
(g/1) of material less water and exempt compounds, or 0.21 pounds per gallon. The effective
date of the revisions is 90 days from the date of adoption by their Board so as to allow affected
facilities sufficient time to comply with the rule requirements.

Other revisions:

      Obsolete emission limits in Subsection B.1 are being deleted;

      Subsection B.4.h became obsolete on July 1, 2000 and is being deleted;

      The exemption in Subsection C.3 has been revised for clarification. The coating of
       wooden cabinets shutters, fences and handrails are done in a shop or manufacturing
       facility, where Rule 74.30 applies. The revision clarifies that, if equipment of this type is
       coated in the field (“at the site of permanent installation”), Rule 74.30 does not apply. In
       many of these cases, Rule 74.2, Architectural Coatings, will apply.
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      The definition of High Volume-Low Pressure (HVLP) spray equipment is being updated
       to be consistent with other District rules (Subsection G.16). Guidance for the
       identification of HVLP equipment is being added in new Subsection E.6

      Capture and control efficiency test methods are being updated in Subsection E.5.

      Other revisions include minor wording revisions to clarify Subsection B.1 and B.2.

EPA Evaluation

        Generally, SIP rules must be enforceable (see section 110(a) of the Act), must require
Reasonably Available Control Technology (RACT) for each category of sources covered by a
Control Techniques Guidelines (CTG) document as well as each major source in nonattainment
areas (see section 182(a)(2)), and must not relax existing requirements (see sections 110(l) and
193). The Ventura County APCD regulates an ozone nonattainment area (see 40 CFR part 81),
so Rule 74.30 must fulfill RACT.

         Specifically, in nonattainment areas, the CAA requires SIPs to “provide for the
implementation of all reasonably available control measures as expeditiously as possible,”
including emission reductions achievable by requiring “reasonably available control technology”
[RACT], and to provide for attainment of the national ambient air quality standards. CAA §
172(c)(1). SIPs for moderate and severe ozone nonattainment areas (among others) are required
to impose RACT on all source categories for which EPA has issued a relevant CTG and on all
major sources of VOCs and NOx. CAA §182(a)(2)(A), (b)(2), (c). The submitted rule is as
stringent as CARB’s RACT/BARCT guidance and other California District rules for this
category and is more stringent than EPA’s CTG. As a result, we have determined that this rule
fulfills RACT requirements. In addition, the rule strengthens requirements in the SIP and so
complies with §110(l) and §193.

        Documents used to evaluate the rule include the following: Portions of the proposed
post-1987 ozone and carbon monoxide policy that concern Reasonably Available Control
Technology, 52 FR 45044, November 24, 1987; EPA’s Issues Relating to VOC Regulation
Cutpoints, Deficiencies, and Deviations ( May 25, 1988, the “Bluebook”); EPA Region IX‘s
Guidance Document for Correcting Common VOC & Other Rule Deficiencies (August 21, 2001,
the “Little Bluebook”); EPA’s Control Technique Guideline - Control of Volatile Organic
Emissions from Wood Furniture Manufacturing Operations (April 1996);

Net Effect on Emissions

        Ventura County anticipates an ROC emission reduction of 0.83 tons per year among
existing sources.
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RECOMMENDED ACTION

       I recommend full approval of submitted Rule 74.30 under Section 110(k) of the Clean
Air Act.


ATTACHMENTS

1.     VCAPCD Rule 74.30, Wood Products Coatings, adopted June 27, 2006 and submitted
       October 5, 2006.

2.     VCAPCD Rule 74.30, Wood Products Coatings, adopted November 11, 2003 and SIP
       approved October 25, 2005.

3.     U.S. EPA, Control Technique Guideline (CTG), “Control of Volatile Organic
       Emissions from Wood Furniture Manufacturing Operations” (EPA-453/R-96-007, April
       1996) (cover only).

4.     Requirements for Preparation, Adoption, and Submittal of Implementation Plans, U.S.
       EPA, 40 CFR part 51.

5.     U.S. EPA, Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,
       May 25, 1988 (the “Blue Book”) (cover only).
.
6.     U.S. EPA, Guidance Document for Correcting Common VOC & Other Rule Deficiencies,
       (August 21, 2001) (cover only).

7.     U.S. EPA, Requirements for Preparation, Adoption, and Submittal of Implementation
       Plans, 40 CFR Part 51 (cover only).

								
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