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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 2 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. 3 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. 4 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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