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PROPOSAL:

Receive Monitoring, Recordkeeping, and Reporting Task Force Progress Report and Approve Recommendations to Streamline VOC Recordkeeping.

SYNOPSIS:

The Monitoring, Recordkeeping, and Reporting (MRR) Task Force has developed a consensus proposal to streamline VOC recordkeeping for numerous facilities within AQMD. It is recommended that the Board direct the staff to develop rule amendments and implement other parts of the proposal, as detailed in the Task Force Progress Report, to reduce or eliminate unnecessary recordkeeping burden while maintaining the enforceability of AQMD�s VOC control rules and regulations.

COMMITTEE:

Not Applicable

RECOMMENDED ACTION:

Receive Monitoring, Recordkeeping, and Reporting Task Force Progress Report and Approve Recommendations to streamline VOC Recordkeeping as contained in that Report.

Barry R. Wallerstein, D.Env.
Executive Officer

Background

The AQMD Governing Board established the Monitoring, Recordkeeping, and Reporting Task Force (Task Force) in April 1999 to develop specific recommendations to the Board on how to streamline the MRR requirements for facilities subject to Regulation XI � Source Specific Rules, Regulation XX � RECLAIM, and Regulation XXX � Title V, while maintaining the air quality objectives and business needs of AQMD�s customers. AQMD Governing Board Vice-Chair Norma Glover was designated as the Task Force Chair and Governing Board member Ron Loveridge was appointed to the Task Force to provide guidance and direction to the Task Force activities. The Task Force included representatives from industry, state and federal government, and businesses that are directly or indirectly impacted by the AQMD MRR requirements. (Task Force members� names and affiliations can be found in the attached Task Force Progress Report.)

In June 1999, the Task Force decided to direct its first effort towards the AQMD recordkeeping requirements for industries using VOC-containing materials such as coatings, inks, solvents, adhesive, and graphic art materials; to be followed later by an examination of the MRR requirements for RECLAIM and Title V sources, respectively. After an initial review of the MRR requirements, the Task Force recommended that AQMD staff visit adjacent regulatory air agencies to understand their recordkeeping practices for VOC sources. Based on staff visits to affected businesses in the Bay Area AQMD, and Santa Barbara, San Diego, San Luis Obispo, and Ventura County Air Pollution Control Districts, staff was able to learn about recordkeeping practices that reduced the burden to affected businesses, while maintaining the enforceability of VOC rules and permits. These efforts resulted in the development of the streamlined VOC recordkeeping proposal, which is expected to help both the affected sources and the AQMD staff in compliance determination in the most efficient manner.

Proposal

The MRR requirements for VOC sources are centralized in Rule 109� Recordkeeping for Volatile Organic Compound Emissions. Rule 109 requires affected sources to show compliance with the exemption thresholds or emission limits contained in permits, applicable Regulation XI rules or Rule 219 � Equipment Not Requiring Written Permit Pursuant to Regulation II, on a daily basis. The goals of the streamlined VOC recordkeeping proposal are to:

- Provide an alternative to the daily recordkeeping system in Rule 109 for facilities not subject to daily mass or usage limits;

- Provide monthly limits as an alternative to daily usage and mass emission limits in VOC rules allowing small quantity usage of high-VOC materials (materials that exceed VOC rule limits); and

- Provide a procedure for facility operators, who wish to change daily emission limits to monthly limits, such that BACT analysis will not be required if there is no emissions increase.

The framework for this proposal hinges on segregating the data required in Rule 109 into three categories based on the frequency with which they are recorded in normal operations and the compliance time frame of the applicable rule limit and permit condition. In addition, this proposal is based on the �record-as-you-use� principle, which provides a direct and verifiable means to determine the monthly usage or mass emissions.

The data in each category are presented in three proposed VOC recordkeeping forms: VOC Listing, Usage Log, and Monthly Summary. The VOC Listing is used to verify the exemption or compliance status of facilities by comparing the VOC content of materials, as applied, with VOC limits in applicable rules. The Usage Log records the amount of material used and serves as the underlying supporting evidence for the total monthly usage and monthly VOC emission calculation. The Monthly Summary form is used to determine the exemption or compliance status of facilities by comparing the monthly usage and/or emissions with allowable VOC limits in applicable rules or permit conditions.

The proposed forms are suggested formats for streamlined recordkeeping, and are designed to incorporate data necessary to ensure compliance with applicable rule limits or permit conditions in an easy but enforceable manner, thereby establishing the general criteria for designing a VOC recordkeeping system. Based on these criteria and the assistance of affected industry representatives and facility operators, the Task Force also designed several industry-specific forms. (Appendix B of the Task Force Progress Report provides a list of industry-specific forms.) An alternative format incorporating all required data is considered to be equivalent to these forms if the general criteria are met. These criteria are discussed in detail in Section II of the attached Task Force Progress Report. Facilities are allowed to design an alternative recordkeeping system such as those based on monthly inventory or monthly purchase records, provided it can be used to demonstrate compliance with AQMD rule limits and permit conditions in a practical and enforceable manner. Further details on the alternative system criteria are provided in Section II of the attached Task Force Progress Report.

The proposed streamlined VOC recordkeeping system will require the development of new Rule 109.1, and amendment of Rules 109, 219, 1306, and Regulation XI VOC rules specifically for the portions directly affected by this proposal. Upon adoption, Rule 109.1 will allow the facility operator the choice of using the proposed recordkeeping system, where feasible. Section III of the attached Task Force Progress Report provides a comprehensive look at the proposed rule amendments and the impact of such rule amendments on VOC sources.

Public Process

Between June and December 1999, the Task Force held six meetings discussing the proposed streamlined VOC recordkeeping requirements and practices. The AQMD staff visited five adjacent air regulatory districts, and held seven public workshops between October and November 1999 to present the draft recordkeeping proposal and seek public review and comments to improve it. A summary of the public meetings including public comments and AQMD responses and site visits are contained in Appendices D and E of the attached Task Force Progress Report.

Task Force Recommendations

Based on Task Force meetings and discussions, staff visits and public workshops, along with input from Task Force members, industries, interested parties, and staff, the Task Force recommends that the Board direct staff to:

- Develop Proposed Rule 109.1 to provide facilities with the option of demonstrating compliance with this rule or Rule 109.

- Develop Amendments to Rule 219 and Regulation XI VOC rules to allow daily or monthly demonstration of usage or mass emission exemptions for facilities using rule-compliant VOC materials.

- Develop Amendments to Regulation III to allow 30% and 50% discounts from plan and permit evaluation fees identified for plans and permit applications, respectively, that are not subject to BACT.

- Develop and maintain a web page for VOC sources, and a simplified computer program allowing daily, monthly or annual data entry, linked with the current system for reporting annual emissions for Emission Fee Billing.

- Provide on-site training and organize training classes.

- Create a simplified avenue for evaluating permit applications to convert daily permit limits to monthly limits.

Further details on the above items are contained in Section IV of the attached Task Force Progress Report.

Resource Impact

Existing AQMD resources are sufficient to implement the proposed streamlined VOC recordkeeping system with no impact on the budget.

Attachment

Monitoring, Recordkeeping & Reporting Task Force Progress Report: VOC Recordkeeping

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