South Coast Air Quality Management District

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Amend Rules 219, 481, 1107, 1141, 1141.1, 1141.2, and 1162

SYNOPSIS: 

Staff is proposing to amend several rules as part of a recordkeeping streamlining project that implements recommendations from the Monitoring, Recordkeeping, and Reporting Task Force. Proposed amendments will allow sources that meet certain criteria the option to keep monthly, rather than daily, records of VOC emissions. Outdated portions of the rules have also been updated.

COMMITTEE: 

Stationary Source, August 28, 2000, Reviewed

RECOMMENDED ACTION:

Adopt the attached resolution:

1. Certifying the Final Environmental Assessment for the proposed amendments.
   
   
2. Amending Rules 219 – Equipment Not Requiring a Written Permit Pursuant to Regulation II, 481 – Spray Coating Operations, 1107 – Coating of Metal Parts and Products, 1141 – Control of Volatile Organic Compound Emissions from Resin Manufacturing, 1141.1 – Coatings and Ink Manufacturing, 1141.2 – Surfactant Manufacturing, and 1162 – Polyester Resin Operations.

Barry R. Wallerstein, D.Env.
Executive Officer

Background

The Board established the Monitoring, Recordkeeping, and Reporting Task Force in April 1999 in response to concerns from the business community about the complexity of recordkeeping. The Task Force consisted of Board members, District staff, industry representatives, and EPA and CARB staff.

The District requires recordkeeping for VOC emissions to ensure compliance with District rules and regulations. VOC emissions contribute to ozone formation. The issue addressed by the Task Force was how to streamline records and maintain the integrity of the compliance program. The Task Force made several recommendations to streamline VOC recordkeeping in a report to the Board in January 2000. The Board approved the recommendations and directed staff to amend several rules to implement monthly recordkeeping.

The Task Force recommended allowing a monthly recordkeeping option for VOC emission sources meeting certain criteria as an alternative to current daily recordkeeping requirements. Facilities must meet the following criteria to be eligible for monthly recordkeeping:

• must not be subject to a daily usage or emission limit in any applicable District rule(s) or permit(s); and
  
  
• must use materials complying with the VOC content limits in the applicable District rule(s).

Rule 109 – Recordkeeping for Volatile Organic Compound Emissions, was amended on August 18, 2000 to include the monthly option. The Task Force also recommended amending Regulation III – Fees, to provide fee relief for facilities requiring permit changes in order to use new streamlined recordkeeping options. This was done in May 2000. In addition to Rule 109, the Task Force recommended amending several other rules to facilitate monthly recordkeeping. Those rule amendments are the subject of this proposal.

Proposal

This proposal is part of the recordkeeping streamlining project for VOC emission sources. The rules included in this proposal are:
 

The proposed amendments include the addition of a monthly recordkeeping option and the addition of monthly limits to some exemptions currently based on daily limits. The addition of monthly limits to Rule 219 will allow sources that do not require a written permit to keep streamlined records consisting of only a monthly summary of emissions as specified in Rule 109. Changes to the other rules will allow sources subject to those rules to use a streamlined monthly recordkeeping system that does not require daily calculations of emissions. Other minor changes are proposed to update definitions and remove exemptions that have expired. These proposed amendments, along with the recent amendment to Rule 109, will facilitate the use monthly recordkeeping for many facilities.

Public Input

A public workshop was held on July 7, 2000 to solicit information and suggestions from the public on the proposed rule amendments. Staff participated in many meetings and conference calls with CARB and EPA throughout the rule development process. Staff also attended two Monitoring, Recordkeeping, and Reporting Task Force meetings to update the members on rule development progress. No significant issues were raised during the meetings.

California Environmental Quality Act (CEQA) Analysis

SCAQMD staff has reviewed the proposed amendments to Rules 219, 481, 1107, 1141, 1141.1, 1141.2, and 1162 pursuant to state CEQA Guidelines Section 15002 (k)(2). A Draft Environmental Assessment (EA) with no significant adverse impacts has been prepared because, although the Draft EA concluded that the proposed rule amendments have the potential to adversely affect air quality, the impacts will not be significant. The Draft EA was circulated for a 30-day public review and comment period which ended November 8, 2000. All comments received are addressed and incorporated into the Final EA for the proposed project.

Socioeconomic Analysis

The proposed amendments are expected to reduce operational and administrative costs. Therefore, the amendments are not expected to have adverse impacts on the economy and employment.

AQMP and Legal Mandates

This amendment implements recommendations from the Monitoring, Recordkeeping, and Reporting Task Force. It is not an AQMP or legal mandate. The proposed changes will provide streamlined recordkeeping for many facilities.

Resource Impacts

Current AQMD resources are sufficient to implement the proposed amendments with no budget impact. Optional monthly recordkeeping will reduce administrative efforts for many facilities.

Attachments

1. Summary of Proposal
2. Key Issues and Responses
3. Rule Development Process
4. Resolution
5. Proposed Rule Language
6. Staff Report
7. Final EA

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