UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX AIR DIVISION

Technical Support Document

For
EPA ’ s Proposed Rulemaking

For the California State Implementation Plan

Santa Barbara County Air Pollution Control District , Rule 353 , Adhesives and Sealants

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

May 201 3 2



Agency: Santa Barbara County Air Pollution Control District ( SB CAPC D)

SIP Approved Rule : Rule 353
– Adhesives and Sealants Adopted – August 19 , 199 9 Submitted
– October 29 , 1999 EPA Approved – April 5 , 200 0 ( 65 FR 17771 )

Subject of this TSD: Rule 353
– Adhesives and Sealants
Revis ed – June 21 , 20 12 Submitted
– September 21 , 201 2

RULE SUMMARY

– SB CAPCD Rule 353 , Adhesives and Sealants , was amended
to clarify exemptions and add exemptions for low

- VOC solvents and for products subject to the consumer products regulation of the California Code of Regulations (CCR) Title 17. Several new provisions were exempted from the new more
st ringent solvent, surface preparation and coating stripper use requirements. The majority of revisions are for further clarification of terms and an expansion of descriptions. Rule 353 was also amended to lower VOC limits of a number of
adhesives and substr ate adhesives to comply with the federal reasonably available control technology (RACT) established in the 200 8 Control Technique Guideline (CTG) for Miscellaneous Industrial Adhesives , 1 and the State of California Air Resources Board (CARB) Determination of Reasonably Available Control Technology and Best Available Retrofit Control Technology (BARCT) for Adhesives

1 . EPA

- 453/R

- 08

- 005 Control Techniques Guidelines for Miscellaneous Industrial Adhesives, September 2008

. 3

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and Sealants

. 2 The compliance provision and test methods section was amende d to include more EPA approved test methods. A compliance schedule, application equipment requirement s, coating stripper requirements, reporting requirements and solvent cleaning machine requirements were added in this amendment. Santa
Barbara is currentl y in attainment for ozone and PM 2.5 so this rule is not required
to fulfil l federal RACT requirements

. The modifications to Rule 353 , Adhesives and Sealants , include:
1. Clarified the Section A, Applicability , to include distribution of adhesive products and associated solvents.
2. Revis ed several por tions in Section B , Exemptions:

a. R emove d the exemption fo r plaque laminating operations.
b. C larif ied several existing exemptions to include associated solvents

.
c. A dded an exemption for cleaning with a solvent co ntaining less than two percent Reactive Organic Compounds (ROC)

. d. A dded an exemption for consumer products regulat ed by CCR section 94507

.
e. Removed the requirement s for cleanup solvents and methods, for surface pre paration and for coating stripper use for a number of specialized items and processes involving adhesives and solvents. 3. Revised Section C to add definitions for the following: Adhesive Product, Airless Spray, Associated Solvent, Bench Scale Project, Coating, Compliant Material, Control, Control System, Dip Coat Application , Electrodisposition, Flow Coat Application, Hand Application Method, Noncompliant Material, Sealant Product, Solvent, Solvent Cleaning, Solvent Cleaning Machine, Stripper and Visco sity. Definitions for Aerosol Adhesives, Contact Bond Adhesive, Contact Bond Adhesive Specialty Substrates or Specialty Contact

2

. State of California Air Resources Board (CARB) Determination of Reasonably Availabl e Control Technology and Best Available Retrofit Control Technology (BARCT) for Adhesives and Sealants,
December 1998. 4

 Adhesive, Fiberglass, Flexible Vinyl, Grams of Reactive O rganic Compound
p er liter of Adhesive or Sealant Less Water and Less Ex empt Compounds, Outdoor Floor Covering Installation Adhesive, Percent Reactive Organic Compound by Weight, Sealant Solid, Surface Preparation Solvent, Thin Metal Laminating Adhesive , Tire Retread Adhesive and Volatile Organic Compound (VOC) were revised fo r clarity . D efinitions for Adhesive Bonding Primer, Any Other Primer, Exempt Compound, and Grams of Reactive Compound Per Liter of Material were deleted.
4. Revised the Tables in Sections D and E to lower ROC limits 12 months after the date of amended rule ad option for the following categories : Metal to urethane/rubber molding or casting, Multi

- purpose Construction (except cove base installation), Other plastic cement welding, PVC Welding and Fiberglass and Porous Material Substrates.
5. Clarified the Requirements for Aerosol Adhesives ROC Limit , Cleanup Solvents and/or Cleanup Method, Surface Preparation Solvent and Alternative Compliance Provisions in Sections F, G, H and I.
6. Changed Section J’s title from Storage of Reactive Organic Compound Containing Materials to Requirements – General Operating . C larified storage and disposal of ROC

- containing materials and added the following:

a. Installation, ventilation and ope ration of application equipment
b. Handling of waste solvent

c. Methods for reducing evaporation of ROC
– containing materials
d. Handling, transfer and storage of coatings, strippers and solvents
7. Clarification of Requirements for the Prohibition of Sale, Manufactur er Compliance Statement and Labeling and Prohibition of Specification in Sections K, L and M. 8. Changed title of Section N from Monitoring to Requiremen ts – Compliance
Provisions and T est Methods . Revised the following:

a. Inclu ded several additional test methods, using the correct titles and EPA approved dates, for determining the ROC content, exempt 5

 compounds, ROC content in aerosol containers, of plastic welding adhesives and primers, of capture efficiency and control de vice efficiency.
b. Remov ed the composite vapor pressure equation and replaced it with an ASTM method for measuring.

c. Clarified active and passive solvent losses from spray gun cleaning
and determination of reactive diluents test methods.
d. Added test methods for determining transfer efficiency, capture efficiency, control device efficiency, viscosity, measurement of emission of ROC from control system exhaust. 9. Revised the Recordkeeping Requirement in Section O to :

a. C larify t he type of information required for ROC

- containing adhesive
and sealant products materials and emission control equipment parameters

. b. Include requirements for purchase and disposal records at stationary

sources.

c. Establish a daily recording of noncompliant material usage and a monthly recording of compliant material usage.

10. Added Section s P, Compliance Schedule, Q , Requirement – Adhesive and Sealant Application Equipment, R, Requirement s – Coating Stripper Use, S, Reporting Requirements and T, Requirements – Solvent Cleaning Machine to provide clarity and completeness.

EPA EVALUATION

- The following criteria were used to evaluate the submitted
rule.

1. Enforceability

- The Bluebook ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations , EPA, May 25, 1988), the Little Bluebook ( Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001), and State Implementation 6

 Plans, General Preamble for the Implementation of Title I of the Clean Air Amendments of 1990 (57 FR 13498, April 16, 1992) were used to help evaluate compliance with the CAA §110(a)(2)(A) requirement for enforceability. 2. Stringency
– The EPA’s CTG s titled Miscellaneous Industrial Adhesives , ( EPA 453/R

- 0 8

- 00 5 , September 2008 ) and Industrial Cleaning Solvents ( EPA 453/R

- 06

- 001, September 2006 ) and CARB’s Determination o f Reasonable Available Control Tech nol ogy (RACT) and Best Available Retrofit Control Technology (

BARCT) for Adhesives and Sealants (December 1998)
were used to establish RACT for adhesives and sealants

. Other district s’ analogous rules for this category were used as the basis for RACT including: South Coast Air Quality Management District ( SC AQMD) Rule 1168 , Adhesive and Sealant Applic ations , amend ed January 7 , 20 05 , and S an Joaquin Valley Unified A ir Pollution Control District ( S JVU A PC D) Rule 4653 , Adhesives and Sealants , amended September 16 , 201 0

. 3. SIP Relaxation – We have evaluated this SIP revision to determine whether it would interfere with any applicable requirement concerning attainment and reasonable further progress (RFP) or any other applicable requirement of the
Act ( CAA §110(l)) or modify, in a nonattainment area, any SIP

- approved control requirement in effect before November 15, 1990 (CAA §193).

Enforceability

- The recordkeeping requirements for Rule 353 are very detailed and have clear time frames. G enerally , they are analogous to that of S C A QMD’s rule
1168 , SJVUAPCD’s rule 4653 and CARB’s Determination of RACT and BARCT for Adhesives and Sealants

. All test methods resemble th e CARB’s Determination of RACT and BARCT for Adhesives and Sealants

. C apture, Overall and Transfer efficienc ies are adequately defined and the minimum Overall efficiency percentage of 85 percent is equal to that of the 2008 CTG and SJVUAPCD’s rule. Therefore, we propose to determine that submitted Rule 353 is sufficiently clear and enforceable. 7

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Stringency
– We believe R ule 353 generally meets federal RACT requirements although that is not currently required in Santa Bar bara . Overall, it is as stringent as,
and in many cases more stringent than , the 2008 CTG and CARB’s 1998
“Determination of RACT and BARCT for Adhesives and Sealants ”

. SB CAPCD’s Rule 353 closely resembles SCAQMD’s Rule 1168 and AVAQMD ’s Rule 1168 for VOC limits for adhesives , adhesive primer s, sealants and sealant primers and for solvent cleaning activities

. SB CAPCD’s Rule 353 also addresse s limits for adhesive strippers which the CTG, CARB determination and other district rules do not.
The exceptions in which this rule meets the CTG or the CARB RACT/BARCT limit , but is not as stringent as other SIP rules are:

 Ceramic Tile (wall and floor) Adhesive with a limit of 13 0 grams/liter: Although the CTG and CARB Determination of RACT and BARCT indicate a 130 gram s /liter limit , SCAQMD Rule 1168 , AVAQMD Rule 1168 and SJVUAPCD 4653 have 65 grams/liter limits for th ese same categories

.

 Computer Diske tte Jacket Manufacturing adhesive, with a limit of 850
grams /liter: T his lim it resembles the limit in the CARB Determination of RACT and BARCT, but both SCAQMD Rule 1168 and AVAQMD Rule 1168 have 3 50 grams/liter limits for this same category.

 Contact Adhesive with a limit of 250 grams/liter: This corresponds to the 250 grams/liter limit of the CTG and the 850/250 grams/liter of the CARB Determination of RACT and BARCT . However, SCAQMD Rule 1168, AVAQMD Rule 1168, SJVUAPCD Rule 4653 and proposed Rule VCAPCD 74.20 all
propose a much lower limit of 80 grams/liter

.

 Cove Base adhesive, with a limit of 150 grams/liter: SCAQMD Rule 1168 , AVAQMD Rule 1168 and SJVUAPCD Rule 4653 have 50 grams/liter limits for this same category.

 Indoor Floor Covering I nstallation, with a limit of 150 grams/liter: SCAQMD Rule 1168, SJVUAPCD Rule 4653 and proposed Rule VCAPCD 74.20 all propose a much lower limit of 5 0 grams/liter. 8

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 ABS We lding with a limit of 400 grams /liter: Although this limit resembles the limits in the CTG and the CARB Determination of RACT and BARCT, both SCAQMD Rule 1168 and AVAQMD Rule 1168 have 325 grams/liter limits for this same category.

 Other P lastic Welding with a limit of 500 grams/liter: SBAPCD Rule 353, SCAQMD Rule 1168, SJVUAPCD Rule 4653 and AVAQMD Rule 1168 have established limits of 250 grams/liter for this category.

 Plastic Welding Primer with a limit of 650 grams/liter: While this limit is equivalent to that of the CTG, it exceeds the 510 grams/liter limit of the CARB Determination of RACT and BARCT , is considerably higher than the 400 grams/liter limit for proposed PCAPCD Rule 235 and for SJVUAPCD
Rule 4653 and is somewhat higher than the 550 grams/liter limit of SCAQMD Rule 1168 and AVAQMD Rule 1168.

 Contact Bond Specialty Substrate with a limit of 400 grams/liter: SCAQMD Rule 1168, SJVUAPCD Rule 4653 have limits of 250 grams/liter and PCAPCD Rule 235 proposes a 200 grams/liter limit. Considering that the 2008 CTG limits have ge nerally been met, we propose to determine that submitted Rule 353 is sufficiently stringent

. SIP Relaxation
– The new submittal generally complies with CAA § 110(l) and § 193 regarding SIP relaxations. In this revision, t wo categories of adhesives; Metal to Urethane /rubber Molding or Casting and Multipurpose Construction , two categories of plastic welding products; PVC welding and Other P lastic cement welding and two substrate/applications; Fiberglass and Porous Material have lowered limits. The category of “s trippers ” ha s been added to the recordkeeping requirements. Effective
June 21 , 2013 , Solvents will be required to contain no more than 25 grams /liter ROCs. In addition, recordkeeping requirements have been clarified and now include recordkeeping of all control system parameters. Therefore, we propose to determine
that submitted Rule 74.20 has not relaxed the SIP rule in violation of CAA sections 110(l) or 193

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ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION
– 1. Section D , Requirements – Reactive Organic Compound Limits for Specific Applications of Adhesive Products or Sealant Products, : We recommend that the following limits be considered as discussed above :

a. 65 grams/liter for Ceramic Tile Adhesive
b. 350 grams/liter for Computer Diskette Jacket Manufacturing Adhesive

c. 80 grams/liter for Contact Adhesive
d. 50 grams/liter for Cove Base Adhesive

e. 50 grams/liter for Indoor Floor Covering Installation Adhesive
f. 150 grams/liter for Outdoor Floor Covering Installation Adhesive
g. 325 grams/liter for ABS Welding
h. 400 grams/liter for Plastic Welding Primer
i. 200 grams/liter for Contact Bond

- Specialty Substrate
2. Section E, Requirements – Reactive Organic Compound Limits for Nonspecific Applications of Adhesive Products or Sealant Products Onto Substrates, Consider modifying the substrate “Metal” to “Metal to Metal.” 2. Section N , Test Methods: Subsection s 7 and 14 – The correct title for A RB Test Method 422 is “Determination of Volatile Organic Compounds in Emissions from Stationary Sources.”
3. The July 21, 2013 compliance date specified in Subsection P

- 1 and P

- 4 should be included in Section J and T respectively.

EPA ACTION

- EPA staff re commends a full approval of SBCAPCD Rule 353 pursuant to CAA §110(k) (4) and §301(a). 10

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ADDITIONAL REFERENCES

– 1. SBCAPCD Rule 353, Adhesives and Sealants, Adopted August 19, 1999.
2. SBCAPCD Rule 353, Adhesives and Sealants, Revised June 21, 2012. http://www.sbcapcd.org/rules/download/rule353.pdf 3. S C AQMD Rule 1168 , Adhesive and Sealant Applications, amended January 7, 2005

. http://www.aqmd.gov/rules/reg/reg11/r1168.pdf
4. SJVUAPCD Rule 4653, Adhesives and Sealants, amended September 16, 2010. http://www.valleyair.org/rules/currntrules/r4653.pdf
5. Control Techniques Guidelines for Miscellaneous Industrial Adhesives, EPA 453/R

- 0 8

- 00 5 , September 200 8 http://www.epa.gov/airquality/ozonepollution/SIPToolkit/ctg_act/200809_v oc_epa453_r

- 08

- 005_ miscellaneous_industrial_adhesives.pdf 6. Control Techniques Guidelines : Industrial Solvent s , EPA

- 453/R

- 06

- 001 , September 2006

. http://www.epa.gov/airquality/ozonepollution/SIPToolkit/ctg_act/200609_v oc_epa453_r

- 06

- 001_ind_cleaning_solvents.pdf
7. State of California Air Resources Board Determination of Reasonably Available Control Technology and Best Available Retrofit Control Techn ology for Adhesives and Sealants, December 1998. http://www.arb.ca.gov/ractbarc/adhfinal.pdf 8. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” (a.k.a., Bluebook) EPA OAQP S, May 25, 1988. http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf 9. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001. http://www.epa.gov/region9/air/sips/littlebluebook2001.pdf