UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

South Coast Air Quality Management District, Rule 1144, 

Metalworking Fluids and Direct-Contact Lubricants

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

May 2011
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Agency: South Coast Air Quality Management District 

(SCAQMD)

SIP Approved Rule: Rule 1144 – Vanishing Oils and Rust Inhibitors

Adopted – March 6, 2009

Submitted – May 17, 2010

EPA Approved – July 14, 2010 (75 FR 40726)

Subject of this TSD: Rule 1144 – Metalworking Fluids and Direct-Contact 

Lubricants

Amended – July 9, 2010

Submitted – April 5, 2011

RULE SUMMARY -

Rule 1144, formerly titled Vanishing Oils and Rust Inhibitors, was revised to 

expand the applicability and purpose to include metalworking fluids and directcontact lubricants. Changes from the approved SIP submittal include:

1. Changed the title from “Vanishing Oils and Rust Inhibitors” to 

“Metalworking Fluids and Direct-Contact Lubricants.”

2. Added several definitions in Section (c) to add the metalworking fluid and 

direct contact lubricant categories to the current rule.

3. Expanded section (d) (1) Table A to include all metalworking fluid 

categories, to delineate between general metal protecting and military 

specified metal protecting categories and to include the direct-contact 

lubricant category. Table A was also expanded to include values for the 

effective date of 1/1/2011.

4. In general the terms “metalworking fluid and direct-contact lubricant” have 

replaced “vanishing oil and rust prevention” throughout the rule. 

5. The Administrative Requirements of section (f) have been expanded to 

require the display of Volatile Organic Compound (VOC) content and date 

of manufacture effective January 1, 2012 and an annual purchase report 

from 2011 through 2013.

6. Section (g) has been revised most significantly to require VOC listing 

records, monthly purchase records, usage records or the option of 

complying with Rule 109 recordkeeping requirements. Recordkeeping no 

longer applies to Super Compliant materials. 

7. Since Method 24 was found to be an inadequate testing method for these 

categories, Section (h) was almost entirely revised to include a newlyapproved thermogravimetric analysis (TGA) method ASTM E1868-10. 

Method ASTM D4017 was added to determine the water content. 

SCAMQD Method 304 was also eliminated as a VOC-content test. 
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8. Dimethyl Carbonate used as a cooling solvent in computed numerically 

controlled (CNC) machines and Super Compliant (fluids with VOC content 

50 grams/liter or less) have been added to the exemptions listed in section 

(i).

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) and the Little 

Bluebook (Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate 

compliance with the CAA §110(a)(2)(A) requirement for enforceability. 

2. RACT - EPA’s model VOC rule guidance titled, “Model Volatile Organic 

Compound Rules for Reasonably Available Control Technology” (June 

1992).

3. SIP Relaxation - Where previous versions of rules have been SIP approved, 

new submittals must comply with CAA §110(l) and §193 regarding SIP 

relaxations.

Enforceability –

The recordkeeping, reporting, testing and other requirements generally ensure 

that the submitted rule can be enforced. Test methods in section (h) that more 

accurately determine VOC content of the metalworking fluids and direct-content 

lubricants replace those methods that yield less accurate results for this category. 

Manufacturer’s annual quantity and emissions report for sales within the District 

required in section (f) will ensure that the VOC content data is available. Finally, 

we believe that the phasing of limits in the Administrative Requirements of section 

(f) and Recordkeeping Requirements of section (g) will provide the owners or 

operators and manufacturers adequate opportunity to make adjustments or 

reformulate while still being in compliance.

RACTSCAQMD’s staff report supporting local adoption of this rule estimates that 

additional controls would cost $35,351 per ton of emission reduction, and are 

therefore not appropriate to adopt at this time. We are also not aware of any 

federal (e.g., control technique guideline), state (e.g., suggested control measure) 

or local rules or guidance that suggest that more stringent requirements for this 

activity is reasonably available. Therefore, we believe the submitted rule is 

consistent with RACT requirements in section 182(b)(2) and elsewhere in the 

CAA. 

Sip Relaxation –

Approval of the submittal would comply with CAA § 110(l) and 193 because the 

submitted SIP revision is more stringent than the rule previously approved into 
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SIP and would insure equivalent or greater VOC emission reductions. The 

revised rule generally regulates more categories of metalworking fluids and 

lubricants and has improved testing, recordkeeping and reporting requirements. 

RULE DEFICIENCIES - We have identified no deficiencies with Rule 1144 

sufficient for EPA to propose less than full approval. 

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION - The 

following revisions are not currently the basis for rule disapproval, but are 

recommended for the next time the rule is amended. 

1. For clarity, we recommend that the following metal forming, metal removal 

and metal treating operations listed in subsections (c) (7), (9) and (10) and 

metalworking fluids listed subsection (c) (11) in be defined: 

a. blanking, coining, drawing, forming, forging, heading, piercing, roll 

forming, stamping and wire drawing.

b. broaching, cutting, drilling, grinding, honing, milling, tapping, 

threading and turning.

c. marquenching and quenching.

d. straight oils, emulsified oils, synthetic fluids and semi-synthetic 

fluids.

2. For completeness, we recommend that the term “single or multiple spindle 

automatic machine” indicated in subsection (c) (13) be defined.

3. For accuracy in defining the Sinker Electrical Discharge Machining method, 

please change the word “energetic” to “energized” in subsection (c) (14).

4. We recommend there be a clearer definition of “recommended dilution” in 

subsection (d) (2) (A) by changing this to the “manufacturer’s

recommended dilution.”

5. Please make the following revisions in subsection (h) (1) (A):

a. Upon approval of SCAQMD Method 319-10, clarify that the

“SCAQMD Additional Requirements to ASTM Standard Test E1868-

10” is “SCAQMD Method 319-10, Determination of Volatile Organic 

Compounds (VOC) in Metalworking Fluids and Lubricants by 

Thermogravimetry which are additional requirements to ASTM 1868-

10.” 

b. Include the date of the EPA-approved version ASTM D4017-96a

and correct the title to be “Standard Test Method for Water in Paints 

and Paint Material by the Karl Fischer Titration Method.”

c. Revise SCAQMD Method 303 to SCAQMD Method 303-91 and 

include the EPA-approved date of August, 1996.

6. Please revise the date of ASTM D93 referenced in subsection (h) (2) to 

ASTM D93-10a which is the most current test method approved by the 

EPA.

7. Please incorporate the following revisions in subsection (h) (3) (A) and (B):

a. Correct the title of the EPA technical guidance document to 

“Guidelines for Determining Capture Efficiency”, January 9, 1995.

b. Add the date, “May, 1995”, after SCAMQD “Protocol for 

Determination of Volatile Organic Compounds (VOC).”
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c. Add the title and date for CARB Method 422: “Determination of 

Volatile Organic Compounds in Emissions from Stationary Sources”, 

December 13, 1991. 

d. Add the complete title of SCAQMD Method 25.1 to “Determination of 

Total Gaseous Non-Methane Organic Emissions as Carbon”, and 

include the EPA-approved version date, February, 1991.

e. Add the complete title of SCAQMD Method 25.3 to “Determination of 

Low Concentration Non-methane Non-ethane Organic Compound 

Emissions From Clean Fueled Combustion Sources”, and include

the EPA-approved version date, March, 2000.

8. Please add the following statement in the section (h) Test Methods and 

Procedures: “When more than one test method or set of test methods are 

specified for any testing, a violation of any requirement of this rule 

established by any one of the specified test methods or set of test methods 

shall constitute a violation of this rule.” 

9. Clarify the following terms used in subsections (i) (4) and (5):

a. Regulation XI rules which are the SCAQMD Source-specific rules.

b. Avionics

10. Please revise subsection (i) (6) which exempts Super Compliant Materials 

from the “... provisions of subdivision (g).” A more accurate statement 

would be that “(T)he provisions of subdivisions (g) (1) and (2) shall not 

apply to Super Compliant Material(s) but those of subdivision (g) (3) shall 

apply to Super Compliant Material(s).” This will provide adequate 

information to demonstrate that the total emissions, including Super 

Compliant Materials, do not exceed 4 tons per calendar year.

EPA ACTION - The submitted Rule 1144 will incorporate provisions on 

metalworking fluids and direct-contact lubricators into the SIP and the associated 

District staff report projects it will reduce VOC emissions up to 0.86 tons per day

by January 1, 2012. The rule largely fulfils the relevant CAA §110 part D 

requirements. EPA staff recommends a full approval of Rule 1144 pursuant to 

CAA §110(k) (3) and §301(a). 

ATTACHMENTS -

1. SCAQMD Rule 1144, Metalworking Fluids and Direct-Contact Lubricants, 

as submitted on April 5, 2011.

2. SCAQMD Rule 1144, Vanishing Oils and Rust Inhibitors, as submitted on 

May 17, 2010.

ADDITIONAL REFERENCES -

1. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and 

Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf

2. “Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001.
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http://www.epa.gov/Region09/air/sips/littlebluebook2001.pdf

3. “Model Volatile Organic Compound Rules for Reasonable Available Control 

Technology,” EPA-Staff Working Document, June 1992.

http://www.epa.gov/ttn/oarpg/t1/ctg/flexpkg_draftctg20060804.pdf