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,

Metal w orking Fluids and Direct

- Contact Lubricants

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

May 20112

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

– Metalw orking Fluids and Direct

- Contact

Lubricants

Amended

– July 9, 2010

Submitted

– April 5

, 201 1

RULE SUMMARY

- Rule 1144 , formerly titled Vanishing Oils and Rust Inhibitors, was revised to expand the applicability and purpose to include metalworking fluids and direct

contact 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. Expand ed 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 exp anded 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 newly

approved thermogravimetric analysis (TGA) method ASTM E1868

- 10.

Method ASTM D4017 was added to determine the water conte nt.
SCAMQD Method 304 was also eliminated as a VOC

- content test.3

8. Dimethyl Carbonate used as a cooling solvent in c omputed 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 enforceabilit y.

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 c ontent 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 opportuni ty to make adjustments or

reformulate while still being in compliance

.

RACT

SCAQMD’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 stri ngent 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

–

A pproval of the submittal would comply with CA A § 110(l) and 193 because the

submitted SIP revision is more stringent than the rul e previously approved into4

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

, meta l removal

and metal treating operations listed in subsection s (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 c ompleteness , we recommend that the term “single or multip le 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 dilu tion” in subsection (d) (2) (A) b y 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, c larify that the “SCAQMD Additional Requir e ments 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. Inc lude 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

- a pproved 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 t he title of the EPA technical guidance document to

“ Guidelines for Determin ing Capture Efficiency”, January 9, 1995.

b. Add the date, “ May, 1995 ” , after SCAMQD “Protocol for Determination of Volatile Organic Compounds (VOC).”5 c. Add the title and date f or 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

includ e 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 versi on 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 s ub section (i) (6) which exempt s 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 su bdivision (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 larg ely fulfils the relevant CAA §110 part D requirements. EPA staff recommends a full approval of Rule 114 4 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 , 201 1

. 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, 2001.6 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