UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX AIR DIVISION

Technical Support Document

For EPA ’ s Proposed Rulemaking

For the California State Implementation Plan

Ventura County Air Pollution Control District , Rule 74. 20 , Adhesives and Sealants

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

May 201 3 2

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Agency: Ventura County Air Pollution Control District ( VCAPC D)

SIP Approved Rule : Rule 74. 20 – Adhesives and Sealants Adopted – June 8 , 199 3 Revised – January 11, 2005 Submitted – April 26 , 2005 EPA Approved – November 24 , 200 8 ( 7 3 FR 70883 )

Subject of this TSD: Rule 74. 20 – Adhesives and Sealants Revis ed – September 1 1 , 20 12 Submitted – April 22 , 201 3

RULE SUMMARY

- VCAPCD Rule 74. 20 , Adhesives and Sealants , was amended
to implement an All Feasible Measure as required by the California Clean Air Act ( Health and Safety Code § 40 914 ) in order to attain the ozone ambient air quality standard. Rule 74. 20 was also amended to comply with the federal reasonably available control technology (RACT) established in the 200 8 Control Technique Guideline (CTG) for Miscellaneous Industrial Adhesives , 1 CTG for Industrial Cleaning Solvents 2 and the State of California Air Resources Board (CARB) Determination of Reasonably Available Control Technology and Best Available Retrofit Control Technology (BARCT) for Adhesives and Sealants

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1 . EPA

- 453/R

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

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2 . EPA

- 453/R

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- 001 Control Techniques Guidelines for Industrial Cleaning Solvents, September 2006

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

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The modifications to Rule 74.20, Adhesives and Sealants include: 1. Revised the Substrate Surface Preparation limits in Section B

- 4 to expire on December 1, 2012 with an effective date of December 1, 2012 for the new limit of 25 grams/liter for a general substrate surface preparation category. Inkjet printer head assemblies w i ll continue to have a 200 gram s /liter limit. 2. Stated that p artial pressure is not a valid metric for Reactive Organic Compounds ( ROC )

- containing materials after the effective date of December 1, 2012 in Section B

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. 3. Clarified the storage requirements for RO C

- containing materials in Section B

- 6. 4. Revised the Adhesive Spray Application Equipment Cleaning limits to expire on December 1, 2012 with an effective date of December 1, 2012 for the new limit of 25 grams/liter for ROC

- containing spray application equipm ent cleaning materials in Section B

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. 5. Removed control equipment parameter s that are redundant to the statement that the equipment be approved by the Air Pollution Control Officer (APCO) in Section B

- 8. 6. Removed the already

- expired 200 5 effective date for sell

- through of non

complying adhesives in Section C

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. 7. Clarified recordkeeping requirements in Section D

. 8. Added titles and EPA approved version dates for all non

- EPA test methods in Section E

. 9. Added or revised definitions in Section G 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 4

 Deficiencies, EPA Region 9, August 21, 2001), and State Implementation 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 Misce llaneous Industrial Adhesives , ( EPA 453/R

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

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- 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 nonattainme nt area, any SIP

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

Enforceability

- The recordkeeping requirements for Adhesives and Sealants are generally analogous to that of S C A QMD’s rule 1168 and SJVUAPCD’s rule 4653

. All
tes t methods resemble th e CARB’s Determination of RACT and BARCT for Adhesives and Sealants

. Unlike the SJVUAPCD and SC AQMD rules , transfer efficiency is not specifically addressed in this rule. Only an adhesive spray application is discussed in this rule and the 25 grams/liter solvent limit restricts the VOC emissions for cleaning this type of equipment. C apture efficiency is adequately 5

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defined and the minimum percentage of 85 percent is the same as the 2008 CTG and SJVUAPCD’s rule. Therefore, we propose t o determine that submitted Rule 74. 20 is sufficiently clear and enforceable.

Stringency – We believe Rule 74.20 generally meets RACT. 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 ” . The only exception is the Plastic S olvent Welding (PVC) limit of 51 0 grams per liter which is slightly higher than the CTG 50 0 grams per limit for Plastic Solvent Welding (except ABS)

. VCAPCD’s Rule 74. 20 closel y resembles SC AQMD ’s Rule 1168 for VOC limits for adhesives , adhesive primer s, sealants and sealant primers and for solvent cleaning activities

. VCAPCD’s Rule 74.20 also addresses limits for adhesive strippers which the CTG, CARB determination and other district rules do not. However, t his rule does not s pecify application methods. Other exceptions in which this rule meets the CTG or the CARB RACT/BARCT limit , but is not as stringent as other SIP rules are:

 Top and Trim Adhesive with a limit of 540 grams/liter: There are no similar categories in with the CTG or CARB Determination of RACT and BARCT although the CTG indicates an 850 gram s /liter l imit for Motor Vehicle Adhesive. Both SCAQMD Rule 1168 and AVAQMD Rule 1168 have 250 grams/liter limits for this same category. However, the one

source which emits VOCs from this category emits 500 lbs/year, well under the 15 lbs/year allowed by the CTG.

 A BS Welding with a limit of 400 grams /liter: Although this lim it 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 Wel ding with a limit of 500 grams/liter: This limit is equal to the CTG and lower than the CARB Determination of RACT and BARCT 6

 but 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. We recommend that the lower limits for these fou r categories be considered for the next revision of this rule

. The definition of VOC in Section G, Subsection 74 , referencing the definiti on in VCAPCD’s Rule 2, does not comply with the 40 CFR 51.100(s) (5) which exempts
t
- butyl acetate (TBAc) except for r ecordkeeping, emissions reporting, photochemical dispersion monitoring and inventory requirements which apply to VOC. However, we do not believe that omitting the requirement for recordkeeping, emissions reporting, photochemical dispersion modeling and inventory requirements o f the exempt compound TBAc is sufficient basis to disapprove this rule. It is our conclusion that “...TBAc will not be VOC for purpos es of VOC emissions limitations or VOC content requirements , ” 4 which are the basis for compliance wit h this rule by a facility. In addition, the State will continue to assume the responsibility for the reporting, modeling and inventory requirements. Based on the discussion above, we propose to determine that submitted Rule 74.20 fulfills RACT requirement s and is sufficiently stringent

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SIP Relaxation – The new submittal generally complies with CAA § 110(l) and § 193 regarding SIP relaxations. In this revision, only the “All Other” Substrate Surface

4 . 40 CFR § 51.100(s)(5)

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Preparation category VOC limit ha s been lowered from 70 grams/liter to 25 grams/liter and the cleaning of adhesive spray application equipment is limited to solvents containing 25 grams/liter VOC

. Therefore, we propose to determine that submitted Rule 74.20 has not relaxed the SIP rule in conflict with CAA sec tions 110(l) or 193

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ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION – 1. Section B, Requirements: We recommend that the following limits be considered as discussed above : b. 250 grams/liter for Top and Trim Adhesive

c. 325 grams/liter for ABS Welding d. 250 grams/liter for Other Plastic Welding

e. 400 grams/liter for Plastic Welding Primer 2. Section C , Exemptions : Subsection 5 – SCAQMD’s Rule 1168 removed the exemption for “a facility that demonstrates that the total volume of non

- compliant adhesive, adhesive primers, adhesive bonding primers, sealants, and sealant primers is less than 55 gallons per facility per rolling 12

- month period.” September 1, 2001. SJVUAPCD’s Rule 4653 exempts a stationary source that “u ses 20 gallons or less of adhesives products in a calendar year.” Please consider either eliminating this exemption effective within a reasonable time period or lowering the de minimus limit to 20 gallons per facility per rolling 12 consecutive months. 2. Se ction E , Test Methods: Subsection 2 – Please add the complete title for ASTM D4457

- 91: Standard Test Method for Determination of Dichloromethane and 1,1,1

- Trichloromethane in Paints and Coatings by Direct Injection into Gas Chromatograph. 8

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EPA ACTION

- EPA staff recommends a full approval of Rule 74. 20 pursuant to CAA §110(k) (4) and §301(a).

ADDITIONAL REFERENCES

- 1. S C AQMD Rule 1168 , Adhesive and Sealant Applications, amended January 7, 2005

. http://www.aqmd.gov/rules/reg/reg11/r1168.pdf 2. SJVUAPCD Rule 4653, Adhesives and Sealants, amended September 16, 2010. http://www.va lleyair.org/rules/currntrules/r4653.pdf 3. Control Techniques Guidelines for Miscellaneous Industrial Adhesives, EPA 453/R

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

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- 005_miscellaneous_industria l_adhesives.pdf 4. Control Techniques Guidelines : Industrial Solvents , EPA

- 453/R

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- 001 , September 2006

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

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- 001_ind_cleaning_solvents.pdf 5. State of California Air Resources Board Determination of Reasonably Available Control Technology and Best Available Retrofit Control Techno logy for Adhesives and Sealants, December 1998. http://www.arb.ca.gov/ractbarc/adhfinal.pdf 6. “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 7. “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/littleblueb ook2001.pdf