UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

For

EPA ’ s Direct Final Rulemaking

For the California State Implementation Plan

Placer County Air Pollution Control District , Rule 2 45

, Surface Coating of Metal

Parts and Products

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

November 20102

RULE IDENTIFICATION Agency: Placer County Air Pollution Control District ( PC APCD )

Superseded Submittals: Amended

– December 11, 2008 ; Submitted

– September 18, 2009

Subject of this TSD: Rule 2 45

- Surface Coating of Metal Parts and

Products

Amended

– August 20, 2009 ; Submitted

– January 10, 2010

RULE SUMMARY

– PC APCD Rule 245

, Surface Coating of Metal Parts and

Products

, is a rule designed to limit volatile organic compound (VOC) emission

from the application of coatings, coating removers (strippers), surface preparation materials, and cleanup materials in metal parts and products coating operations. VOC limits f or applicable coating materials are indicated in Table 1 of

Section 301. Recordkeeping is stipulated in Section 501 and test methods are

outlined in Section 503.

EVALUATION CRITERIA

- The following criteria and guidance documents 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 Littl e 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 Control Technique Guideline s (CTG) titled, “ Control Techniques for Miscellaneous Metal and Plastic Parts Coatings ” (E PA

45 3 / R

- 08

- 003 ) and other state and local rules for this category were used to help evaluate the RACT requirements of CAA § 182(b)(2).

3. R ule Relaxation

– CAA §110(l) and §193 restrict SIP revisions that interfere with attainment or other provisions of the Act.

EPA EVALUATION

The monitoring, recordkeeping, reporting and other requirements generally ensure

that the submitted rule can be enforced.

We believe Rule 2 45 implements RACT partly because it is generally as stringent

as the 2008 CTG which has been issued for this activity with regard to coating of metal parts. We note, however, that the 2008 CTG also addresses coating of plastic parts, which is not addressed by Rule 245

. As part of a broader demonstration of RACT, PCAPCD will need to adopt additional requirements for plastic parts equivalent to the CTG, or submit a negative declaration3

demonstrating that implementation of the CTG would not affect any plastic part coating operations in PCAPCD.

Since no previous version of these requirements is already in the SIP, approval of this version only improves the SIP and does not relax the SIP in violation of CAA section 110(l) or 193.

RULE DEFICIENCIES

– We have identified no deficiencies with Rule 245 sufficient for EPA to propose less than full approval.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION

– The following revision s are not currently the b asis for rule disapproval, but are

recommend ed for the next time the rule is amended.

1. Please revise the introductory paragraph for section 105 to read, “Except for recordkeeping and work practices requirements...” As a result of this change, please revise Section 501.1.2 to “Classification according to terminology used in Sections 105, 301, 302 and 303.”

2. Please consider the following changes to definitions:

a. After initial use of “Volatile organic components” in Section 101, add “(VOC). ”

b. Revise sections 220, 226, 227, 232, 233, 248, 253, 257 and 264

consistent with the definitions in the 2008 CTG

, SCAQMD Rule

1107 or SMAQMD Rule 451.

c. R evise title of Section 242 to “Military Specification Coating.

d. D elet e any material or term from the definitions list that is not referenced in this rule. For example, Aluminum Coating for Window

Frames and Door Frames and Non

- skid Coating are not included in

301.

3. Please consider using the lower v alues for air

- dried Prefabricated Architectural Coating pe r SCAQMD’s Rul e 1107 in Section 301

.

4. Sections 302.1 and 302.7 should be revised to require the appropriate application methods indicated in the 2008 CTG :

a. For e xample in Section 302.1, “ Electrostatic attraction ” should be

“ Electrostatic Application” and “Roll Coat” should be “Roll Coater”

. b. Section 503.5 should be revised to agree with the coating type

listed in Section 301 : “ Metallic and Iridescent Coating ”

.

5. Several references have not been updated to reflect previous section changes:

a. Section 402.4 reference s Section 270. This should be changed to

Section 272.4 b. Sections 405, 501.3, 501.3.1, 501.3.2, 503.3 and 503.4 reference Section 304. This should be changed to Section 305

. c. Section 503.2 references Section 224. This should be changed to

Section 22 5.

d. Section 501.3.2 also references Section 235. This should be changed to Section 236.

6. Please revise Section 403 to be consistent with the 2008 CTG (page 28) to require that all VOC

– containing materials, including thinners and any other additives, be included when determining the coating unit’s emission rate. See, for example, SMAQMD Rule 4 51, Section 403.

7. Please revise Section 501.1.3 to list all mixing ratios and delete the phrase “, if different from the manufacturer's recommendation.” This change will

eliminate the need for Section 501.1.4.

8. In Section 503.5, please use t he correct methods listed in SCAQMD Rule

1107 : Method 311

- 91, “Analysis of Percent Metals in Metal Coatings by Spectrographic Method” and SCAQMD's Method 318

- 95, “Determination of Weight Percent Elemental Metal in Coatings by X

- Ray Diffraction ”.

9. Similar to SCAQMD Ru le 1107 , please consider revising Section 503. 6 to read, “The acid content of pretreatment wash primers and etching filler

shall be measured...”

10. We note that R ule 245 does not address plastic parts coating opera t ions

while the 2008 CTG does. PCAPCD will need to adopt additional requirements for plastic parts equivalent to the CTG, or submit a negative declaration demonstrating that implementation of the CTG would not affect any plastic part coating operations in PCAPCD.

EPA ACTION

- The District staff re port states that Rule 245 was amended to address the 2008

CTG and we have found this to be the case. EPA staff recommends approval of

Rule 2 45 pursuant to CAA §110(k ) ( 3) and §301(a).

ATTACHMENTS

- 1. PCAPCD Rule 2 45

, Surface Coating of Metal Parts and Products , as
submitted on August 20, 2009

ADDITIONAL REFERENCES

- 1. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

2

. “Guidance Document for Correcting Common VO C & Other Rule Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001

.5

3. “Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coating ,” EPA

- 453/R

- 0 8

- 00 3 , September 200 8

. http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200809_voc_epa453_r

- 08

- 003_misc_metal_plasticparts_coating.pdf