UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX AIR DIVISION

Technical Support Document

for EPA’s Direct Final Rulemaking

for the California State Implementation Plan

San ta Barbara County Air Pollution Control District,

Rule 337 , Surface Coating of Aerospace Vehicles and Components

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

December 201 2- 2

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RULE IDENTIFICATION

Agency: San ta Barbara County Air Pollution Control District (S BC APCD)

SIP

- Approved Rule: Rule 337
– Surface Coating of Aircraft or Aerospace
Vehicles Parts and Products
A dopt ed – Octo ber 20, 1994 Submitted
– January 24 , 1995 Approved – February 12, 1 996 ( 61 FR 5288 )

Subject of this TSD: Rule 337

- Surface Coating of Aerospace Vehicles and Components
Amended – June 21 , 201 2 Submitted
– September 21 , 201 2

RULE SUMMARY

- Rule 337 establishes reactive organic content (R OC ) limits and workplace standards for industrial sites engaged in the specification, use, application and solicitation of coating, st ripping and solvents used for coating aerospace vehicles and components, including the cleanup of equipment, and the storage and disposal of solvents and waste solvent materials associated with these sites . It also describes related recordkeeping, reporting, and monitoring requirements. Changes from the approved SIP rule include the following:
1. Section A, Applicability: This section was expanded to include those who use or solicit surface co ating for aircraft with the understanding that this term includes those who specify aerospace vehicle and component coatings

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2. Section B, Exemptions: Several exemptions have been added which are
included in Code of Federal Regulations 1 (CFR) or California Code of Regulations (CCR) with the exception of B.14.a which exempts the cleaning or stripping of coating overspray from personal protective equipment. This exemption was deemed necessary for safe operating procedures. 3. Several n ew definition s were added in Section C. A ll definitions are either defined in the Control Techniques Guideline (CTG) 2 , CFR or the district’s
SIP

- approved rule s

. 4. The ROC limits in Section D are similar to or lower than those in the CTG. There are five categories that are not included in the CTG: Barrier Coating, Extreme Performance Interior Topcoat, Fastener Sealant, Interior Topcoat and Space Vehicle Coating

- Other. These limit values are equal to those of other districts including San Joaquin Valley Unified Air Pollut ion Control District (SJVUAPCD), Bay Area Air Quality Management District (BAAQMD) and South Coast Air Quality Management District (SCAQMD).
5. Subsections 9, 10 and 11 were added to Section E, Application Equipment. These additions allow other application methods if they are approved by the Control O fficer, California Air Resources Board (CARB) and the EPA; air

atomized spray application for contact and specialty contact adhesives and other sealant products that meet a viscosity threshold. 6. Section F, Gener al Operating, which is basically a housekeeping section was greatly elabo rated to include storage requirements for ROC materials and the handling of application equipment and spills.
7. The recordkeeping of Section G, now incorporates more detail, different
d urations for compliant and non

- compliant materials, record keeping of key operating parameters for all facilities using emission control equipment and detailed recordkeeping for those claiming the exemption for use of less than

1 . 40 CFR 63 Subpart GG
– National Emission Standards for Aerospace Manufacturing and Rework Facilities
2

. CTG for Control of Volatile Organic Compounds (VOC) from Coating at Aerospace Manufacturing and Rework Facilities

– EPA

- 453/R

- 97

- 004, December 1997- 4

- 20 gallons of each formulatio n. The retention of records on site was reduced from 3 years to 2 years which is analogous with other aerospace vehicle coating rules. 8. Section I was renamed Compliance Provisions and Test M ethods and is divided and expanded according to test results, such as control device efficiency, application transfer efficiency and viscosity rather than by rule section as was the previous arrangement. Several more test methods have
been included. 9. New sections for solvent cleaning (section J) , a compliance schedule (sec tion K), reporting criteria for permitted facilities (section L) and requirements for solvent cleaning machines (section M) were added to rule 337.

RULE EVALUATION CRITERIA

- We primarily used the following criteria to evaluate
the submitted rule:

1. Enforceability

- CAA section 110(a)(2)(A) requires that regulations submitted to EPA for approval into a SIP must be clear and legally enforceable.

2. Rule Stringency
– CAA section 172(c)(1) requires nonattainment areas to implement all reasonably available control measures (RACM), including such reductions in emissions from existing sources in the area as may be obtained through the adoption, at a minimum, of reasonably available control technology (RACT), as expeditiously as practicable. In addition, under CAA section 182(b)(2)
, ozone nonattainment areas classified as moderate or
above must implement RACT for all VOC sources covered by a CTG
document and all other major sources of VOCs

. The SBCAPCD regulates an
area that is classified as maintenance for the 1

- hour ozone standard and is in attainment for all criteria pollutants, thus, submitted Rule 337 does not have to fulfill RACT requirements. 40 C.F.R. § 81.305 (2010). EPA’s CTG s titled Control of Volatile Organic Compound Emissions from Coating Operations at- 5

- Aerospace Manufacturing and Rework Operations (EPA

- 453/R

- 97

- 004, December 1997) (hereinafter “Aerospace CTG”) and Control of Volatile Organic Compound Emissions from Solvent Metal Cl eaning (EPA

- 45 0 /R

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- 7 7

- 0 22 , Nov ember 19 7 7) (hereinafter “ Solvent Metal Cleaning CTG”) cover many of the source s regulated under Rule 337

. 3. SIP Re laxation

- CAA section 110(l) prohibits EPA from approving any SIP revision that would interfere with any applicable requirement concerning attainment and reasonable further progress (RFP) or any other applicable requirement of the CAA. In addition, CAA section 19 3 prohibits the modification of any SIP

- approved control requirement in effect before November 15, 1990, in a nonattainment area.

In applying these criteria to the submitted rule, we referred to the following guidance and policy documents:

 Issues Relating to VOC Regulation, Cutpoints, Deficiencies, and
Deviations (the "Blue Book"), US EPA, OAQPS (May 25, 1988).

 Guidance Document for Correcting Common VOC and Other Rule Deficiencies

, EPA Region IX (August 21, 2001, the “Little Bluebook”).

 State Implementati

on Plans; General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990, 57 FR 13498 (April 16, 1992); 57 FR 18070 (April 28, 1992).

 EPA’s Aerospace CTG

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 EPA’s Solvent Metal Cleaning CTG. In addition, we reviewed other state an d local rules for this source category.

RULE EVALUATION
1. Enforceability
– The recordkeeping requirements for coatings and control system parameters, test methods and other requirements generally ensure that the submitted rule can be enforced. They include records of usage of compliant and noncompliant materials, purchase records, records of key- 6

- operating parameters and records for those claiming an exemption for de minimis usage

. Therefore, we propose to determine that submitted Rule 337 is sufficiently clear and enforceable.
2. Stringency
– The Aerospace CTG contains EPA’s most recent identification of national presumptive RACT for this industry. Since S BC APCD is in attainment, it is not required to meet RACT. Nevertheless, t he VOC limits in
amended Rule 33 7 are as , or more , stringent than the VOC limits in this CTG, and we are not aware of significantly more stringent requirements in other analogous regulations. Those categories for which there are no analogous CTG categories are compar able to the most stri ngent limits of
other district rules.
Rule 337 also identifies VOC content limits for solvents that are , for the most part, addressed by the Aerospace CTG. Section D

. 3 of the rule allows, as an alternative to compliance with these limits, the use of an a d d

- on control system with an overall efficienc y of at least 85.5 % exceed ing the 81% of the Aerospace CTG. In addition, compliance through use of such a control system must not result in emissions greater than the VOC emissions that would have resulted if ma terials in compliance with the applicable VOC limits
had been used. 3. SIP Relaxation

- In addition, we believe the submitted rule is more stringent than the version previously approved into the SIP, so the submitted rule does not relax the SIP and complies with CAA §110(l) and §193.

RULE DEFICIENCIES
– We have identified no deficiencies in submitted Rule 33 7 sufficient for EPA to propose less than full approval.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION
– We have no further recommendations for this rule.- 7

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EPA ACTION

- EPA staff recomm ends a full approval of Rule 337 pursuant to CAA §110(k) (4) and §301(a).

ADDITIONAL REFERENCES

– 1. SBCAPCD Rule 337
– Surface Coating of Aerospace Vehicles and Components submitted September 21 , 201 2
2. Rule 3 37
– Surface Coating of Aircraft or Aerospace Vehicles Parts and
Products , as approved into the SIP on February 12, 1996

. 3. “ Control of Volatile Organic Compound Emissions from Coating Operations at Aerospace Manufacturing and Rework Operations , ” EPA

- 453/R

- 97

- 004, December 1997. http://www.epa.gov/ttn/naaqs/ozone/ctg_act/199712_voc_epa453_r

- 97

- 004_aerospace_rework.pdf
4. “Control of Volatile Or ganic Emissions from Solvent Metal Cleaning,” EPA

450/2

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- 022, November 1977. http://www.epa.gov/ttn/naaqs/ozone/ctg_act/197711_voc_epa450_2

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- 022_solvent_metal_cleaning.pdf
5. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.
6. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001. http://www.epa.gov/Region09/air/sips/littlebluebook2001

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