UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

Sacramento Metropolitan Air Quality Management District 

Rule 464, Organic Chemical Manufacturing Operations

Prepared by: David Grounds

Reviewed by: Andrew Steckel

June 21, 2011
RULE IDENTIFICATION

Agency: Sacramento Metropolitan Air Quality Management District 

(SMAQMD)

SIP Approved Rule: Rule 464 – Organic Chemical Manufacturing Operations

Adopted – July 23, 1998

Submitted – May 13, 1999

EPA Approved – April 19, 2000 (65 FR 20912)

Subject of this TSD: Rule 464 – Organic Chemical Manufacturing Operations

Amended – September 25, 2008

Submitted – September 15, 2009

RULE SUMMARY - SMAQMD Rule 464, Organic Chemical Manufacturing Operations, is a 

rule designed to limit volatile organic compound (VOC) emissions from organic chemical 

plants. The rule establishes requirements for reactors, distillation columns, separators, 

dryers, process tanks and other operations. 

Changes from the approved SIP rule include:

1. Lowered the solvent VOC limit in section 308.5 for maintenance solvent cleaning 

from 50 g/l to 25 g/l.

2. Updated ASTM method numbers in section 406 to the most current versions.

3. Added rule language in sections 501.4 – 501.7 to require sources to keep records 

of the VOC content of materials used. 

4. Added paragraph in section 502.6 to clarify enforceability.

None of the three facilities regulated by Rule 464 currently uses solvent-based materials 

for maintenance cleaning in organic chemical manufacturing operations. Water-based 

detergent solutions are used for this purpose. As a result, SMAQMD projects no 

emissions reductions or additional costs will result from the proposed rule.

EPA EVALUATION CRITERIA –

1. Enforceability – Section 110(a)(2)(A) of the CAA requires that regulations 

submitted to EPA for incorporation into the SIP must be clear and legally 

enforceable.
2. Stringency – Control of Volatile Organic Emissions from Batch Processes –

Alternative Control Techniques Information Document (EPA-453-93-017, 

February 1994); and Control of Volatile Organic Emissions from Manufacture of 

Synthesized Pharmaceutical Products (EPA-450-2-78-029, December 1978), were 

used to evaluate the Reasonably Available Control Technology (RACT)

requirements of §182(b)(2) and elsewhere in the CAA.

 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 non-attainment area, any SIP-approved control 

requirement in effect before November 15, 1990 (CAA 193).

EPA EVALUATION –

1. Enforceability – The rule requirements are clear and contain adequate 

monitoring, recordkeeping and reporting provisions to ensure enforceability 

pursuant to CAA section 110(a).

2. Stringency - The submitted Rule 464 is more stringent than the approved SIP, 

largely because of the lower solvent VOC limit of 25 g/l. The stringency of 

requirements in submitted Rule 464 is also generally consistent with relevant 

guidance listed above that help define RACT. We are not aware of more 

stringent analogous rules in other areas.

3. SIP Relaxation - We propose to determine that our approval of the submittal 

would comply with CAA section 193 because the submitted SIP revision is more 

stringent than the rule previously approved into the SIP and would insure 

equivalent or greater emission reductions of VOC. We also propose to 

determine that our approval of the submittal would comply with CAA section 

110(l), because the proposed SIP revision would not interfere with the on-going 

process for ensuring that requirements for RFP and attainment of the NAAQS are 

met, and the submitted SIP revision is more stringent than the rule previously 

approved into the SIP.

RULE DEFICIENCIES – We have identified no deficiencies with Rule 464 sufficient for EPA 

to propose less than full approval.

EPA ACTION – EPA staff recommends full approval of Rule 464 pursuant to CAA 

§110(k)(3) and §301(a).
REFERENCES –

SMAQMD Rule 464, Amended September 25, 2008.

SMAQMD Rule 464, Staff Report, August 26, 2008.

SMAQMD Rule 464, Adopted July 23, 1998.