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, O rganic Chemical Manufacturing Operations

Prepared by: David Grounds Reviewed by: Andrew Steckel

June 2 1

, 2011RULE 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 46 4

, 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. Lower ed the solvent VOC limit in section 308.5 for maintenance solvent cleaning from 50 g/l to 25 g/l

.

2. Update d ASTM met hod numbers in section 406 to the most current versions.

3. Added rule language in section s 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 thr ee facilities regulated by Rule 464 currently use s 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 reduction s 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. Stri ngency

– 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 (EP A

- 450

- 2

- 78

- 029, December 1978)

, were used to evaluate the Reasonably Available Control Technology (RACT ) requirements of §1 82(b)(2) and elsewhere in the CAA.

3. SIP Relaxation

– We have evaluated this SIP revision to determine whether it

would in terfere 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 Novem ber 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 t hat help define RACT. We are not a ware 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 int o 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

proc ess for ensuring that requirements for RFP and attainment of the NAAQS are met, and the submitted SIP revision is more stringent than the rule pr eviously approved into the SIP.

RULE DEFICIENCIES

– We have identified no deficiencies with Rule 464 sufficie nt 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

.