UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for EPA’s Direct Final Rulemaking

for the California State Implementation Plan

FEATHER RIVER AIR QUALITY MANAGEMENT DISTRICT

Rule 3.14

, Surface Preparation and Clean

- Up

Prepared by: Arnold Lazarus Reviewed by: Andy Steckel

September 20142

RULE IDENTIFICATION

Agency: Feather River Air Quality Management District (FRAQMD)

SIP Approved Rule: Rule 3.14

– Solvent Degreasing (Sutter County Air Pollution Control District)

Submitted

– January 28, 1981

EPA Approved

- May 3, 1982 (47 FR 118856)

Subject of this TSD: Rule 3.14

- Su rface Preparation and Clean

- U p Amended

- May 8, 2013

Submitted

- February 10, 2014

RULE BACKGROUND

–

Under Section 107(d) of the Clean Air Act (CAA), EPA designated portions of Yuba and Sutter counties nonattainment for the following three National Ambient Air Quality Standards (NAAQS): 1

- hour ozone, 1997 8

- hour ozone and 2008 8

- hour ozone . These

areas ar e regulated by the Feather River Air Quality Management District (FRAQMD).

Sutter County Air Pollution Control District (SCAPCD) Rule 3.14 “ Solvent Degreasing ” reads, in entirety, “Any container of solvent which exceeds 55 gallons capacity shall

contain i nstructions to store in a closed condition.” SCAPCD Rule 3.14 was approved by

EPA into the State Implementation Plan (SIP) on May 3, 1982. I n June 1991 , SCAPCD and the Yuba County APCD combined to form the FRAQMD, and SCAPCD Rule 3.14 became enforceable by FRAQMD. In 2011

, the FRAQMD renamed the rule “Surface Preparation and Clean

- Up” and significantly expanded the requirements to account for

the various uses of solvents . FRAQMD further amended Rule 3 .1 4 on May 8, 2013

, and CARB submitted this version to EPA on February 10, 2014 to be incorporated into

the SIP. FRAQMD’s staff report that supported the 2011 rule revisions explained that,

“ The rule will effectively lower the VOC content limit for the various uses of solvents and document procedures to reduce the evaporation of solvents into the atmosphere. Lower VOC content limits for these solvents have been achieved for most applications in other Air Districts through the use of aqueous technologies or by transitioning to exempt compounds.” 1

R ULE SUMMARY

- FRAQMD Rule 3.14, Su rface Preparation and Clean

- U p (SP&CU)

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

associated with su rface preparation, c lean

- up and disposal of the materials used in SP&CU through the use of aqueous technologies, solutions using either compliant

solvents such as acetone or D

- limonene or compliant solvents combined with low VOC

1 “Final Staff Report Rule 3.14,” FRAQMD, June 6, 2011. 1.3

solvents

, and techniques that contain the cleaning process thus limiting VOC emission

into the atmosphere

, such as paint spray gun cleaners. According to the Staff Report,

“District rule 3.14 is based on EPA’s Control Techniques Guidelines (CTG) for Industrial Cleaning Solvents, which was issued in September 2006. ” 2 Most of the general VOC

content limits are 50 g/l which is specified in the aforementioned CTG. Electrical apparatus and components, and all operations related to printing

, have VOC limits of 100 g/l.

EPA EVALUATION CRITERIA

– 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) and T he Little 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. Stringency

- Rule 3.14 was partially evaluated against EPA’s Control Technique Guidelines (CTGs) titled, “Control of Volatile Organic Emissions from Solvent Metal Cleaning” (EPA

- 450/2

- 77

- 022, November 1977)

, “Control Techniques Guidelines for Industrial Cleaning Solvents” (EPA

- 453/R

- 06

- 001 September 2006), “Control Technique Guidelines for Flexible Package Printing” (EPA

453/R

- 06

- 003) September 2006, “Control of Volatile Organic Compound Emissions from Coating Operations at Aerospace manufacturing and Rework Operations” (EEPA

- 453/R

- 97

- 004), CARB’s RACT/BARCT guidance titled, “Organic Solvent Cleaning and Degreasing Operations” (July 18, 1991), and

other state and local rules for this category to help evaluate the RACT requirements of CAA § 182(b)(2). The solvent limits were also compared to South Coast Air Quality Management District’s Rules 1171 and 1124, Yolo

Solano Air Quality Management District’s Rule 2.31 , San Joaquin Valley Unified Air Pollution Control District’s Rule 4663, and Sacramento

- Metropolitan Air Quality Management District’s Rule 466.

3. SIP Relaxation

- We have evaluated this SIP revision to determine whether it would interfere with any appli cable requirement concerning attainment and reasonable further progress (RFP) or any other applicable requirement of the Act (CAA § 110(l)) or modify, in a nonattainment area, any SIP

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

The VOC limits, recordkeeping requirements and other provisions of Rule 3.14 are clear and adequately fulfil the enforceability requirements summarized in paragraph #1 above. Rule 3.14 implements RACT because it is generally as stringent as the guidel ines listed in paragraph #2 above. The submitted rule complies with CAA §110(l) and §193 consistent with paragraph #3 above.

2 Ibid. 2.4

RULE DEFICIENCIES

– We have identified no deficiencies with Rule 3.14 sufficient for EPA to propose less than full approval.

EPA ACTION

Rule 3.14 strengthen s the SIP because the FRAQMD did not have a SIP approved rule regulating surface preparation and clean

- up with solvents. The FRAQMD projects that Rule 3.14 will result in a reduction of 1.5 tons of VOC per year in the Sacra mento Federal Nonattainment Area (SFNA) portion of the district. 3 The remaining northern portion of FRAQMD is projected to achieve a 28 ton per year VOC reduction. 4 The rule satisfies relevant CAA §110 and part D requirements. EPA staff recommends full

app roval into the SIP.

EPA RECOMMENDATIONS

The following revisions are not currently the basis for rule disapproval but are

recommended for the next time the rule is amended.

1. Lower the VOC content limit for Aerospace Component product cleaning in paragraph C.1, Table 1 , from 900 grams/liter (g/l) to 200 g/l or ≤ 45 mm Hg
consistent with South Coast AQMD Rule 1171.

2. Lower the VOC content limit , Product Cleaning and Cleaning of Application Equipment in paragraph C.1, Table 1, from 50 g/l to 25 g/l consistent with many other analogous California rules, including San Joaquin Valley Unified Air

Pollution Control District’s Rule 4663

, Sacramento

- Metropolitan Air Quality Management District’s Rule 466 and South Coast Air Quality Management

District’s Rules 1171 and 1124

.

R EFERENCES

1. FRAQMD Rule 3.14

- Su rface Preparation and Clean

- U p , as submitted on February 10, 2014

2. The Bluebook ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and

Deviations , EPA, May 25, 1988)

3. The Little Bluebook ( Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001)

4. “Control of Volatile Organic Emissions from Solvent Metal Cleaning” (EPA

- 450/2

- 77

- 022, November 1977)

5. “Control Techni ques Guidelines for Industrial Cleaning Solvents” (EPA

- 453/R

- 06

- 001 September 2006)

6. “Control Technique Guidelines for Flexible Pack age Printing” (EPA 453/R

- 06

- 003, September 2006 )

7. “Control of Volatile Organic Compound Emissions from C oating Operations at

3 Ibid.

4 Ibid.5

A erospace M anufacturing and Rework Operations” (EPA

- 453/R

- 97

- 004)

8. CARB’s RACT/BARCT guidance titled, “Organic Solvent Cleaning and Degreasing Operations” (July 18, 1991)

9. South Coast Air Quality Management District Rule 1171 ,“Solvent Cleaning Operations”

10. South Coast Air Quality Management District Rules 1124, “Aerospace Assembly and Component Manufacturing Operations”

11. Yolo

- Solano Air Quality Management District Rule 2.31, “Solvent Cleaning and Degreasing”

12. San Joaquin Valley Unified Air Pollution Control Di strict Rule 4663, “Organic Solvent Cleaning , Storage and Disposal”

13. Sacramento

- Metropolitan Air Quality Management District Rule 466 ,”Solvent Cleaning”