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 2014
2

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 - Surface Preparation and Clean-Up

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 are 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 instructions to store in a closed condition.” SCAPCD Rule 3.14 was approved by 

EPA into the State Implementation Plan (SIP) on May 3, 1982. In 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 3.14 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

RULE SUMMARY - FRAQMD Rule 3.14, Surface Preparation and Clean-Up (SP&CU), 

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

associated with surface preparation, clean-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 The 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, YoloSolano 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 applicable 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 

guidelines 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 strengthens 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 Sacramento 

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 

approval 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.

REFERENCES

1. FRAQMD Rule 3.14 - Surface Preparation and Clean-Up, 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 Techniques Guidelines for Industrial Cleaning Solvents” (EPA-453/R-06-

001 September 2006)

6. “Control Technique Guidelines for Flexible Package Printing” (EPA 453/R-06-

003, September 2006)

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

 

3

Ibid.

4

Ibid.
5

Aerospace Manufacturing 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 District Rule 4663, “Organic 

Solvent Cleaning, Storage and Disposal”

13. Sacramento-Metropolitan Air Quality Management District Rule 466,”Solvent 

Cleaning”