UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX AIR DIVISION

Technical Support Document

For EPA ’ s Direct Final Rulemaking

For the California State Implementation Plan

Northern Sierra Air Quality Management District , Rule 228

, Surface Coating of Metal Parts and Products

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

Dec ember, 201 1 2



Agency: Northern Sierra Air Quality Management District ( NS AQMD)

Superseded Submittals: A dopt ed

– November 27, 2006 Submitted

– March 7, 2008 Amended

- February 22, 2010 Submitted

- July 20, 2010

Subject of this TSD: Rule 2 28

- Surface Coating of Metal Parts and Products Amended

– April 25, 2011 Submitted

– September 27

, 201 1

RULE SUMMARY

- NSAQMD Rule 228

, Surface Coating of Metal Parts and

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

from the application of coatings, surface preparation materials, and cleanup
materials in metal parts and products coating operations. As st ated in Section 1.1, it
applies to portions of the Northern Sierra Air Quality Management District (NSAQMD) that are designated as non

- attainment for federal ambient air quality
standards for ozone per 40 CFR 81.305. Exemptions in Section 1.2 include total
coating use that do es not exceed the 2.7 tons per rolling 12

- month period, touch

up and repair coatings with the exception of VOC limits and work practices

, coatings for which other rules exist, coatings whose usage does not exceed the 55
gallon per rolling 12

- month period limit and strippers used for cured coatings . VOC
limits for the applicable coating materials are indicated in Section 3.1 and alternate

limits with add

- on controls a re listed in Section 3.2. Work p ractices are outlined in

Section 3. 4 and 3.5, recordkeeping requirements are stipulated in Section 4.2 an d

test methods are listed in Section 5.0.

EPA EVALUATION

- 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 evaluate compliance with the CAA §110(a)(2)(A) requirement for enforceability 3



2. Stringency

– EPA’s Control Technique Guidelines (CTG) titled, “Control

Techniques for Miscellaneous Metal and Plastic Parts Coatings” (EPA

453/R

- 08

- 003 , September 2008 ) and other state and local rules for this

category , including SCAQMD’s Rule 1107, Coating of Metal Parts and

Products, were used to help evaluate the RACT requirements of CAA
§ 182( c )( 1 ).

3. Rule Relaxation

– CAA §110(l) and §193 restrict SIP revisions that interfere

with attainment or other provisions of the Act.

Enforceability

- The test ing, recordkeeping, monitor ing and other rule requirements
generally ensure that the submitted rule can be enforced.

Stringency

– Rule 228 is generally as stringent as the relevant CTGs and analogous
rules in other nonattainment areas that we have approved as RACT (73 FR
70883). The 2011 staff report states that this rule has no effect on emissions.

Rule Relaxation

- Since no previous version of these requirements is already in the
SIP, approval of this version only improves the SIP and does not relax the SIP in
violation of CAA section 110(l) or 193.

EPA ACTION

- EPA staff recommends a full approval of Rule 228 pursuant to CAA §110(k) (4) and §301(a).

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION

–
The following revisions are not currently the basis for rule disapproval, but are recommended for th e next time the rule is amended:

1. Section 1.1 stipulates that this rule only regulates those portions of the District that are in nonattainment for any federal ambient air quality standard for ozone. We suggest that t his rule regulate all sources of VOCs in metal coating operations in the District in accordance with CAA § 182(b ) ( 2 ) ( C)

, for equity in the District and to o btain additional VOC emission reductions that may help the nonattainment areas. If the District requires separate rules for attainment and nonattainment areas, refer to 40 CFR 81, section 305 to specify which regions are regulated by this rule. 4



2. Please consider removing Section 1.2.6 and establishing VOC content limits for st r ippers such as c ontained in SCAQMD Rule 1107 , Section (c) (3).

3. The air dried VOC limits for Prefab Architectural Multi

- Component and Prefab Architectural One

- Component categories listed in Section 3.1 are consistent with the CTG values. However, SCAQMD’s rule 1107 has lower values for these categories, effective 7

- 01

- 2007. Please consider adopting these lower limits

.

4. The capture efficiency and control efficiency minimum of 90% required in Section 3.2.2 se ems to be consistent with the overall efficiency of 90% suggest ed by the CTG. However, p lease consider clarifying the criteria in Section 3.2.2 to

, “In lieu of complying with VOC content limits specified in Subsection 3.1 or the emission rate limitation in 3.2.1, air pollution control equipment with an overall efficiency of 90% may be used ...” O verall efficiency is defined as the product of capture efficiency and control efficiency

.

5. The work practices in Section 3.4 basically exempts the application of the work practices at facilities using control equipment as defined in Section 3.2.2. The CTG recommends that the work practices be applied to all control options, including that which includes add

- on controls affording a 90% overall efficiency. We suggest applying the work practices for solvent cleaning to those facilities that opt for the add

- on control method s defined in Section 3.2.2.

6. Please consider the following minor changes:

a. Change “does” to “do” in Section 1.2.1: “...VOC emissions (excluding
exempt compounds) from all coatings do es not exceed 2.7 tons...”

b. For consistency, a dd definitions in Section 2.0 for Airless Spray and

Air

- assisted Airless Spray which are listed in Section 3

. 3

.

c. For clarity, provide the correct titles of ASTM E169 which is entitled “Standard Practices f or General Techniques of Infrared Quantities Analysis”.

EPA ACTION

- EPA staff recommends a full approval of Rule 228 pursuant to CAA §110(k) (4) and §301(a).

ADDITIONAL REFERENCES

– 1. NSAQMD Rule 228, Surface Coating of Metal Parts and Products, as submitted on April 25, 2011. 5



2. NS AQMD Rule 228

, Surface Coating of Metal Parts and Products , as adopted on November 27, 2006

.

3. “Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts
Coating,” EPA

- 453/R

- 08

- 003, September 2008.
http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200809_voc_epa453_r

- 08

- 003_misc_metal_plasticparts_coating.pdf

4. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf

5. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001.

http://www.epa.gov/region9/air/sips/littlebluebook2001.pdf