UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX AIR DIVISION

Technical Support Document

for EPA’s Direct Final Rulemaking

for the California State Implementation Plan

Placer County Air Pollution Control District,

Rule 240 , Surface Preparation and Cleanup

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

November 201 3 2



RULE IDENTIFICATION

Agency: Placer County Air Pollution Control District ( P C APCD)
SIP

- Approved Rule: None Subject of this TSD: Rule 240
– Surface Preparation and Clean up Adopted

- June 8, 1995
Amended
– December 11 , 20 03 Submitted
– September 24 , 201 3

RULE SUMMARY
– PCAPCD Rule 240 currently regulates solvent cleaning activities from manufacturing , repair, maintenance and coating application operations that are not specifically regulated by other District rules. It has never been approved by EPA into the State Implementation Plan (SIP). The proposed rule include s cleaning activities such as general solvent cleaning,
cleani ng of electrical apparatus and electronic components, cleaning of medical and pharmaceutical devices, repair and maintenance cleaning and architectural coating application equipment cleaning. It applies to servicing parts, products, tools, machinery and eq uipment and the storage and disposal of materials used in solvent cleaning. The Sacramento Region has been designated as a severe nonattainment area for the federal ozone standard by the EPA. According to the District’s staff report
associated with this R ule , as part of the legal mandates resulting from this classification, the District committed to reduce the Volatile Organic Compounds (VOC) for this category by 2.33 tons per day. The Proposed Rule 240 does not
meet this milestone , so it appears that addi tional reductions from this category are needed. EPA EVALUATION

- The following criteria were used to evaluate the submitted
R ule:
1. Enforceability

- The Bluebook ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations , EPA, May 25, 1988) and the Little Bluebook 3

 ( Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluat e compliance with the CAA §110(a)(2)(A) requirement for enforceability.

2. Stringency

- Rule 240 was evaluated against EPA’s Control Technique Guidelines (CTG) titled, “Control Techniques Guidelines: Industrial Cleaning
Solvents ” (EPA

- 45 3 / R

- 06

- 001 , Sept ember 2006 ) to evaluate the RACT requirements of CAA § 182(b)(2).

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).

RULE EVALUATION Enforceability

- P CAPCD ’s Rule 240 specifies clear, unambiguous terminology that closely resembles the definitions of SMAQMD Rule 466, Solvent Cleaning, SCAQMD
Rule 1171 , Solvent Cleaning Operations and SJVUAPCD Rule 4663, Organic Solvent Cleaning, Storage, and Disposal. Each type of solve nt cleaning activity is described in section 200 and distinguished from other categories that are clearly
delineated in the limits table in section 301. Cleaning devices and methods are clearly described in section 302. Whil e the Emission Control System r equirements of
section 303 do not specify equipment, they do clearly indicate the required parameters. Th e requirement for monitoring and for submitting records in section
500 further strengt hens this R ule’s enforceability

. Test methods are similar to thos e in SMAQMD’s Rule 466

.

Stringency

- P CAPC D’s Rule 240 is largely consistent with the EPA CTG: Industrial Cleaning Solvents. 4



Relaxation

- Since there is no version of Rule 240 in the SIP, SIP approval would strengthen the SIP by regulating a previously unregulated stationary source category

. Therefore, we propose to determine that our approval of the submittal would comply
with CAA § § 110(l) and 193 because the proposed rule will not interfere with the ongoing process for ensuring that the requirements f or RFP and attainment of the National Ambient Air Quality Standards (NAAQS) are met and because the em ission
limits in the submitted R ule are more stringent than any existing SIP

- approved control requirements for these sources in the SIP

.

RULE DEFICIENCIES
– We have identified no deficiencies in submitted Rule 240’s
VOC limits to justify less than full approval . They are consistent with the CTG.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION
– The following revisions are not currently th e basis for R ule disapproval, but we encourage PCAPCD to consider these recommendations the next time the R u le is amended:

1. In subsection 104.3, w e r ecommend that the term “this rule” be replaced with “section 301.2” in order to have application methods, recordkeeping and other work practices applicable to these exempt operations

. 2. Please revise the limit specified in 104.3.1 from 50 grams/liter to 25 grams/liter so that it is similar to rules adopted in other district s

. 3. Please remove subsection 104.3. 6 as this exemption in the analogous SMAQMD Rule 466 has expired.
4. In subsection 213, the definition of Exempt Compounds, consider referring to 40 CFR § 51.100 instead of Rule 102.
5. In sub section 2 1 7 , the definition of Janito rial Cleaning, consider expanding the terminology to match that of SMAQMD Rule 466 : “The cleaning of building or facility components, such as the floor, ceiling, wall, windows, doors, stairs, bathrooms, furnishings and exterior surfaces of office equipment and excludes 5

 the cleaning of work areas where manufacturing or repair activity is performed

. ”
6. In subsection 220, the definition of Maintenance Cleaning, consider adding
the following caveat t o SCAQMD Rule 1171 : “..., in clea n and good operating
condition. This definition does not include the clean ing of coatings , adhesives or ink application equipment.”
7. For clarity, please delete those limits in subsection 301.1 that have expired. The VOC limits are consistently higher than other Districts’ for these categories. EPA suggests that, as applicable, VOC limits that resemble those of SMAQMD Rule 466 , effective 9/25/2009, be adopted.
8. In subsection 403, the C alc ula tion for Determining VOC Composi te Partial Pressure, please add the missing parenthesis in the numerator:
PP c =  W n ) ( VP i ) (the remainder of the equation is not shown)

MW i 9. In subsection 503, Test M ethods, please adhere to the Little Bluebook recommendation to include title and EPA approved date of all ASTM methods
and full title of EPA

- approved State or D istrict methods:

a. 503

- 2 references ASTM D4457

- 91, Test Method for the
Determination of Dichlorome thane and 1,1, 1

- Trichloroethane in Paints and Coatings by Direct Injection into a Gas Chromatograph and ARB Method 432, Determination of Dichloromethane and 1,1,1

- Trichloroethane in Paints and Coatings adopted September 12, 1989.
Please consider also refe rencing SCAQMD Method 303

- 91, Determination of Exempt Compounds, February 1993 which is used in SCAQMD Rule 1171.
b. 503

- 3 references ASTM E260

- 96, General Gas Chromatography Procedures and ASTM D3792

- 91, Standard Test Method for Water
Content of Water

- Reduc ible Paints by Direct Injection into a Gas Chromatograph. 6

 c. 503

- 4 references ASTM D2879

- 97 (2010 is approved too), Test Method for Vapor Pressure

- Temperature Relationship and Initial Recomposition Temperature of Liquids by Isoteniscope

.

EPA ACTION

- EPA st aff recomm ends a n approval of Rule 240 pursuant to CAA §110(k) (4) and §301(a).

ADDITIONAL REFERENCES
– 1. PCAPCD Rule 240
– Surface Preparation and Cleanup, amended October 9, 1997.
2. P CAPCD Rule 240
– S urface Preparation and Cleanup, amended December 11, 2003, submitt ed September 21 , 201 2.
3. SMAQM D Rule 466
– Solvent Cleaning , amend ed Octo ber 2 8 , 201 0.
4. SCAQMD Rule 1171
– Solvent Cleaning Operations, amended May 1, 2009.
5. SJVUAPCD Rule 4663
– Organic Solvent Cleaning, Storage and Disposal, Amended September 20, 2007.
6. Control Techniques Guidelines (CTG): Industrial Cleaning Solvents, EPA
435/R

- 06

- 001, September, 2006. http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200609_voc_epa453_r

- 06

- 001_ind_cleaning_solvents.pdf
7. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001. http://www.epa.gov/Region09/air/sips/littlebluebook2001.pdf