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 2013
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RULE IDENTIFICATION

Agency: Placer County Air Pollution Control District (PCAPCD)

SIP-Approved Rule: None

Subject of this TSD: Rule 240 – Surface Preparation and Cleanup

Adopted- June 8, 1995

Amended – December 11, 2003

Submitted – September 24, 2013

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 includes cleaning activities such as general solvent cleaning, 

cleaning 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 equipment 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 Rule, 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 additional reductions from this category are 

needed.

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 
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(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 240 was evaluated against EPA’s Control Technique 

Guidelines (CTG) titled, “Control Techniques Guidelines: Industrial Cleaning

Solvents” (EPA-453/R-06-001, September 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 - PCAPCD’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 solvent 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. While the Emission Control System requirements of 

section 303 do not specify equipment, they do clearly indicate the required 

parameters. The requirement for monitoring and for submitting records in section 

500 further strengthens this Rule’s enforceability. Test methods are similar to those 

in SMAQMD’s Rule 466. 

Stringency - PCAPCD’s Rule 240 is largely consistent with the EPA CTG: Industrial 

Cleaning Solvents. 
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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 for RFP and attainment of the 

National Ambient Air Quality Standards (NAAQS) are met and because the emission 

limits in the submitted Rule 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 the basis for Rule disapproval, but we encourage 

PCAPCD to consider these recommendations the next time the Rule is amended:

1. In subsection 104.3, we recommend 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 districts.

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 subsection 217, the definition of Janitorial 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 
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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 to SCAQMD Rule 1171: “..., in clean and good operating 

condition. This definition does not include the cleaning 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 Calculation for Determining VOC Composite Partial 

Pressure, please add the missing parenthesis in the numerator: 

PPc = Wn)(VPi) (the remainder of the equation is not shown)

 MWi

9. In subsection 503, Test Methods, 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 District methods:

a. 503-2 references ASTM D4457-91, Test Method for the 

Determination of Dichloromethane 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 referencing 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-Reducible Paints by Direct Injection into a Gas 

Chromatograph.
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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 staff recommends an 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. PCAPCD Rule 240 – Surface Preparation and Cleanup, amended December 

11, 2003, submitted September 21, 2012.

3. SMAQMD Rule 466 – Solvent Cleaning, amended October 28, 2010.

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