UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Proposed Rulemaking

for the

California State Implementation Plan

San Joaquin Valley Unified Air Pollution Control District, Rule 4605, 

Aerospace Assembly and Component Coating Operations

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

August 2011
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RULE IDENTIFICATION -

Agency: San Joaquin Valley Unified Air Pollution Control 

District (SJVUAPCD)

SIP Approved Rule: Rule 4605 – Aerospace Assembly and Component 

Coating Operations

Amended – September 20, 2007

Submitted – March 7, 2008

EPA Approved – January 7, 2010 (75 FR 3996)

Subject of this TSD: Rule 4605 - Aerospace Assembly and Component 

Coating Operations

Amended – June 16, 2011

Submitted – July 28, 2011

RULE SUMMARY - Rule 4605 establishes VOC content limits and workplace 

standards for industrial sites engaged in manufacturing, assembling, coating, 

masking, bonding, paint stripping, surface cleaning, service, and maintenance of 

aerospace components, the cleanup of equipment, and the storage and disposal 

of solvents and waste solvent materials associated with these operations. It also 

describes related recordkeeping, reporting, and monitoring requirements.

On January 7, 2010, EPA issued a limited approval/limited disapproval of 

SJVUAPCD Rule 4605. EPA identified the following rule deficiencies which 

prevented full approval: Rule 4605 does not include 17 of the specialty coating 

limits in the CTG and has higher limits for two other specialty coatings listed in 

the CTG. EPA’s limited approval/limited disapproval action started sanctions 

clocks under section 179 of the Clean Air Act and 40 CFR 52.31. Unless EPA 

approves a subsequent SIP revision which corrects the deficiencies, offset 

sanctions would become effective August 6, 2011, and highway sanctions would 

become effective February 6, 2012. 

The purpose of the June 2011 rule amendment is to correct deficiencies 

identified by EPA in the January 7, 2010 (75 FR 3996) final rulemaking on the 

previous version of this rule. Changes from the approved SIP rule include:

1. Added new definitions in Section 3.0 including those for: Ablative Coating, 

Bearing Coating, Calking and Smoothing Compounds, Chemical Agentresistant Coating (CARC), Electromagnetic Interference (EMI) Coating, 

Intermediate Release Coating, Lacquer, Metalizing Epoxy Coating, Mold 

Release, Part Marking Coating, Rocket Motor Nozzle Coating, Screen 

Print Ink, Silicone Insulation Material, Specialized Function Coating, 

Thermal Control Coating and Wet Fastener Installation Coating.

2. Added 17 new products in Table 1 of Section 5.1, including: Ablative, 

Bearing Coating, Caulking and Smoothing Compounds, Chemical Agent 

Resistant Coating, Electromagnetic Interference Coating, Intermediate 

Release Coating, Lacquer, Metalized Epoxy Coating, Mold Release, Part 
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Marking Coating, Rocket Motor Nozzle Coating, Screen Print Ink, Silicone 

Insulation Material, Specialized Function Coating, Thermal Control 

Coating, Epoxy Polyamide Topcoat and Wet Fastener Installation Coating. 

Relabeled the header “Before January 1, 2013” and included a column for 

VOC limits effective after January 1, 2013. Footnotes were added 

exempting Department of Defense coatings used on space vehicles.

3. Lowered the VOC limits for 2 products of Table 1 of Section 5.1 including 

Fastener Sealants and Sealant (Extrudable/Rollable/Brushable), effective 

January 1, 2013.

EPA EVALUATION - The following criteria and guidance documents were used 

to evaluate the submitted rule. 

1. Enforceability - The “Bluebook” (Issues Relating to VOC Regulation 

Cutpoints, Deficiencies, and Deviations and Clarification to Appendix D (52 

FR 45044 November 24, 1978); the “Little Bluebook” (Guidance Document 

for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, 

August 21, 2001), and State Implementation Plans, General Preamble for 

the Implementation of Title I of the Clean Air Amendments of 1990 (57 FR 

13498, April 16, 1992) were used to help evaluate compliance with the 

CAA §110(a)(2)(A) requirement for enforceability. 

2. Stringency – EPA’s Control Technique Guideline (CTG) titled, “Surface 

Coating Operations at Aerospace Manufacturing & Rework Operations”

(EPA-453/R-97-004, December 1997), EPA’s CTG titled, “Control of VOC 

Emissions from Solvent Metal Cleaning” (EPA-450/2-77-022, November 

1977) SJVAPCD’s 2009 RACT SIP Demonstration (April 16, 2009), and 

other state and local rules for this category were used to help 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 

CAA §110(l) or modify any SIP-approved control requirement in effect 

before November 15, 1990 (CAA §193).

Enforceability – The recordkeeping of coatings and control system parameters, test 

methods and other requirements generally ensure that the submitted rule can be 

enforced. 

Stringency –The CTG “Surface Coating Operations at Aerospace Manufacturing & 

Rework Operations” (EPA-453/R-97-004, December 1997) contains EPA’s most 

recent identification of national presumptive RACT for this industry. The VOC 

limits in amended Rule 4605 are as or more stringent than the VOC limits in this 

CTG, and we are not aware of significantly more stringent requirements in other 

analogous regulations. . 
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Rule 4605 identifies solvent VOC content limits or a control system with

efficiencies of at least 90% capture and 95% control, and that would not allow 

more emissions than if compliant materials were utilized. These efficiencies 

exceed those of the CTG “Control of VOC Emissions from Solvent Metal 

Cleaning”. 

Based on this and on information provided in SJVUAPCD’s 2009 RACT SIP 

analysis, we believe that SJVUAPCD has adequately demonstrated that this rule 

implements fulfills CAA RACT requirements.

Relaxation - Because the seventeen coating categories were added and VOC 

limits for two categories are reduced, the submitted rule is more stringent than the 

version previously approved into the SIP. We propose to determine that our 

approval of the submittal would comply with CAA §193 because the submitted SIP 

revision is more stringent than the rule previously partially approved into the SIP 

and would ensure equivalent or greater emission reductions of VOCs. We propose 

to determine that our approval of the submittal would also comply with CAA §110 

and part D requirements, because the SIP revision would not interfere with the ongoing process for ensuring that the requirements for RFP and attainment of the 

NAAQS are met, and the submitted SIP revision is more stringent than the rule 

previously approved into the SIP.

RULE DEFICIENCIES – Our January 2010 final rule identified the following 

deficiencies with the previous version of this rule:

“Table 1 of Rule 4605 does not include 17 of the specialty VOC coating limits 

provided in the CTG and has a higher limit for two other specialty limits listed in 

the CTG. SJVAPCD has not demonstrated that any of the CTG limits are 

infeasible in San Joaquin or otherwise adequately demonstrated that Rule 4605 

implements RACT consistent with CAA §182 (b)(2).” 

The 17 missing categories, with limits equal to the CTG limits, have been added 

to Table 1.The district has also lowered the limits for the two categories, Fastener 

Sealants and Sealant (Extrudable/Rollable/Brushable) that exceeded the CTG 

limits, also effective January, 1, 2013.

We have identified no other deficiencies with Rule 4605 sufficient for EPA to 

propose less than full approval. As a result, we believe relief from sanctions 

should be provided as quickly as possible.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION - The 

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

recommended for the next time the rule is amended. 

1. Please consider making the following editorial changes in Section 3.0 to 

provide clear and complete definitions:

a. For consistency with subsection 3.10, refer to Rule 1020 

(Definitions) for the definition of ARB in subsection 3.11.
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b. Remove “a” in the beginning of the definition of “Caulking and 

Smoothing Compounds” in subsection 3.16 as this definition is for 

the plural “materials”.

c. Revise subsection 3.30 to define Wire Coating which is an

application for both electrical and electronic wire and is consistent 

with the category in Table 1 of Section 5.0. 

d. In subsection 3.31, please correct the statement so that “the 

electrostatic applications are operated at a minimum 60 kV voltage. 

e. For consistency with the definition in the CTG, please change 

“component” to “components” in the definition of Non-structural 

Adhesive in subsection 3.55.

f. For thoroughness, please add definitions for the following terms 

used in the rule: Epoxy Polyamide Coating, Electrical Radiation 

Coating, Electrostatic Discharge Protection, Wire Coating (unless 

change noted in “c”) and Pre-Bonding Etching Wire Coating.

2. For consistency with the CTG exemptions, consider adding touch-up 

operations to Section 4.0.

3. For consistency and completeness please consider making the following 

changes to Table 1 in Section 5.0:

a. The staff report indicates that this rule applies to sprayable sealant 

but only “extrudable/rollable/brushable” sealant is indicated in item 

35. Please add a category for sprayable sealant in Table 1 or 

remove this category from the staff report.

b. For consistency with the definition and with the CTG, please revise 

the category in item 43 as “Epoxy Polyamide Topcoat”.

c. Consider expanding sub-item “a” of item 47 to be “Electrical and

Electronic” as it is likely both types of wiring will require coating.

d. The District has noted that the emission inventory for the source 

category of Aerospace Assembly and Component Coating 

Operations is 0.02 tons per day. Nevertheless, there are three

instances where other districts have considerably lower VOC limits 

than SJVAPCD’s rule 4605. Consider adopting the lower VOC limits:

i. High Temperature Coating - SMAQMD’s Rule 456 has a 420 

g/l limit compared to SJVUAPCD’s 850 g/l.

ii. Rain Erosion Resistant Coating – SMAQMD’s Rule 456 has a 

600 g/l limit and VCAPCD’s Rule 74.13 has a 420 g/l limit 

compared to SJVUAPCD’s 800 g/l.

iii. Sealant (Extrudable/Rollable/Brushable) - SCAQMD’s Rule 

1124 has a 280 g/l limit compared to SJVUAPCD’s 600 g/l.

e. Three categories in the CTG were not listed in the rule: Corrosive 

Prevention Compound, Cryoprotective Coating and Insulation 

Covering. The District has confirmed both that these specialty 

coatings are not in use at this time, and that the more stringent 

general category limit would be applied to any source which uses 

these specialty coatings. 1 

 

1 Email from Sami Sheikh (SJVUAQMD) to Andrew Steckel (EPA) dated 8-9-2011.
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4. In section 6.0, per the requirement of the Little Bluebook (page 13), 

references to EPA-approved state or local (i.e. district) methods should 

include the full title but may or may not specify the date of the version:

a. In Subsection 6.2.1, provide the title for ARB Method 432, 

“Determination of Dichloromethane and 1, 1, 1-Trichloroethane in 

Paints and Coatings.” (EPA approved date is September 12, 1989)

b. In Subsection 6.2.2, correct the title for ASTM Method D1613 to 

(Standard Test Method....)

c. In Subsection 6.2.6, provide the title for ARB Method 422,

“Determination of Volatile Organic Compounds in Emissions from 

Stationary Sources.” (EPA approved date is September 12, 1990)

EPA ACTION - The submitted changes to Rule 4605 adequately correct 

deficiencies identified by the limited disapproval on the previous version of this 

rule and otherwise fulfill the relevant CAA criteria.

2 As a result, EPA staff 

recommends a full approval of Rule 4605 pursuant to CAA §110(k) (3) and 

§301(a). 

REFERENCES –

1. SJVUAPCD Rule 4605, Aerospace Assembly and Component Coating 

Operations, as submitted on July 28, 2011.

2. SJVUAPCD Rule 4605, Aerospace Assembly and Component Coating 

Operations, as approved into the SIP on March 7, 2008. 

3. “Surface Coating Operations at Aerospace Manufacturing & Rework 

Operations,” EPA-453/R-97-004, December 1997. 

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/199712_voc_epa453_r-97-

004_aerospace_rework.pdf

4. “Control of Volatile Organic Emissions from Solvent Metal Cleaning,” EPA450/2-77-022, November 1977.

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/197711_voc_epa450_2-77-

022_solvent_metal_cleaning.pdf

5. “Reasonably Available Control Technology (RACT) Demonstration for 

Ozone State Implementation Plans (SIP)” SJVUAPCD, April 16, 2009.

6. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and 

Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

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.

 

2 Technical Support Document (TSD), June, 2009 and 75 FR 3996.
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