UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA ’ s Prop o sed 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- 2

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RULE IDENTIFICATION

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Agency: San Joaquin Valley Unified Air Pollution Control

District ( SJV U APCD )

SIP Approved Rule: Rule 4605

– Aerospace Assembly and Component Coating Operations

A mend ed

– Septe mber 20, 200 7
Submitted

– March 7 , 200 8 EPA Approved

– January 7, 2010 ( 75 FR 3996 )

Subject of this TSD: Rule 4605

- Aerospace Assembly and Component Coating Operations

Amended

– June 16 , 20 11

Submitted

– July 28 , 20 11

RULE SUMMARY

- Rule 4605 establishes VOC content limits and workplace

standards for industrial sites engaged in manufacturing, assembling, coating, masking, bonding, paint stripping, su rface 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 monit oring 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 i n 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 amend ment 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: A blative Coating, Bearing Coating, Calking and Smoothing Compounds, Chemical Agent

resistant Coating (CARC)

, Electromagn e tic Interference (EMI) Coating, Intermediate Release Coating, Lacquer, Metalizing Epoxy Coating, Mold Release, Part Marking Coating, Roc ket Motor Nozzle Coating, Screen
Print Ink, Silicone Insulation Material, Specialized Function Coating, Thermal Control Coating and Wet Fastener Installation Coating.

2. Added 1 7 new products in Table 1 of Section 5.1, including: Ablative, Bearing Coating, C aulking and Smoothing Compounds, Chemical Agent Resistant Coating , Electromagnetic Interference Coating, Intermediate

Re lease Coating, Lacquer, Metalized Epo xy Coating, Mold Release, Part- 3

- M arking Coating, Rocket Motor Nozzle Coating, Screen Print Ink, Sili cone Insulation Material, Specialized Function Coating, Thermal Control Coating, Epoxy Polyamide Topcoat and Wet Fastener Installation Coating. Relabeled the header “Before January 1, 2013 ” and i ncluded 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

- 45 3 / R

- 97

- 004

, December 1997 ), EPA’s CTG titled, “ Control of VOC Emissions from Solvent Metal Cleaning ” (EPA

- 45 0 / 2

- 77

- 022

, Nov ember

19 7 7) 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 de termine 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

– T he 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 , an d 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

mor e emissions than if compliant materials were utilized. The se 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

ve rsion previously approved into the SI P

. 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 e quivalent 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 on

going process for ensuring that t he 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 pr evious 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 sufficien t for EPA to propose less than full approval. As a result, w e 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 di sapproval, 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 cl ear and complete definitions:

a. For consistency with subsection 3.10, r efer 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 s ubsection 3.30 to define Wire C oating which is a n 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 a re 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 Coatin g, Electrical Radiation Coating, Electrostatic Discharge Protection, Wire Coating (unless change noted in “c”) and Pre

- B onding Etching Wire Coating.

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

- up operations to Section 4.0.

3. For consistenc y and completeness please consider making the following changes to Table 1 in Sec t ion 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 catego ry 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 Polyamid e Topcoat ”

. c. Consider expanding sub

- item “a” of item 47 to be “ E lectrical 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 d istricts have considerably lower VOC limits

than SJVAPCD’s rule 4605. Consider adopt ing the lower VOC limit s : i. High Temperature Coating

- SMAQMD’s R ule 456 has a 42 0 g/l limit compared to SJV U APCD’s 85 0 g/l.

ii. Rain Erosion Resistant Coating

– SMAQMD’s R ule 456 has a 600 g/l limit and VCAPCD ’s Rule 74.13 has a 42 0 g/l limit compared to SJV U APCD’s 800 g/l.

iii. Sealant (Extrudable/R ollable/Brushable)

- SCAQMD’s R ule 1124 has a 280 g/l limit compared to SJV U APCD’s 600 g/l.

e. Three cat egories in the CTG were not listed in the rule: Corrosive Prevention Compound, Cryoprotective Coating and Insulation Covering. T he District has confirmed both that these specialty coatings are not in use at this time, and that the more stringent general ca tegory 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.- 6

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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 m ay 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 Se ptember 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. SJV U APCD Rule 4605, Aerospace Assembly and Component Coating Operations, as submitted on July 28, 2011

. 2. SJV U APCD 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,” EPA

450/2

- 77

- 022, Nov ember 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)” SJV U APCD, 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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