UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX AIR DIVISION

Technical Support Document for EPA’s Direct Final Rulemaking for the California State Implementation Plan

Ventura County Air Pollution Control District , Rule 74.13, Aerospace Assembly and Component Manufacturing Operations

Prepared by Nancy Levin, April 7, 20141 RULE IDENTIFICATION

Agency: Ventura County Air Pollution Control District (VCAP CD)

SIP-Approved Rule: Rule 74.13, Aerospace Assembly and Component Manufacturing Operations; Adopted – 4/15/86; Revise d 10/13/87, 1/22/91, 9/ 10/96, 11/11/03; Submitted – 4/26/05; Approved – 10/25/2005 (70 FR 6156)

Subject of this TSD: Rule 74.13, Aerospace Assembly and Component Manufacturing Operations; Amended – 9/11/12; Submitted – 4/22/13

RULE SUMMARY - Rule 74.13 establishes reactive organic compound (ROC) limits for industrial sites engaged in the manufacturing, assembling, coating, ma sking, bonding, paint stripping, and surfac e cleaning of aerospace co mponents and the cleanup of equipment associate with these operations. It also describes related recordkeeping requirement s and test methods.

This rule does not apply to coating or cleaning of metal parts, includ ing tooling operations, which are covered by Rule 74.12. Ventura County APCD Rule 74.12 "Surface Coating of Metal Parts and Products" was approved into the St ate Implementation Plan (SIP) on May 24, 2011 (76 FR 30025).

Changes from the approved SIP rule include the following:

1. Section B.2 – This section's name was cha nged from “Surface and Ge neral Cleaning” to "Solvent Cleaning” to be consiste nt with the definition in VC 74.6 1 "Surface Cleaning and Degreasing". 2. Section B.2.b.2 – This section reduces the li mit for the composite partial pressure of solvent cleaners from 45 to 5mm Hg at 20 o C. It requires solvent cl eaners to be less than 5mm Hg at 20 o C or limits the ROG content to 25 grams per liter or less. 3. Section B.4 – This section changed the requirements for “Storage of ROC Containing Materials,” making them more enforceab le and consistent with VC Rule 74.12. 2

4. Section B.5.e – This section added a requirement that if a spray gun is used, the user shall demonstrate that it meets the definition of high volume low pressure (HVLP) (section G.27) in design and use. It requires HVLP equipment to be identified by test air cap measurements or an inlet pressure meas urement as specified in section G.27. 5. Section B.5.f

– This section was changed by dele ting the requirement for other application methods to demonstrate achieveme nt of 65% transfer efficiency. Rather, it allows for any other alternative method that ac hieves a transfer effi ciency “equivalent to, or higher than one of the application methods listed” in sections B.5.a through B.5.e. It requires prior written approval of the APCO for each alternative method. Section E.6 specifies the South Coast Air Quality Management District test method to determine transfer efficiency.

1 VC 74.6 was adopted on 11/11/03 and approved by EPA on 10/25/2005 (70 FR 61561).

2 VC 74.12 was adopted on 4/8/08 and approved by EPA on 5/24/11 (76 FR 30025).2 6. Section B.6 – Clarified that wr itten approval in the form of an Authority to Construct and Permit to Operate is required for usi ng the “Add-on Control Equipment Option.” 7. Section B.10 – Requires that the ROG content of low-solids adhesives, coatings, primers or sealants in section B.1 be expressed in grams/liter of material. 8. Section C.2 – Exemptions were revised. 9. Section D – Recordkeeping was reformatted and reworded to be consistent with VC Rule 74.12 3

10. Section E – Test Methods were updated. 11. Section G – Definitions were added for “Captu re Efficiency,” “Degreaser,” “Low-Solids Adhesive, Coating, Primer or Sealant,” a nd “Solvent Cleaning.” Changes to other definitions increased their specificity. Definitions were renumbered.

RULE EVALUATION CRITERIA - We primarily used the following criteria to evaluate the submitted rule:

1. Enforceability – Section 110(a)(2)(A) of the Clean Air Act (CAA) requires that regulations submitted to EPA for incorporati on into the SIP must be clear and legally enforceable. The Bluebook ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations , EPA, May 25, 1988) and the Little Bluebook ( Guidance Document for Correcting Comm on VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001) were used to he lp evaluate compliance with the CAA §110(a)(2)(A) requirement for enforceability.

2. Stringency – CAA section 172(c )(1) specifies that SIPs fo r nonattainment areas must include reasonably available control tec hnology (RACT) for sources of emissions. Section 182(b)(2) specifically provides that for nonattainment areas classified as moderate or worse, states mu st revise their SIP to incl ude RACT for sources of VOC emissions covered by a Control Techniques Guidelines (CTG) document issued after November 15, 1990 and prior to the area’s date of attainment.

3. Non-interference – CAA §110(l) prohibits EP A from approving any SIP revision that would interfere with any applicable requirement concerning attainment and reasonable further progress (RFP) or any othe r applicable requireme nt of the CAA.

The VCAPCD regulates an area that is classified as nona ttainment (serious ) for the 1997 and 2008 8-hour Ozone standards.

We used EPA’s CTGs titled Control of Volatile Organic Co mpound Emissions from Coating Operations at Aerospace Manufacturing an d Rework Operations (EPA-453/R-97-004, December 1997) (hereinafter “A erospace CTG”) and 40 C.F.R. 63 Subpart GG – National Emission Standards for Aerospace Manufacturing an d Rework Facilities (her einafter "Aerospace NESHAP") to evaluate this rule. In addition, we reviewed other state and local rules for this source category.

3 Ibid.3 RULE EVALUATION

1. Enforceability – The recordkeeping requirements for coatings and control system parameters, test methods and other requirem ents generally ensure that the submitted rule can be enforced. They include records of usage of compliant and noncompliant materials, records of key operating parameters and records for those claiming an exemption for de minimis usage. Therefore, we propose to determine that submitted Rule 74.13 is sufficiently clear and enforceable.

2. Stringency – The VCAPCD has stated that sources subj ect to this rule in the District are below the CTG's threshold of 25 tons per ye ar potential to emit and therefore, are not subject to RACT. 4 However, while VCAPCD has st ated that these sources are not subject to RACT and its demonstration seem s sufficient, based on our review of the Aerospace CTG, Aerospace NESHAP, and other state and local rules for this source category, we believe Rule 74.13 could be fu rther strengthened. Please see “Additional Recommendations” for details.

3. Non-interference - We believe the submitted rule is more stringent than the version previously approved into the SIP, and theref ore this rule would not interfere with any applicable requirement concerning attainme nt and reasonable further progress (RFP) or any other applicable requirement of the CAA.

RULE DEFICIENCIES – We have not identified deficiencies in submitted Rule 74.13 sufficient for EPA to propose less than full approval.

ADDITIONAL RECOMMENDATIONS FO R THE NEXT RULE REVISION – The following revisions are not currently the basis fo r rule disapproval, but are recommended for the next time the rule is amended. If, in the futu re, existing sources become major sources of VOC emissions, or new sources locate in the District, the District will n eed to amend the rule to meet RACT requirements. In particular, Rule 74.13 does not contain limits for all the Aerospace CTG categories. In addition, the exemptions in the ru le appear to be less stringent than in the Aerospace CTG Appendix B: Aerospace Manufactur ing and Rework Operations Model Rule (Model Rule).

Add VOC categories and coating limits

The VOC limit table of Rule 74.13 does not include the following specialty coating categories that are provided in the CTG. Rule 74.13 should be updated to include the following categories and limits updated to meet current RACT leve ls the next time the rule is amended.

1. Ablative Coating

4 Draft Ventura County Air Pollution Control District 2014 Reasonably Available Control Technology (RACT) State Implementation Plan (SIP) Revision April 2, 2014, pp. 32-33.4 2. Commercial Interior Adhesive 3. Cyanoacrylate Adhesive 4. Rocket Motor Bonding Adhesive 5. Rubber-based Adhesive 6. Bearing Coating 7. Caulking and Smoothing Compounds 8. Chemical Agent-Resistant Coating 9. Clear Coating 10. Commercial Exterior Aer odynamic Structure Primer 11. Compatible Substrate Primer 12. Corrosion Prevention Compound 13. Cryogenic Flexible Primer 14. Cryoprotective Coating 15. Electrostatic Discharge and Electromagnetic Interference (EMI) Coating 16. Elevated-Temperature Skydrol-R esistant Commercial Primer 17. Epoxy Polyamide Topcoat 18. Flexible Primer 19. Insulation Covering 20. Intermediate Release Coating 21. Lacquer 22. Bonding Maskant 23. Critical Use and Line Sealer Maskant 24. Seal Coat Maskant 25. Metalized Epoxy Coating 26. Mold Release 27. Part Marking Coating 28. Rocket Motor Nozzle Coating 29. Screen Print Ink 30. Extrudable/Rollable/Brushable Sealant 31. Sprayable Sealant 32. Silicone Insulation Material 33. Specialized Function Coating 34. Thermal Control Coating 35. Wet Fastener Installation Coating

Clarify or Revise Exemptions

1. Rule 74.13 allows an exemption when “No comp lying coating or adhesive is available,” which is not provided for in the CTG. Please clarify the criteria used to make this determination (e.g., not available within the District v. not sold in the U.S.).

2. The model rule contained in the Aerospace CTG allows an exemption for facilities that use separate formulations of coatings in volumes of less th an 50 gallons per year, subject to a maximum exemption of 200 gallons per year. Rule 74.13 includes a maximum exemption of 200 gallons for facilities that us e separate formulations of coatings in volumes of less than 20 gallons per year . However, Rule 74.13 appears to allow5 unlimited use of separate formulations of a dhesives in volumes of less than 10 gallons. When the rule is revised, we recommend that the District clarify how these exemptions are at least as stringent as the model rule, or revise the rule to be at least as stringent as

the model rule.

EPA ACTION - EPA staff recommends approval of Rule 74.13 pursuant to CAA §110(k) (4) and §301(a).

REFERENCES

1. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988 (http://www.epa.gov/ttn/naaqs/ozon e/ozonetech/voc_bluebook.pdf). 2. “Guidance Document for Corre cting Common VOC & Other Ru le Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001 ( http://www.epa.gov/region09/ air/sips/littlebluebook2001.pdf ) 3. State Implementation Plans; General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990, 57 FR 13498 (April 16, 1992); 57 FR 18070 (April 28, 1992). 4. CTG for Control of Volatile Organic Compounds (VOC) from Coating at Aerospace Manufacturing and Rework Facil ities EPA-453/R-97-004, December 1997 5. 40 C.F.R. 63 Subpart GG – National Emission Standards for Aerospace Manufacturing and Rework Facilities 6. VCAPCD Rule 74.13 – Aerospace Assembly a nd Component Manufacturing Operations, September 11, 2012. 7. VCAPCD Rule 74.13 – Aerospace Assembly a nd Component Manufacturing Operations, as approved into the SIP on October 25, 2005 (70 FR 6156).