UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for EPA’s Proposed Rulemaking

for the California State Implementation Plan

Imperial County Air Pollution Control District , Rule 4 25 , Aerospace Coating Operations

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

January

, 201 12

RULE IDENTIFICATION

-

Agency: Imperial County Air Pollution Control District ( ICAPC D)

SIP Approved Rule: Rule 4 25

– Aerospace Coating Operations Adopted

– May 18, 2004 ; Submitted

– July 1 9

, 2004 EPA Approved

– May 19, 2005 ( 70 FR 28826 )

Subject of this TSD: Rule 425

– Aerospace Coating Operations

A dopt ed

– February 23, 2010 ; Submitted

– July 20,

2010

RULE SUMMARY

- Rule 4 25 , Aerospace Coating Operations, is a rule designed to reduce VOC emissions at industrial sites engaged in coating airplanes, space craft and their
component parts. VOCs are emitted during the preparation and coating of the parts, as well as the drying phase of the coating process. The provisions of this rule apply to any person who applies, specifies the use of, or supplies coatings for the surface preparation and coating of metal parts. Section A defines the Applicability of the rule, including exemptions and the ROC limit table. Section B covers requirements, including storage, disposal

, transfer efficiency and maximum quantities and vapor pressure of solvents, the ROC limit for maskants and strippers, application methods and cleaning methods of electrostatic spray gun cleaning. Section C outlines the recordkeeping requirements, reporting schedule and content. Finally, Section D indicates the test methods necessary for this coating operation. Changes from the approved SIP rule include:

1. In section A.4

, the reference to deleted Section A.3c, was removed.

2. The references to non

- existent subsections of A.2 were removed.

3. Record retention denoted in Section C.2 was increased from two to five

years.

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 ( Guidance Document for Correcting Common VOC & Other Rule

Defici encies, EPA Region 9, August 21, 2001) were used to help evaluate compliance with the CAA § 110(a)(2)(A) requirement for enforceability.

2. RACT

– EPA’s Control Technique Guideline (CTG) titled, “Surface Coating Operations at Aerospace Manufacturing & R ework Operations” (EPA

453/R

- 97

- 004, December 1997), and other state and local rules for this category were used to help evaluate the RACT requirements of CAA § 182(b)(2).3

3. SIP Relaxation

- Where previous versions of rules have been SIP approved,

new submit tals must comply with CAA §110(l) and §193 regarding SIP

relaxations.

The monitoring, recordkeeping, reporting and other requirements generally ensure

that the submitted rule can be enforced.

ICAPCD regulates a serious nonattainment area for Ozone and therefore needs reasonably achievable control technologies (RACT). However, as noted in their

RACT SIP

, “Draft 2009 Reasonably Available Control Technology State Implementation Plan,” Imperial County Air Pollution Control District, dated July 13,

201 0, no aerospace coating sources exist in the district . As a result, ICAPCD is not required to adopt RACT requirements for this source category. Nonetheless,

we have still reviewed Rule 4 25 for potential RACT issues and identified these in

the recommendat ions section below

.

The submitted rule does not relax the SIP and complies with §110(l) and §193

.

RULE DEFICIENCIES

– We have identified no deficiencies with Rule 4 25 sufficient for EPA to propose less than full approval.

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. Table 425

- 1 lists ROC limits f or various types of coatings that have not

been defined. For clarity and enforceability

, please define the following:

a. Adhesive, Structural Autoclavable

b. Adhesive, Structural E poxy

c. Adhesive, Non

- autoclavable

d. Adhesive, Elastomeric

e. Radiation

– effect Coating

f. Solid

- film Lubricant ; Fasteners and Non

- fastener lubrication

g. Dip coat

2. Table 425

- 1 lists ROC limits for coatings that are not specifically included in

the CTG

. These higher limits should be removed or justified for :

a. Adhesive, Structural Epoxy

b. Adhesive, Elastomeric

3. Section B.9 lists several application techniques that have not been defined. For clarity and enforceability, please define the following:

a. Dip coat

b. Airless spray application for use with Maskants and Temporary Protective Coatings4

4. Please verify, per the CTG Model Rule in appendix B, B.3 (b) (1) , that the airless spray application , specified in Section B.9.e, a chieves emission reductions equivalent to HVLP or electrostatic application methods.

5. To comply with the Little Bluebook reco mmendations for EPA

- approved ASTM test methods (page 13, #4) please provide the title of ASTM

Method D 2369 referenced in Section D .2 Please use only the version approved by EPA listed in 40 CFR 60.17, which is 1995 for ASTM D2369. Similarly, EPA methods, listed in Sections D.1, D.7, D.8 and D.9, should

include the full title.

6. Both ASTM D1639 and ASTM D 2306 referenced in Section D.3 an d D.4, respectively, had been withdrawn by ASTM in 2005 and 2006

, resp ec tively

, with no replacements

. EPA Method 18, Measurement of Gaseous Organic Compound Emissions by Gas Chromatography, is an approved method that replaces ASTME D 2306

.

EPA ACTION

- The submitted Rule 4 25 strengthens the SIP and the rule largely

fulfills the relevant CAA § 110 and part D requireme nts. EPA staff recommends a full approval of Rule 4 25 pursuant to CAA § 110(k ) ( 3) and § 301(a).

ATTACHMENTS

- 1. ICAPCD Rule 4 25

, Aerospace Coating Operations

, as submitted on July 20, 2010

2. ICAPCD Rule 4 5 2, Aerospace Coating Operations,

as submitted on July 1 9

, 2004 into the SIP on May 19

, 2005

.

ADDITIONAL REFERENCES

- 1. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

2. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001.

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. “Draft 2009 Reasonably Available Control Technology State Implementation Plan,” Imperial County Air Pollution Control District, July
13, 2010.