UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Proposed Rulemaking

for the

California State Implementation Plan

Sacramento Metropolitan Air Quality Management District, Rule 466, Solvent 

Cleaning

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

July 2011
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RULE IDENTIFICATION -

Agency: Sacramento Metropolitan Air Quality Management 

District (SMAQMD)

SIP Approved Rule: Rule 466 – Solvent Cleaning 

Adopted - May 23, 2002

Amended – September 25, 2008

Submitted – September 15, 2009

EPA Approved – May 5, 2010 (75 FR 24406)

Subject of this TSD: Rule 466 – Solvent Cleaning

Amended – October 28, 2010

Submitted – April 5, 2011

BACKGROUND – SMAQMD Rule 466 Solvent Cleaning was adopted in 2002 to 

regulate solvent cleaning activities not already covered in district rules. The rule 

establishes VOC content limits, lists acceptable cleaning operations, defines 

storage and disposal practices and describes emission control equipment. 

Additionally, the rule establishes administrative requirements including 

recordkeeping, a compliance schedule, an operation and maintenance plan and 

test methods.

RULE SUMMARY SMAQMD Rule 466, Solvent Cleaning, is a rule designed to 

limit volatile organic compound (VOC) emissions from solvent cleaning 

operations and activities, as well as from the storage and disposal of cleaning 

solvents. The rule describes related administrative requirements for 

recordkeeping and VOC content calculations. The changes to the rule are 

mainly to provide an exemption from the sterilization methods for dry food 

products: 

1. Definitions for Low-moisture Food and Water Activity were added.

2. The exemption for sanitizing products which are labeled and applied to 

food-contact surfaces that are used to process dry and low-moisture food 

products was added.

3. FDA Inspection Technical Guide no. 39 was added as the test method for 

the determination of water activity in foods. 

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 

Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate 

compliance with the CAA §110(a)(2)(A) requirement for enforceability
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2. Stringency – Rule 466 was partially evaluated against EPA’s “Control 

Techniques Guidelines for Industrial Cleaning Solvents” (EPA-453/R-06-

001 September 2006), CARB’s RACT/BARCT guidance titled, “Organic 

Solvent Cleaning and Degreasing Operations” (July 18, 1991), 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 the Act (CAA §110(l)) or modify, in a nonattainment area, any SIPapproved control requirement in effect before November 15, 1990 (CAA 

§193).

Enforceability – The monitoring, recordkeeping, reporting and other requirements 

of SMAQMD’s Rule 466 generally ensure that the submitted rule can be enforced. 

Stringency - The requirements of the rule meet the stringency of the CTGs and 

RACT/BARCT guidance. The solvent cleaning activity, sterilization of food 

manufacturing and processing equipment, is a new category for which there is no 

limit in either the CTGs or the CARB guidance. However, the loss of VOC 

emissions is a de minimis level representing less than 1% of the emission 

reductions for solvent cleaning operations. In addition, these emissions will be 

more than offset by other emission limits in the rule that are more stringent than 

the CTG and RACT/BARCT guidance.

Relaxation – The new solvent cleaning activity category, sterilization of food 

manufacturing and processing equipment, has a VOC limit of 200 g/l. This

represents a relaxation from the general solvent cleaning category limit of 25 g/l. 

However, on page 6 of the Staff Report, the District states that the proposed 

amendment will result in total theoretical lost VOC emissions reduction of only 

0.005 tons per day, which seems de minimis in light of the District’s overall VOC 

emission reductions of 0.711 tons per day from all solvent cleaning operations.

Also, since the VOC limit for this category was infeasible and never enforced, there 

will be no real environmental impact. 

Therefore, we propose to determine that our approval of the submittal would 

comply with CAA § 110(l), because the proposed SIP revision would not interfere

with the on-going process for ensuring that requirements for reasonable further 

progress (RFP) and attainment of the NAAQS are met.

 

RULE DEFICIENCIES – We have identified no deficiencies with Rule 466

sufficient for EPA to propose less than full approval. 
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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. For clarity, please delete those exemptions in subsection 110.2.a and 

110.2.g that have expired. 

2. For clarity, please specify what the cleaning of spray gun nozzles will entail 

after the September 25, 2009 date indicated in subsection 302.6.

EPA ACTION - The submitted Rule 466 will incorporate provisions on solvent 

cleaning operations into the SIP. The rule fulfils the relevant CAA §110 and part 

D requirements. EPA staff recommends approval of Rule 466 pursuant to CAA

§110(k)(3).

REFERENCES –

1. SMAQMD Rule 466, Solvent Cleaning, as submitted on April 5, 2011.

2. SMAQMD Rule 466, Solvent Cleaning, as submitted on September 15, 

2009.

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

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

4. “Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001. 

5. “Organic Solvent Cleaning and Degreasing Operations,” CARB, July 18, 

1991.and other state and local rules for this category were used to help 

evaluate the RACT requirements of CAA §182(b)(2). 

6. “Control Techniques Guidelines for Industrial Cleaning Solvents,” EPA453/R-06-001, September 2006. 

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200609_voc_epa453_r-06-

001_ind_cleaning_solvents.pdf