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 Quali ty Management District, Rule 466

, Solvent Cleaning

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

July 201 12

RULE IDENTIFICATION

-

Agency: Sacramento Metropolitan Air Quality Management

District ( SMAQMD )

SIP Approved Rule: Rule 466

– Solvent Cleaning Adopted

- May 23, 2002

A mend ed

– September 25, 2008

Submitted

– September 15, 2009 EPA Approved

– May 5, 2010 ( 7 5 FR 24406)

Subject of this TSD: Rule 46 6

– Solvent Cleaning

A mend ed

– October 28, 2010

Submitted

– April 5, 2011

BACKGROUND

– SMAQMD Rule 466 Solvent Cleaning was a dopt ed 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 46 6

, S olvent 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 f or 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 Tech nical 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 fo r enforceability3

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 nonattainme nt area, any SIP

approved control requirement in effect before November 15, 1990 (CAA § 193).

Enforceability

– The monitoring, recordkeeping, reporting and other requirements

of S M AQMD’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 min imi s level representing less t han 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 clean ing 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 t h e Staff R eport

, 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 o perations

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

will be no real environmental impact.

Therefore, w e propose to determine that our approval of the submittal would comply with CAA § 110(l), because the proposed SIP revis ion 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 4 66 sufficient for EPA to propose less than full approval.4

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 cla rity, 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 Sep tember 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. S MAQMD Rule 46 6

, Solvent Cleaning , as submitted on April 5, 20 11

. 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. “Gui dance 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,” EPA

453/R

- 06

- 001, September 2006. http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200609_voc_epa453_r

- 06

- 001_ind_cleaning_solvents.pdf