SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

APPENDIX E: Rule Consistency Analysis September 20, 2007

E

- 1 Final Staff Report with Appendices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules 

# APPENDIX E

RULE CONSISTENCY ANALYSIS FOR THE SOLVENT CLEANING

PORTION OF ELEVEN DISTRICT RULES

SEPTEMBER 20, 2007SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

APPENDIX E: Rule Consistency Analysis September 20, 2007

E

- 2 Final Staff Report with Appendices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules RULE CONSISTENCY ANALYSIS

I. REQUIREMENTS FOR RULE CONSISTENCY ANALYSIS

Prior to adopting, amending, or repealing a rule or regulation, California Health and Safety Code Section 40727.2 requires that District staff perform a written analysis that identifies and compares the air pollution control elements of the proposed rule with the corresponding elements of existing or propo sed District and United States Environmental Protection Agency (EPA) rules, regulations, and guidelines that apply to the affected source category. The elements that were analyzed are emission limits; work practices; monitoring and testing; and recordkeep ing and reporting requirements. The analysis is detailed in Section II of this report. Conclusions based on the analysis

are shown in Section III.

II. RULE CONSISTENCY ANALYSIS

District staff reviewed EPA rules, regulations, and guidelines, as well as District rules for the source categories covered by the eleven District rules in this rule project. The analysis was confined to those provisions that refer to solvent cleaning for the particular source category. Emission limits, operating parameters, m onitoring, testing, records, and reporting requirements from processes other than solvent cleaning associated with the source category were ignored for purposes of the rule consistency analysis.

A. Existing or Proposed District Rules

There is only one District rule that has solvent cleaning requirements that is not part of this rule project

– Rule 4602 ( Motor Vehicle and Mobile Equipment Coating Operations). The provisions of this rule will no longer be in force as of January 1, 2009, so District staff chose not to change any requirements in this rule. It should be noted that Rule 4602 will be superseded by Rule 4612 ( Motor Vehicle and Mobile Equipment Coating Operations

Phase II) on and after January 1, 2009. Rule 4612 is being amended as part of th is current rulemaking project to incorporate the provisions of solvent cleaning operations.

B. Existing or Proposed Federal Rules, Regulations, and Guidelines

1. Control Techniques Guidelines (CTGs)

There are five CTGs that have solvent cleaning provisi ons. These applicable CTG are

listed in Table 1.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

APPENDIX E: Rule Consistency Analysis September 20, 2007

E

- 3 Final Staff Report with Appendices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules Table 1

– CTGs Having Solvent Cleaning Provisions

CTG Number

CTG Title Operation Covered

EPA

- 450/2

- 77

- 022 Control of Volatile Organic Emissions from Solvent Metal Cleaning Facilities that use a degreaser to clean

EPA

- 453/R

- 97

- 004 Control of Volatile Organic Compound Emissions from Coating Operations at Aerospace Manufacturing and Rework Operations Facilities that have coating operations for aerospace manufacturing and rework

EPA

- 453/R

- 06

- 001

Control Tec hniques for Industrial Cleaning Solvents Cleaning with solvent in industrial settings

EPA

- 453/R

- 06

- 002 Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing Lithographic and letterpress printing

EPA

- 453/R

- 06

- 003

Control Techniques Guidelines for Flexible Package Printing Flexible packaging printing

The CTG for solvent metal cleaning relates to degreasers. Rule 4662 addresses these units. Because this CTG was approved in 1977, all of the requirements related to

solvent degreasers have been incorporated into Rule 4662 by previous rule projects.

The CTG for cleaning in industrial settings recommends a general VOC content limit of 50 g/L with some exceptions, mostly for cleaning of printing equipment. This rule project i ncorporates a VOC content of 25 g/L for most cleaning operations, which is

lower than the CTG

- recommended content limit.

The CTG for offset lithographic/letterpress printing and the CTG for flexible packaging printing contain work practices for minimizi ng emissions from solvent cleaning, but no specific VOC content limit. The work practice recommended by the CTG is already contained in the solvent cleaning portion of Rule 4607 (Graphic Arts), the District rule that covers printing operations. Therefore , solvent cleaning portion of Rule 4607 does not conflict with the two CTGs related to printing.

2. New Source Performance Standards (NSPS)

NSPS requirements are organized by source category in 40 CFR Part 60. The District has incorporated the NSPS by r eference, meaning that District Rule 4001 lists all of the NSPSs and the requirements of these NSPSs have been adopted without change the District. District Rule 4001 lists 71 NSPSs. None of these NSPSs has solvent cleaning as part of its requirements. Therefore, this rule project is neither inconsistent with nor conflicts with any requirement of an NSPS.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

APPENDIX E: Rule Consistency Analysis September 20, 2007

E

- 4 Final Staff Report with Appendices for Proposed Amendments and Revised Proposed Amendments

to the Solvent Cleaning Portion of Eleven District Rules 3. National Emission Standards for Hazardous Air Pollutants (NESHAPs)

NESHAPs are requirements contained in 40 CFR 61 and 40 CFR 63. As with the

NSP Ss, the District has incorporated the requirements of the NESHAPS into its rules and District Rule 4002. There are no NESHAPs in 40 CFR 61 with solvent cleaning requirements. Table 2 lists the NESHAPs from 40 CFR 63 with solvent cleaning provisions. Of the NESHAPs in Table 2, 40 CFR 63 Subpart T applies to District Rule 4663 for solvent degreasers. The District rules that apply to the source categories for the remaining NESHAPs all have solvent cleaning requirements in District Rule 4662 (Organic Solven t Cleaning), which is the general solvent

- cleaning rule.

Table 2

– NESHAPs Having Solvent Cleaning Provisions

40 CFR 63 Subpart: Source Category

T Halogenated Solvent Cleaning

GG Aerospace Manufacturing and Rework

WW Boat Manufacturing

- Resin and Gel C oat Application Equipment Cleaning Operations

III Flexible Polyurethane Foam Production

In complying with the District rules for the above source categories, there is no conflict

with NESHAP.

III. RESULTS OF RULE CONSISTENCY ANALYSIS

District staff fo und that facilities could comply with the proposed amendments to the solvent cleaning portions of the eleven District rules as well as all other existing or proposed District rules. Furthermore, District staff found that none of the proposed requirements of for this rule project would conflict with federal rules, regulations, or policies covering similar stationary sources.