UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for EPA’s Direct Final Rulemaking

for the California State Implementation Plan

YOLO

- SOLANO AIR QUALITY MANAGEMENT DISTRICT

Rule 2.31, Solvent Cleaning and Degreasing

Prepared by: Arnold Lazarus Reviewed by: Andy Steckel

August 20142

RULE IDENTIFICATION

Agency: Yolo

- Solano Air Quality Management District (YSAQMD)

SIP Approved Rule s : Rule 2.31

- Su rface Preparation and Cleanup Adopted

- April 27, 1994

Submitted

- November 30, 1994 EPA Approved

- April 02, 1999 (64 FR 15922)

Rule 2.13

- Organic Solvents Adopted

- May 24, 1994 EPA Approved

- April 30 , 199 6 (6 1 FR 18962 )

Rule 2.15

- Disposal and Evaporation of Solvents

Submitted

- June 22, 1978 EPA Approved

- January 29, 1979 ( 44 FR 5663)

Rule 2.24

- Solvent Cleaning Operations (Degreasing) Adopted

- November 14, 1990

Submitted

- May13, 1991 EPA Approved

- December 13, 1994 ( 59 FR 64130)

Subject of this TSD: Rule 2.31

- Solvent Cleaning and Degreasing

Amended

- May 8, 2013

Submitted

- February 10, 2014

R ULE SUMMARY

- YSAQMD Rule 2.31, Solvent Cleaning and Degreasing, is a rule designed to reduce volatile organic compound (VOC) emission from operations associated with solvent cleaning and degreasing.

YSAQMD Rule 2.13, Organic Solvents, is designed to redu ce VOC emission from operations associated with the use of organic solvents.

YSAQMD Rule 2.15, Disposal and Evaporation of Solvents, is designed to regulate disposal and evaporation of photochemically reactive organic solvents or compounds

into the atmos phere

YSAQMD Rule 2.24, Solvent Cleaning Operations (Degreasing), limit s VOC emission from operations associated with solvent degreasing.

Rule 2.31 has been revised from the adopted version in scope and stringency. The rule3

has been expanded to incorpor ate the concepts of R ule s 2.13, “Organic Solvents,” 2.15, “Disposal and Evaporation of Solvents,” and 2.24

, ”Solvent Cleaning Operations (Degreasing)

. ” Concurrently, Rules 2.13, 2.15 and 2.24 are being rescinded in the SIP. A new category, Aerospace Solven t Cleaning has been added to Rule 2.31. The May 8, 2013 SIP submitted version of Rule 2.31 is more stringent than the currently SIP approved rules , 2.13, 2.15

, 2.24 and 2.31

. The revised R ule 2.31 establishes VOC limits and workplace requirements for cleaning and degreasing products sold, distributed or used within the District. It also prescribes administrative requirements for recordkeeping and test methods. Major changes from the approved SIP rule include:

1. Section 101, Purpose, was revised to incl ude degreasing operations.

2. Section 102, Applicability, was revised to include anyone who sells or distributes VOC containing materials for solvent cleaning or degreasing

.

3. Sections 110 through Sections 114, Exemptions, were expanded and reorganized as follows:

a. Section 110, General, classifies certain operations that are exempt from the provisions of Rule 2.31, and reduces the size of an exempt degreaser from five gallons to one gallon which serves to strengthen the rule

. b. Sec tion 111, Solvent Requirements, is a revis ion which requires a YSAQMD permit or written exemption from the air pollution control officer (APCO) in order to be exempt ed from the r equirements of Section 301. Previously

, a person could just claim an exemption for specialized u sage which pertained to wipe cleaning. An exemption for solvents used for the cleaning of sterilization ink indicating equipment limiting usage to less than 1.5 gallons per day was also added to the rule. Permitting is also now required of these sources, which strengthens the rule by further restricting

rule exemptions.

c. Section 112, General Prohibition

, was revised to describe a limited
exempt ion from Section 301.4 for use of closed cleaning or non

- propellant spray bottl es which contain less than 16 fluid ounces.

d. Section 113, Limited Aerosol, was revised to exempt cleaning with aerosol products if they comply with size, daily usage, YSAQMD permit or written exemption from the APCO and the products comply with Californ ia Air Resources Board (CARB) regulations limiting VOC content of aerosol coatings

. e. Section 114, Aerospace Vehicle or Components, specifies exemptions to the aerospace requirements which are newly incorp orated into Rule 2.31

, Section 301.1, VOC Content Limits. The requirements for aerospace in this rule as a whole establish more stringent requirements than previously

existed in the EPA

- approved YSAQMD SIP.

4. Section 200, Definitions, was revised and expanded to include degreasing, aerospace and othe r terms to help clarify Rule 2.31 requirements

.4

5. Section 300, Standards, has been reorganized as follows:

a. Section 301, Solvent Cleaning Operations, applies to solvent cleaning operations and specifies the VOC content limits for all categories related to solvent cleaning including a new category that has been created specifically for cleaning related to aerospace vehicle or components. The other parts of Section 301 involve cleaning techniques, application equipment cleanup and general prohibition. The VOC limits are more stringent in all categories compared to the SIP approved rule and

, except for Lithographic, Letterpress a nd Ultraviolet (except screen printing)

, match the limits in South Coast 1171

. The printing solvent limits have been lowered from 900 g/l and 800 g/l for Lithographic, Letterpress operations and Ultraviolet (except screen printing) to 238 g/l. Aerospace s olvent cleaning is limited to 200 g/l or 45 mmHg and identical

to South Coast Rule 1124

– Aerospace Assemble and Component Manufacturing Operations.

b. Section 302, Solvent Degreasing Operations, establishes operational requirements for solvent degreasers

. c. Section 303, Cold Cleaner Requirements, establishes operational requirements for the use of “cold cleaners” which include but are not limited to temperature, solvent drainage, placement, cover specifications and methodology.

d. Section 304, Op en Top Vapor Degreaser Requirements, establishes operational requirements for the use of Open Top Vapor Degreasers (OTVG) which specify design requirements, usage, temperature, technique, placement, cover specifications, safety procedures and solvent

recovery. OTVG re q uirements were not part of SIP approved Rule 2.31.

e. Section 305, Airless/Airtight Cleaning System Requirem ents, establishes

r equirement s for the operation, solvents pract ice and gauge necessity for an airless/airtight cleaning s ystem (AACS)

. This provision is new to Rule

2.31. Cleaning occurs in a closed system so no VOCs should be released during, before or a fter a cleaning operation. The specifications for the

AACS are found in Section 200 Definitions and are identical to the approved SIP for San Joaquin Valley Unified APCD Rule 4462.

f. Section 306, Remote Reservoir Cold Cleaner Requirements, establishes

r equirements for the use of a Cold Cleaner equipped with a Remote

Reservoir

. g. Section 307, Storage and Disposal

, m akes small revisions to clarify the requirements for storage and disposal of solvents. It lowers the disposal

limits of all materials containing VOCs to zero evaporation into the atmosphere with the exception of filling or emptying into normally closed

leak

- proof containers. Previously

, there was a limit of 1 1⁄2 gallons per day

in Rule 2.15 , so t his strengthen s the SIP

. h. Section 308, E mission Control System (ECS) , allows the use of an alternative to the methods and systems of Sections 301 through Sections 307 providing it meets the performance standards of a capture efficiency of ≥ 90% of the emissions generated by the surface preparati on and5 cleanup and one of the following. 1. The control device has a control efficiency of ≥ 95% by weight, or

2. The VOC Emission System has an output of < 50 parts per million by weight calculated as carbon with no dilution.

i

. Conveyori zed Degreasers, a category previously regulated by Rule 2.24,

is no t addressed in Rule 2.31

. YSAQMD has clarified that “there are currently no conveyori zed degreasers and there are no sources planning

to construct one in the District .” 1

6. Section 400, Administrative Requirements, has been added to Rule 2.31. It prohibits anyone from specifying any solvents use and cleanup that would result in a violation of Rule 2.31; specifies informational directives to sellers and

distributors of solvents conta ining VOC content; and describes an Operation and Maintenance Plan with permit requirements to any person using an Emission Control System pursuant to Section 308 of Rule 2.31.

7. Section 500, Monitoring a nd Records, has been revised and reorganized as

fo llows:

a. Sections 501 Record Keeping

– General addresses general record keeping and record maintenance

. b. Section 502 Emission Control System (ECS) , formerly “ Test Methods,”

addresses the recordkeeping of ECS (Section 308).

c. Section 503 Burden of Proof , a new addition to the Rule

, specifies the

records needed for exemptions as verification to an APCO.

d. Section 504 Record Retention specifies how long a perso n must keep

records and make the m availab le to the APCO

.

8. Section 600, Test Methods and Calculations, is a new section, replacing the SIP version which was Section 502, Test Methods. This section updates test

methods for VOC content and includes calculations of VOC Content and VOC composite partial pressure and determination of “c apture efficiency” and “control efficiency.” The determination of VOC from Spray Gun Cleaning Systems is also

described in Section 600.

EPA EVALUATION CRITERIA

– 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 evaluat e compliance with the CAA §110(a)(2)(A) requirement for enforceability.

1 C ommunication from M. Ehrhardt, P.E.

, Executive Director, YSAQMD

, to A. Steckel, Chief , Rulemaking Office, EPA Region 9, Octobe r 23, 2014.6

2. Stringency

- Rule 2.31 was partially evaluated against EPA’s Control Technique Guidelines (CTGs) titled, “Control of Volatile Organic Emissions from Solvent Metal Cleaning” (EPA

- 450/2

- 77

- 022, November 1977) and “ Control Technique

Guidelines for Industrial Cleaning Solvents” (EPA

- 453/R

- 06

- 001

, September 2006), “Control Technique Guidelines for Flexible Package Printing” (EPA

453/R

- 06

- 003

, September 2006 ) , “Control of Volatile Organic Compound Emissions from Coating Operations at Aerospace manufacturing and Rework Operations” (EPA

- 453/R

- 97

- 004

, December 1997 ), CARB’s RACT/BARCT guidance titled, “Organic Solvent Cleaning and Degreasing Operations” (July 18, 1991), and other stat e and local rules for this category were used to help evaluate the RACT requirements of CAA § 182(b)(2). The solvent limits and requirements were also compared to South Coast Air Quality Management District’s ( SC AQMD) Rules 1122 “Solvent Degreasers

, ” SCAQM D Rule 1124

“ Aerospace and Assembly Operations and Component Coating Operations,” and
SCAQMD Rule 1171 “Solvent Cleaning Operations”

.

3. SIP Relaxation

- We have evaluated this SIP revision to determine whether it would interfere with any applicable req uirement 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 SIP

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

The VOC limits, recordkeeping requirements and other provisions of Rule 2.31 are clear and adequately fulfil the enforceability requirements summarized in paragraph #1 above. Rule 2.31 implements RACT because it is generally as stringent as the guidelines listed in paragraph #2 above. T he submitted rule is significantly more stringent than the version of Rules 2.13, 2.15, 2.24 and 2.31 previously approved into the SIP, so the submitted rule does not relax the SIP and complies with CAA §110(l) and §193 consi stent with paragraph #3 above.

RULE DEFICIENCIES

– We have identified no deficiencies with Rule 2.31 sufficient for EPA to propose less than full approval.

EPA ACTION

The submitted rule revisions to Rule 2.31 strengthen the SIP. The rule satisfies relevant CAA §110 and part D requirements. According to the YSAQMD staff report, there will be no impact in emission reduction. EPA staff recommends full approval of Rule 2.31 pursuant to CAA §110(k) and removal from the SIP of Rules 2.13, 2.15 and 2.24.

EPA RECOMMENDATIONS

The following revision is not currently the basis for rule disapproval but is recommended

for the next time the rule is amended.7

1. Lower the VOC content limit for Ultraviolet (UV) (except screen printing) in

Section 301.1 VOC Content Limits, Table 1 to 100 grams/liter

, consistent with
South Coast AQMD Rule 1171.

R EFERENCES

1. YSAQMD Rule 2.31

, “Surface Preparation and Cleanup

, ” EPA Approved

- December 13, 1994 ( 59 FR 64130)

. 2. YSAQMD Rule 2.31, “Solvent Cleaning and Degreasing

, ” Submitted February
10, 2014.

3. YSAQMD Rule 2.13, “Organic Solvents

, ” EPA Approved

- April 30 , 199 6 (6 1 FR 18962)

. 4. YSAQMD Rule 2.15, “Disposal and Evaporation of Solvents

, ” EPA Approved

- January 29, 1979 ( 44 FR 5663)

. 5. YSAQMD Rule 2.24, “Solvent Cleaning Operations (Degreasing), ” EPA Approved

- December 13, 1994 ( 59 FR 64130)

. 6. “Control of Volatile Organic Emissions from Solvent Metal Cleaning” EPA

- 450/2

- 77

- 022

, November 1977

. 7. “Control Technique Guidelines for Industrial Cleaning Solvents” EPA

- 453/R

- 06

- 001

, September 2006

. 8. “Control Technique Guidelines for Flexible Package Printing” EPA 453/R

- 06

- 003

, September 2006

. 9. “Control of Volatile Organic Compound Emissions from Coating Operations at Aerospace manufac turing and Rework Operations” EPA

- 453/R

- 97

- 004

, December 1997

. 10. CARB’s RACT/BARCT guidance titled, “Organic Solvent Cleaning and Degreasing Operations” ( July 18, 1991 )

. 11. SCAQMD) Rule 1122, “ Solvent Degreasers,” EPA Approved

- February 8, 2006 (71 FR 6350)

. 12. SCAQMD) Rule 1124

, “ Aerospace and Assembly Operations and Component Coating Operations,” EPA Approved

- August 13, 2002 (67 FR 52611)

. 13. SCAQMD) Rule 1171, “Solvent Cleaning Operations,” EPA Approved

– September 29, 2011 (76 FR 60376)

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

15. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001 (http://ww w.epa.gov/region09/air/sips/littlebluebook2001.pdf).8