UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX AIR DIVISION

Technical Support Document

For
EPA ’ s Proposed Rulemaking

For the California State Implementation Plan

Antelope Valley Air Quality Management District , Rule 1168

,

Adhesive and Sealant Applic ations

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

May

, 201 2 2



Agency: Antelope Valley Air Quality Management District ( AV AQMD) SIP Approved Rule: South Coast Air Quality Management District
(SCAQMD) Rule 1168 , Adhesive and Sealant
Applications
Adopted

- January 7, 2005 Submitted

– April 29, 2009 EPA approved

– December 21, 2009 (74 FR 67821) Subject of this TSD: Rule 11 68

- Adhesive and Sealant Applications A dopt ed

– September 2 0 , 20 11 Submitted

– February 23

, 201 2

RULE SUMMARY

- AVAQMD Rule 11 68

, Adhesive and Sealant Applications

, is
a rule designed to limit volatile organic compound s (VOC) and to eliminate
emissions of chloroform, ethylene dichloride, methylene chloride, perchlorethylene
and trichloroethylene from the application of adhesives, adhesive primers, sealants,
sealant primers or any other primer used in commercial and industrial applications

and sales . Definitions are included in Section (B), VOC limits for appl icable general
adhesives, specialized adhesives, adhesive primers, sealants and sealant primers
are tabulated in Section (C) in addition to application methods and alternative
compliance methods . Section (D) refers to the recordkeeping pursuant to AVAQMD

R ule 109, Recordkeeping for Volatile Organic Compound Emissions

. Section s (E)
and (F) cover methods of analysis including procedur es for determining VOC

content and exempt compounds , and t est methods for determining control device
efficiency and VOC conte nt as well as viscosity and exempt compounds

. S ections
(G) and (H) explain the prohibition of specifications, sales and use of non

complying adhesives, sealants and primers. Solvents used in the application of
adhesives, sealants and primers are referred t o AVAQMD Rule 442 in Section (I)
and exemptions are listed in Section (J).

EPA EVALUATION CRITERIA

- The following criteria were used to evaluate the submitted rule. 3



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, Augu st 21, 2001) were used to evaluate compliance with the CAA §110(a)(2)(A) requirement for enforceability

.

Stringency

– EPA’s Control Technique Guidelines (CTG) titled, “Control Techniques

Guidelines for Miscellaneous Industrial Adhesives ” ( EPA

- 453/R

- 08

- 00 5 ) , dated
Sept ember 2008

, State of Ca lifornia Air Resources Board’s (CARB) “Determination of Reasonably Available Control Technology (RACT) and Best Available Retrofit Control Technology (BARCT) for Adhesives and Sealants” dated December, 1998

,
and other st ate and local rules for this category were used to help evaluate the
RACT requirements of CAA § 182( c ) ( 1 ).

Rule 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 SIP

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

EPA EVALUATION

– The following is the EPA evaluation of the rule based on previously identified criteria.

Enforceability

– Sections (D) R ecordkeeping Requirements

, (G) Prohibition of
Specifications and (F) Prohibitions of Sales and Use and other requirements of Rule

1168 generally ensure that the submitted rule is adequately clear and enforceable. Section (E) Methods of Analysis and (F) Test Methods provide the basis for

evaluating the VOC content in order to keep accurate records and determine the
VOC content, exempt comp ound content and control device efficiency to realize the
enforceability of the rule.

Stringency

- We believe Rule 11 68 generally meets RACT

. Overall, it is as stringent
as, and in some cases, more stringent than the 2008 CTG

. The only exception is

the P lastic Solvent Welding (PVC) limit of 500 grams per liter which is slightly

higher than the RACT 510 grams per limit. Rule 1168 is also generally as stringent 4



as, and in some cases, more stringent than CARB’s 1998 “Determination of RACT

and BARCT for Adhesives and Sealants ”

. The exceptions are :

 Metal to Urethane/Rubber Molding or Casting for whic h CARB has 250
grams per liter limit . AVAQMD Rule 1168 has a limit of 850 grams per liter
which corresponds to the CTG limit.

 Sheet Rubber Lining Instal lation for which CARB has 250 grams per liter
limit. AVAQMD Rule 1168 has a limit of 850 grams per liter which
corresponds to the CTG limit.

 Perimeter Bonded Sheet Vinyl for which CARB has 100 grams per liter limit.

AVAQMD Rule 1168 has a limit of 660 grams per liter which corresponds to

the CTG limit.

 Automotive Glass Adhesi ve Primers for which CARB has 700 grams per liter

limit

. AVAQMD Rule 1168 has a limit of 900 grams per liter which
corresponds to the CTG limit.

The Metal to Ure thane/Rubber Mo lding or Casting, Sheet Rubber Lining Installation

and Perimeter Bonded Sheet Vinyl category limits are considered by CARB to be
technology forcing. In addition, t he BARCT requirements exceed what is required for

this district as adopted by the California Air Resources Board (CARB).

SIP Relaxation

- The submitted is a new addition to the SIP, strengthening the requirements of the SIP. Therefore, w e propose to determine that our approval of the submittal would comply with CAA § 110(l) and § 193 regarding SIP relaxation because the submitted SIP rule ensures VOC emissions equivalent to or greater than those of the applicable SIP rule for the area, South Coast Air Quality Management District (SCAQMD) Rule 1168 as adopted in 2005. In addition, for all categories, the rule limits are less than or equal to those limits in the CTG.

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. Please consider making the following revisions to the definitions in section (B):

a. In subsection (2), Adhesive, please rem ove the term Adhesive Bonding Primer as this category is not used in the rule

. 5

 b. Subsection (3), Adhesive Bonding Pr i mer, should be deleted as this category is not used in the rule.

c. In subsection (36), Grams of VOC per Liter of Adhesive, Less Water and Less Exempt Compounds, please add the term “or sealant” after Adhesives in the equation since this equation is for adhesives and sealants. d. In subsection (50), Motor Vehicle Glass Bending Adhesive Primer, please delete th e word “Adhesive” in the title since that is not a category in Table 1 and since the word, adhesive, is even excluded in the definition.

e. In subsection (78), Sheet Rubber Lining Installation Adhesive, please preface the definition, which presently is for t he process of

s heet r ub ber lining installation, with “A dhesive used in ...” f. In subsection (91), Tire Repair Adhesive, please replace the definition, which presently is for the process of tire repair, with “Adhesive used after expanding of a hole, tear, fissure or blemish in a tire casing by grinding or gouging and filling the hole or crevice with rubber.” 2. For clarity, revise subsection (C) ( 5 ) (g) to read “Such other Adhesive applicati on methods as are demonstrated to the APCO Officer to be capable of achieving a transfer efficiency no less efficiency that is equal to or greater than that of the HVLP method and for which prior written approval of the APCO has been obtained; or” 3. To avoid conflict with (C) (6), please consider adding a caveat to subsection (C) (7): A Person may comply with the provision of subsection (C) (1) and subsection (C) (2) by means of an Alternative Emission Control Plan pursuant to District Rule 108, Alternative Emission Control Plans , except for the 20% emission reduction requirements which are not in compliance with the 85% reduction using the approved air pollution control equipment described in (C) (6)

. 4. Per T

he Little Blue Book

, in Section s (E) , Methods of Analysis and (F) Test Methods please provide titles and EPA approved dates for all ASTM methods and all other state or local methods.

a. In subsection (E) (1) use: i. ASTM D2369

- 95, Standard Test Method for Volatile Content of Coatings

. ii. SCAQMD Method 304

- 91, De termination of Volatile Organic Compounds in Various Materials, February 1996

. iii. Consider adding Appendix A of 4 0 CFR 63, subpart PPPP for VOC R eactive Adhesives for Plastic P arts

. b. In subsection (E) (2) use: i. SCAQMD Method 302

- 91, Distillation of Solvents f or Paints, Coatings and Ink, February 1993. ii. SCAQMD Method 303

- 91, Determination of Exempt Compounds, August 1996

. 6

 iii. ASTM D4475

- 85 (91), Test method for Determination of Dichloromethane and 1, 1, 1

- Trichloroethane in Paints and Coatings by Direct Injection Int o a Gas Chromatograph

. c. In subsection (E) (3) use: i. SCAQMD Method 316A

- 92, Determination of Volatile Organic Compounds in Materials Used f or Pipes and Fittings , October 1996. d. In subsection (E) (4) use: i. SCAQMD Method 316B

- 97, Determination of Volatile Organic Compounds in Adhesives Co n taining Cyanoacrylates 1996.

e. In sub section (F)(1) use: i. CARB Method 422, Exempt Halogenated Volatile Organic Compounds in Gases , September 12, 1990

. ii. SCAQMD Method 25.1, Determination of Total Gaseous Non

- Methane Organic Emissions as Carbon, February 1991

. iii. SCAQMD Method 25.3, Determination of Low Concentration Non

- Methane Non

- Ethane Organic Emissions From Clean Fueled Combustion Sources, March 2000

. f. In sub section (F) (2) use: i. ASTM D1084

- 08, Standard Test Methods for Viscosity of Adh esives. 5. Section (I) indicates that any adhesive, sealant, adhesive or Sealant application, operation of person which is exempt from this rule shall comply with the applicable provisions of district Rule 442, Usage of Solvents. Rule 442 only regulates solve nts so it is not likely that any part of it, e x cept solvents, will apply to the exempt adhesives and sealants. For clarity, Refer to Rule 442 for solvent use applicable to adhesives and sealants. 6. Adhesives used in tire repair are exempt in subsection (J) ( 1) (a). However t his specific type of adhesive has an assigned VOC limit in subsection (C) (1). This seems contradictory and the intent is not clear.

EPA ACTION

- Rule 1168 fulfills the relevant CAA §110 and part D requirements. EPA staff recommends a full approval of Rule 1168 pursuant to CAA §110(k) (3) and §301(a).

ATTACHMENT S

-

1. AV AQMD Rule 11 68

, Adhesive and Sealant Applications

, Amended September 20, 2011. 7



ADDITIONAL REFERENCES

–

1. EPA’s Control Technique Guidelines (CTG) titled, “ Control Techniques

Guidelines for Miscellaneous Industrial Adhesives” EPA

- 453/R

- 08

- 005,
September 2008.
http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200809_voc_epa453_r

- 08

- 005_miscellaneous_industrial_adhesives.pdf

2. State of California Air Re sources Board’s (CARB) “Determination of
Reasonably Available Control Technology (RACT) and Best Available Retrofit Control Technology (BARCT) for Adhesives and Sealants” dated December,

1998 http://www.arb.ca.gov/ractbarc/adhfinal.pdf
3. “ Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations, ” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988

. http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf 4. “ Guidance Document for Correcting Common VOC & Other Rule Deficiencies, ” (a.k.a., Little Bluebook), EPA Region 9, Augu st 21, 2001

. http://www.epa.gov/Region09/air/sips/littlebluebook2001.pdf 5. SCAQMD Rule 1168, Adhesive and Sealant Applications, Amended January 7, 2005 http://www.aqmd.gov/rules/reg/reg11/r1168.pdf 6. AVAQMD Rule 108, Alternative Emission Control Plans, Amended May 17, 2005http://www.avaqmd.ca.gov/Modules/ShowDocument.aspx?documenti d=905 7. AVAQMD Rule 109, Recordkeeping For Volatile Organic Compound Emissions, Amended April 20, 2010 http://www.avaqmd.ca.gov/Modules/ShowDocument.aspx?documentid=90 6 8. AVAQMD Rule 442 , Usage of Solvents, Amended November 15, 2005 http://www.avaqmd.ca.gov/Modules/ShowDocument.aspx?documentid=85 4