UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX AIR DIVISION

Technical Support Document

for EPA’s Direct Final Rulemaking

for the California State Implementation Plan

San ta Barbara County Air Pollution Control District,

Rule 33 0 , Surface Coating of Metal Parts and Products

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

Sept ember 201 3- 2

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RULE IDENTIFICATION

Agency: San ta Barbara County Air Pollution Control District (S BC APCD)

SIP

- Approved Rule: Rule 33 0 – Surface Coating of Metal Parts and Products A dopt ed – J anuary 20 , 2000 Submitted – March 28, 2001 Approved – June 8 , 200 1 ( 6 5 FR 36349 )

Subject of this TSD: Rule 33 0

- Surface Coating of Metal Parts and Products Amended – June 21 , 201 2 Submitted – September 21 , 201 2

RULE SUMMARY

- Rule 33 0 establishes reactive organic content (R OC ) limits and workplace standards for industrial sites engaged in the use, application and solicitation of coating a nd solvents used for metal parts and products , including the cleanup of equipment, and the storage and disposal of waste coating and solvent materials associated with these sites . It also describes related recordkeeping, reporting, and monitoring requirements. Changes from the approved SIP r ule include the following: 1. Section A, Applicability: This section was expanded to include “...any person who manufactures any metal part or metal product coating for use within the District.” The applicability to “any person who specifies the use of any metal part coating..” was increas ed to “any person who solicits...” and the solvents applicable to metal parts or products coating was added to the applicable products. 2. Section B, Exemptions: Sev eral exemptions have been added or amended which are included in analogous rules for South Coast Air Quality- 3

- Management District (SCAQMD), San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) and Bay Area Air Quality Management District (BA AQMD) with the exception of subsection B.11 d, e and g which exempts the solvent cleaning of various specialized procedures from the 25 grams/liter VOC limit indicated in Section J for cleaning of parts assemblies or subassemblies exposed to strong oxidize rs or reducers, cleaning of transparencies or glass substrates and cleaning or stripping of coating overspray from personal protective equipment. These exemption s are deemed
necessary for safe operating procedures. Section 12 was also added to allow the us e of low

- VOC (less than 20 grams/liter) coatings. 3. Several n ew definitions were added in Section C. A ll definitions are either defined in the Control Techniques Guideline (CTG) 1 or in the district’s SIP

approved Rule 102, Definitions

. The only exception to this is the definition for High Volume Low Pressure Spraying which was deleted in this revision although i t remains an acceptable application method. 4. The ROC limits in Section D are similar to or lower than those in the CTG. However , this rule does not a ddress the specific categories indicated in the CT G. Instead, only limits for Air

- dried and Baked Non

- powder Coatings, Non

powder Air

- dried Extreme Performance and Electric

- insulating Coatings and Powder Coatings are specified. The se f ive categories are co nsistent with the CTG’s General One Component, Gener al Two Component Air

- dried and Baked Coating VOC limits and Extreme Performance and Electric Insulation Air

- dried Coating VOC limits

. The CTG does not have a limit for powder coating since “...no VOCs are released during the application operation, and volatile emissions from the curing operation, if any, are generally much less than the volatile emissions from liquid coating systems.” Thes e limit values are equal or less than those of SJVUAPCD Rule 4603 Surface Coating of Metal Parts and Products, Plastic Parts and Products and Pleasure Crafts ,

1 . CTG for Miscellaneous Metal and Plastic Parts Coatings – EPA

- 453/R

- 08

- 003 , September 2008- 4

- BAAQMD Rule 8

- 19, Surface Preparation and Coating of Miscellaneous Metal Parts and Products and S CAQMD Rule 1107, Coating of Metal Parts and Products

. One exception is the SCAQMD limit for one

- component general air

dried coating which is 275 grams/liter , slightly lower than the 340 grams/liter of this rule . In addition, the overall efficiency specifie d in this section is 85.5% which is slightly lower than the 90% recommended in the CTG. 5. Section E, Application Equipment had only minor changes

. We note that High volume, low pressure spraying has been retained in subsection 4 , b ut this method has been del eted from the definitions in section C. Additionally, t he additions to subsection 8 now allow other application methods if they are approved by the Control O fficer, California Air Reso urces Board (CARB) and the EPA. The required transfer efficiency for alt ernate ap plications was revised from “at least 65%” to “equivalent to or greater than 65%

.. . ” 6. Section F, General Operating, which had been entitled “Closed Container ” , is basically a housekeeping section . Several subsections were added to include the sele ction of application equipment, disposal of waste materials, the use of devices to reduce coating or solvent evaporation and basic handling and storage of coatings and solvent

. It is now comparable , in detail , to the Work Practices section of SJVUAPCD’s Ru le 4603. 7. Section G , Requirements – Manufacturer Labeling , had only minor, clarifying changes. The section was renamed from “Requirements
– Labeling” to “Requirements
– Manufacturer Labeling”. 8. Section H, Recordkeeping, was expanded to include more detail f or stationary source materials, records of disposal methods, usage records for compliant,

non - compliant materials, including those claiming exemptions and those operations using emission control equipment . The recordkeeping in general is now applicable to “any owner or operator of any stationary source comprised of more than one facility on a facility basis.”- 5

-

9. Section I was renamed Compliance Provisions and Test M ethods and is divided and greatly expanded according to test results, such as : reactive organic compound content, capture and control device efficiency, capture efficiency for toxic air contaminant emissions and emission control systems VOC emissions rather than by rule section as was the previous arrangement. Several more test methods have been included. 10. New sections for solvent cleaning (section J) , a compliance schedule (section K), reporting criteria for permitted facilities (section L) and requirements for solvent cleaning machines (section M) were added to rule 33 0

.

RULE EVALUATION CRITERIA

- We primarily used the following criteria to evaluate the submitted rule:

1. Enforceability

- CAA section 110(a ) ( 2 ) ( A) requires that regulations submitted to EPA for approval into a SIP must be clear and legally enforceable.

2. Rule Stringency – CAA section 172(c)(1) requires nonattainment areas to implement all reasonably available control measures (RACM), including such reductions in emissions from existing sources in the area as may be obtained through th e adoption, at a minimum, of reasonably available control technology (RACT), as expeditiously as practicable. In addition, under CAA section 182(b)(2) , ozone nonattainment areas classified as moderate or above must implement RACT for all VOC sources covered by a CTG document and all other major sources of VOCs

. The SBCAPCD regulates an area that is classified as maintenance for the 1

- hour ozone standard and is in attainment for all criteria pollutants, thus, submitted Rule 33 0 does not have to fulfill RACT requirements. 40 C.F.R. § 81.305 (2010). EPA’s CTG s titled Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coating s (EPA

- 453/R

- 08

- 003 , Sept ember 2008) herein referred to as the- 6

- “ Metal Parts Coating CTG ” , Control Techniques Guidelines for Large Appliance Coating

s (EPA

- 453/R

- 07

- 004 , Sept ember 2007), Control Techniques Guidelines for Metal Furniture Coating s (EPA

- 453/R

- 07

- 005 , Sept ember 2007) and Control Techniques Guidelines: Industrial Cleaning Solven ts (EPA

- 45 0 /R

- 06

- 0 01 , Sept ember 2006 ) cover many of the source s regulated under Rule 33 0

. 3. SIP Re laxation

- CAA section 110(l) prohibits EPA from approving any SIP revision that would interfere with any applicable requirement concerning attainment and reasonable furt her progress (RFP) or any other applicable requirement of the CAA. In addition, CAA section 193 prohibits the modification of any SIP

- approved control requirement in effect before November 15, 1990, in a nonattainment area.

In applying these criteria to t he submitted rule, we referred to the following guidance and policy documents:

 Issues Relating to VOC Regulation, Cutpoints, Deficiencies, and Deviations (the "Blue Book"), US EPA, OAQPS (May 25, 1988).

 Guidance Document for Correcting Common VOC and Other Rule Deficiencies

, EPA Region IX (August 21, 2001, the “Little Bluebook”).

 State Implementation Plans; General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990, 57 FR 13498 (April 16, 1992); 57 FR 18070 (April 28, 1992).

 EPA’s Solvent Metal Cleaning CTG. In addition, we reviewed other state and local rules for this source category.

RULE EVALUATION 1. Enforceability – The recordkeeping requirements for coatings and control system parameters, test methods and other requirement s generally ensure that the submitted rule can be enforced. They include records of usage of compliant and noncompliant materials, purchase records, records of key- 7

- operating parameters and records for those claiming an exempt status

. Therefore, we propose to determine that submitted Rule 33 0 is sufficiently clear and enforceable. 2. Stringency – The Metal Parts Coating CTG contains EPA’s most recent identification of national presumptive RACT for this industry. Since S BC APCD is in attainment, it is not required to meet RACT. Nevertheless, t he VOC limits in amended Rule 33 0 are generally as , or more , stringent than the VOC limits in this CTG, and we are not aware of significantly more stringent requirements in other analogous regulations. Rule 33 0 also i dentifies VOC content limits for solvents that are , for the most part, addressed by the Aerospace CTG. Section D

. 3 of the rule allows, as an alternative to compliance with these limits, the use of an a dd

- on control system with an overall efficienc y of at least 85.5 % exceed ing the 81% of the Aerospace CTG. In addition, compliance through use of such a control system must not result in emissions greater than the VOC emissions that would have resulted if materials in compliance with the applicable VOC limits had been used. 3. SIP Relaxation

- In addition, we believe the submitted rule is more stringent than the version previously approved into the SIP, so the submitted rule does not relax the SIP and complies with CAA §110(l) and §193.

RULE DEFICIENCIES – We have identified no deficiencies in submitted Rule 33 0 sufficient for EPA to propose less than full approval.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION – The following revisions are not currently the basis for rule disapproval, but are

re commended for the next time the rule is amended: 1. The definition for High Volume Low Pressure Spraying in Section C, Definitions, was removed in this rule’s current revision. Since this remains an- 8

- accepted application method in subsection E

- 4, we recommend reinstating this definition. 2. The coating categories indicated in subsection D

- 1 are very general and may be problematic if other categories are introduced into the district. In fact, although the limits are analogous to the general categories of the CTG f or Miscellaneous Metal and Plastic Parts Coating s , the air

- dried general one and multi

- component categories in the CTGs for both the CTG for Large Appliance Coating s and the CTG for Metal Furniture Coatings have a lower limit of 275 grams/liter. We recomme nd that categories similar to that of the CTG for Miscellaneous Metal and Plastic Parts Coatings be included and that consideration be given to lowering the limit for the air

- dried general coating category. 3. In subsection D

- 4

- a, the overall efficiency of t he total (control) system is required to be at least 85.5%. We recommend a slightly higher efficiency of 90% suggested in the CTG for Miscellaneous Metal and Plastic Parts Coating.

EPA ACTION

- EPA staff recomm ends a full approval of Rule 33 0 pursuant to CAA §110(k) (4) and §301(a).

ADDITIONAL REFERENCES

– 1. SBCAPCD Rule 33 0 – Surface Coating of Metal Parts and Products submitted September 21 , 201 2 2. SBCAPCD Rule 330 – Surface Coating of Metal Parts and Products , as approved into the SIP on January 8 , 2001

. 3. “ Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings , ” EPA

- 453/R

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- 00 3 , Sept ember 2008

. http://www.epa.gov/groundlevelozone/SIPToolkit/ctg_act/200809_voc_epa 453_r

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- 003_misc_metal_plasticparts_coating.pdf- 9

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4. “Control Techniques Guidelines for Large Appliance Coatings ,” EPA

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07

- 004 , Sept ember 2007

. http://www.epa.gov/groundlevelozone/SIPToolkit /ctg_act/200709_voc_epa 453_r

- 07

- 004_lg_appliance_coating.pdf 5. “Control Techniques Guidelines for Metal Furniture Coatings ,” EPA

- 453/R

07

- 00 5 , Sept ember 2007

. http://www.epa.gov/groundlevelozone/SIPToolkit/ctg_act/200709_voc_epa 453_r

- 07

- 005_metal_furniture_coating.pdf 6. “ Control Techniques Guidelines: Industrial Cleaning Solvents ,” EPA

- 45 3 / R

06

- 0 01, Sept ember 2006

. http://www.epa.gov/groundlevelozone/SIPToolkit/ctg_act/200609_voc_epa 453_r

- 06

- 001_ind_cleaning_solvents.pdf 7. “Issues Relating to VOC Regu lation Cutpoints, Deficiencies, and Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988. 8. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001. http://www.epa.gov/Region09/air/sips/littlebluebook2001

.