UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for EPA’s Direct Final Rulemaking

for the California State Implementation Plan

Santa Barbara County Air Pollution Control District, Rule 32 1

, Solvent Cleaning Machines and Solvent Cleaning

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

Ju ly 20112

Agency: Santa Barbara County Air Pollution Control District (S BAPC D)

SIP Approved Rule: Rule 321

– Solvent Cleaning Operations Adopted

– September 18, 1997

Submitted

– March 10, 1998 EPA Approved

– April 2, 1998 ( 64 FR 15922 )

Subject of this TSD: Rule 32 1

– Solvent Cleaning Machine s and Solvent Cleaning

Amended

– September 20, 2010

Submitted

– April 5

, 201 1

RULE SUMMARY

- Rule 321 establishes operating requirements for solvent cleaning machines and for solvent cleaning , stipulates the emission control system limits and lists the acceptable test methods. The rule also includes an Operating and Maintenance

Plan

, and R ecordkeeping and Reporting requirements

, and establishes a compliance schedule. The changes incorporated by the September 20, 2010

amendment are extensive. Some of the mo st significant changes include:

1. The title

, Solvent Clean ing Operations

, was changed to Solvent Cleaning Machines and Solvent Cleaning

. In all cases, the term “degreaser” was replaced with “solvent cleaning machine”.

2. Section A, Applicability, now include s any person who owns, operates or

uses any solvent cleaning machine or performs solvent cleaning during production, maintenance or servicing of parts, products, tools, machinery and equipment or in the general work area at any stationary source.

3. Section B, Exemptions, was expanded to include the e xemption of operations already subject to other district rules and s everal exemptions particularly targeting Raytheon’s systems. Exe mptions for small containers

have been removed.

4. S everal definitions in section C, Definitions

, were added to clarify terms used throughout the rule.

5. Section D, General Operating Requirements was expanded to include persons who own, operate or use solvent cleaning machines or performs solvent cleaning . Language was added to clarify ambiguous terminology and to address spills, f illing, draining and the use of ventilation fans.

6. Requirements for operation of a system with a vapor zone was added to section E, Additional Operating Requirements for Batch Vapor Cleaning

Machines and In

- Line Vapor Cleaning Machines.

7. Added provisions for returning drained solvent to the container, augmented the solvent agitation to describe the acceptable motion and added requirements for ventilation fan usage to Section G, General Equipment Requirements for Solvent Cleaning Machines.

8. The addition of the 50 grams/l iter Reactive Organic Compounds (ROC)

limit was added to section H, Additional Equipment Requirements for Remote Reservoir Cold Cleaning Machines, section I, Additional Equipment Requirements for Batch Cold Cleaning Machines

, and section3 K, Additional Equipment Requirements for In

- Line Cold Cleaning

Machines

. 9. The addition of the 50 grams / liter R OC limit and corresponding requirements was added to section L, Additional Equipment Requirements

for In

- Line Vapor Cleaning Machines.

10. Section M, Requirements

– Solvent Cleaning, was added and includes solvent cleaning limit Table 1, Cleaning Devices and Methods and Solvent Cleaning of Spray Application Equipment.

11. Section N, Emission Control System Requirements, was revised to include a compliance test and also to require that the emission control system result in emissions no greater than the limits allowed without controls.

12. Section P, Test Methods, was revised to further elaborate on the emission control device efficiency testing method and required results.

13. The requirements for recordkeeping were expanded in Section R, Recordkeeping Requirements, to include usage, type of machine, solvent boiling point and, for e mission control systems, the key operating
parameters.

14. Section T, Compliance Schedule, was updated to inclu de current dates for compliance, including new dates for compliance by existing facilities.

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 for enforceability.

2. Stringency

– Rule 321 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 Techniques Guidelines for Industrial Cleaning Solvents” (EPA

45 3/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 nonattainment area, any SIP

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

Enforceability

– SBAQMD’s Rule 32 1 specifies clear, unambiguous terminology

and R OC limits. Each type of solvent cle aning machi ne has been addressed in terms of drainage, usage with high and low volatility solvents, when heat is applied

, required freeboard height , etc . While the Emission Control System4

Requirements ( section N) does not specify equipment, it does clearly indicate t he required parameters. The Compliance Schedule (section T) clearly indicates the dates for full compliance for the various features of the rule. The requirement for submitting an Operation and Maintenance Plan (section Q) further strengthens

this rule’s e nforceability through procedures and recordkeeping.

Stringency

- S B AQMD’s Rule 32 1 is consistent with the EPA CTG : Industrial Cleaning Solvents and CARB’s Determination of Reasonably Available Control Technology (RACT) and Best Available Retrofit Control Technology (BARCT) Organic Solvent Cleaning and Degreasing Operations . However, it does not have as stringent R OC levels as analogous rules in other district s including Sacramento Metropolitan AQMD r ule s 1122 and 1171 and San Joaquin Valley UAPCD rules

466 1, 4662 and 4663. SBAQMD is in attainment with the national ambient air quality standards (NAAQS) and , therefore, more stringent requirements are not required at this time under national requirements for RACT ( CAA § 182(b ) ( 2)) or RACM ( CAA § 172(c ) ( 1))

.

SIP Relaxation

– SBAQMD’s Rule 32 1 now applies to any person who owns, operates or uses solvent cleaning machines or performs solvent cleaning operations which is a change from the 1992 version of the rule which only applies to any person who performs solvent cleaning. The rule has ROC limits which, compared to the current SIP rule that has no ROC limits , represents a strengthening of the rule

. In sections E through L, specific requirements for machine operation have been added that also serve to strengthen t he rule

. The staff report indicates that the proposed revisions to Rule 321 will result in about 0.5 tons per day of ROC emission reduction

.

Therefore, w e propose to determine that our approval of the submittal would comply with CAA § 110(l), because the SIP , as revis ed to reflect the submitted
revision, would provide for RFP and attainment of the NAAQS and this revision of the rule is more stringent than the rule previously approved into SIP. CAA § 1 93 does not apply to this proposed action because SBAQ M D is designated

attainment for VOC’s.

RULE DEFICIENCIES

- We have identified no deficiencies with Rule 32 1 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

recommended for the next time the rule is amended.

1. Consider reducing the solvent ROC limit to 25 grams/liter in the following

subsections: B

- 13, B

- 15 , G

- 3 , H

- 7, I

- 7, J

- 1 1, K

- 6, L

- 11

, M

- 2 and M

- 3

. This will maximize the emission reductions and provide consistency with other district rules such as those in South Coast AQMD and San Joaquin Valley

APCD.5

2. Please consider reducing the other limits in Table 1 of Section M according

to the CARB recommendations that are currently in the South Coast AQMD Rules 1171 and 1124, and San Joaquin Valley APCD Rule 4663 :

Solvent and Cleaning Activity ROC Limit

From To g/l (lb/gal) g/l (lb/gal) (a) Product Cleaning During Manufac turing

Processes and Surface Preparation for Coating Application: (i) General 50 (0.42) 25 (0.21) (ii) Electrical Apparatus Components & Electronic Components 900 (7.51) 100 (0.84) (iii) Medi cal Devices & Pharmaceuticals 900 (7.51) 800 (6.7) (b) Repair Cleaning and Maintenance Cleaning: (i) General 50 (0.42) 25 (0.21) (ii) Electrical Apparatus Components & Electronic Components 900 (7.51) 100 (0.84) (iii) Medical Devices & Pharmaceuticals: (I) Tools, Equipment, & Machinery 900 (7.51) 800 (6.7) (II) General Work Surfaces 900 (7.51) 600 (5.0) (c) Cleaning of Coatings Application Equipment 950 (7.51) 25 (0.21) (d) Cleaning of the Following Items and Equipment and their Components: 900 (7.51) 200 (1.68) (i) Aerospa ce Vehicles; (ii) Aerospace Vehicle Payloads and Satellites; (iii) Aerospace Vehicle, Aerospace Vehicle Payload,

and Satellite: (I) Transport Equipment (e.g., railcars, trucks, trailers, forklifts, and containers), and (II) Support Processing Equipment (e. g., clean rooms, tools, payload fairing fixtures, alignment jigs, fuel and oxidizer loading carts and associated transfer lines).

3. For clarity, please c hange the phrase in subsection M

- 2 from “50 grams per liter of material...” to “50 grams of reactive organic compound per liter... ”
Also, subsection M

- 2

- a w ould be more complete if the requirement to store wipes in containers was added

.

4. The following revisions to Section P should be incorporated to support the enforceability of this rule:

a. Subsection 5: Method 2G is in 40 CFR, Part 60, Appendix A

- 2

. b. Subsection 8 : Method 18 is in 40 CFR, Part 60, Appendix A

- 6

. c. For consistency, add reference 40 CFR, Part 60, Appendix A

- 7, to

Methods 25 and 25A indicated in subsection 8.

d. The EPA approved version of ASMT E169, referenced in subsection
7, is 1993

. For consistency indicate as ASTM E169

- 93 (2004).6

EPA ACTION

- The rule fulfils the relevant CAA §110 requirements. EPA staff recommends a full approval of Rule 321 pursuant to CAA §110(k ) ( 3) and §301(a).

ATTACHMENTS

- 1. S B AQMD Rule 321

, Solvent Cleaning Machines and Solvent Cleaning

, as
submitted on April 5 , 201 1

. 2. SCAQMD Rule 32 1

, Solvent Cleaning Operation s, as submitted on Ma rch

10

, 1998

.

REFERENCES

–

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

450/2

- 77

- 022, November 1977. http://www.epa.gov/ttn/naaqs/ozone/ctg_act/197711_voc_epa450_2

- 77

- 022_solvent_metal_cleaning.pdf

2. Control Techniques Guidelines (CTG): Industrial C leaning Solvents, EPA

435/R

- 06

- 001

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

- 06

- 001_ind_cleaning_solvents.p df

3. “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/littleblu ebook2001.pdf

4. California Air Resources Board (CARB) Determination of Reasonable Available Control Technology (RACT) and Best Available Retrofit Control Technology (BARCT) for Organic Solvent Cleaning and Degreasing Operations July 18, 1991.