UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX AIR DIVISION

Technical Support Document

For EPA ’ s Proposed Rulemaking

For the California State Implementation Plan

Placer County Air Pollution Control District ,

Rule 235 , Adhesives

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

May 201 3 2



Agency: Placer County Air Pollution Control District ( P CAPC D)

SIP Approved Rule : Rule 235 – Adhesives Adopted – June 8 , 199 5 Submitted – October 13 , 1995 EPA Approved – July 18 , 1996 ( 6 1 FR 37390 )

Subject of this TSD: Rule 235 – Adhesives Amended – April 10, 1997 Amended – April 8, 2004 Amend ed – October 11, 2012 Submitted – February 6 , 20 13

RULE SUMMARY

– The 1995 SIP approved P CAPCD Rule 2 35 , Adhesives , was amended to clarify exemptions and add an exemption for adhesive materials that fall under other district rules. The majority of revisions concern further clarification of terms and an expansion of descriptions. Rule 235 was also amended to lower VOC limits for a number of adhesives , sealants and substrate adhesives to comply with the federal reasonably available control technology (RACT) requirements established in the 200 8 Control Technique Guideline (CTG) for Miscellaneous Industrial Adhes ives , 1 and the State of California Air Resources Board (CARB) Determination of Reasonably Available Control Technology and Best Available Retrofit Control Technology (BARCT) for Adhesives and Sealants

. 2 The Recordkeeping section was expanded to reference the requirements of several other

1 . EPA

- 453/R

- 08

- 005 Control Techniques Guidelines for Miscellaneous Industrial Adhesives, September 2008

.

2

. State of California Air Resources Board (CARB) Determination of Reasonably Available Control Technology and Best Available Retrofit Control Technology (BARCT) for Adhesives and Sealants, December 1998

. 3



district rules and requirements for emission control equipment records were added. The test methods section was amended to include the determination of several more param eters

. Placer Cou n ty is currently in non - attainment for ozone and PM 2.5. The specific modifications to Rule 235 , Adhesives , include: 1. Revised the Section 100 , General , to include the purpose of the rule and a severability clause. 2. Added two new exemptions:

a. 104.2 Consumer Products Contacts Adhesives, those products subject
to 16 Code of Federal Regulations , Part 1302

. b. 104.8 Materials Regulated Under other District Rules 3. Revised Section 200 to add definitions for the following: Adhesive or Sealant Product, Aerosol Adhesive or Adhesive Primer, Aerosol Cleaning Solvent, Airless Spray, Application Equipment, Architectural, Chlorinated Polyvinyl Chloride (CPVC) Welding Adhesive, Chlorinated Polyvinyl Chloride (CPVC) Plastic, Cleanup Solvent, Closed Container, Co mputer Diskette Jacket Manufacturing Adhesive, Control Device , Cured, Cyanoacrylate Adhesive, Drywall Installation, Enclosed Gun Cleaner, Ethylene Propylene Diene Monomer (EPDM) Roof Membrane , Fiberglass, Flexible Vinyl Adhesive, Hand Application , High Pre ssure Laminate, High

- Volume, Low

- Pressure (HVLP) Application Equipment, Indoor Carpet Adhesive, Indoor Floor Covering Installation Adhesive, Key System Operating Parameter, Leak, Low

- Solids Material, Marine Deck Sealant/Sealant Primer, Material, Metal to Urethane/Rubber Molding or Casting Adhesive, Motor Vehicle, Motor Vehicle Weatherstrip Adhesive, Noncompliant Material, Outdoor Floor Covering Installation Adhesive, Panel Installation, Perimeter Bonded Sheet Flooring Installation Adhesive, Plastic Foam, P lasticizer, Propellant, Reactive Adhesive, Reinforced Plastic Composite, Roadway Sealant, Rubber, Rubber Flooring, Rubber Vulcanization Bonding, Sealant, Sealant Primer, Sheet Rubber Lining Installation, Si ngle

- ply Roof Membrane , Single

- ply Roof 4

 Membrane I nstallation and Repair Adhesive, Solvent Welding , Sol id Ma terial , Stationary Source, Stripper , Structural Wood Member Adhesive, Subfloor Installation, Substrate, Surface Preparation Solvent, Thin Metal Laminating Adhesive, Tire Retread Adhesive, Top and T r im Adhesive, Traffic Marking Tape Adhesive Primer, VCT and Asphalt Tile Adhesive and VOC Composite Partial Pressure . Definitions for Acrylonitrile

- Butadiene

- Styrene (ABS) Welding Adhesive, Adhesive, Aerosol Adhesive , Contact Adhesive, Cove Base Installatio n Adhesive, Exempt Organic Compounds, Flexible Vinyl, Household Adhesive, Multipurpose Construction Adhesive, Non

- Membrane Roof Installation/Repair Adhesive/Sealant, Plastic Cement Welding, Plastic Cement Welding Adhesive, Porous Material, Single

- ply Roof Membrane Adhesive Primer, Single

- ply Roof Membrane Adhesive Sealant and Volatile Organic Compounds (VOC) were revised for clarity . D efinitions for Carbon Adsorption, Catalytic Incineration, Floor Covering Installation Adhesive, Grams of VOC Per Liter of Adhesive, Less Water, Less Exempt Organic Compound, Low Emissions Spray Gin Cleaner, Sales Outlet, Sealant Products, Solvent, Substrate Surface Preparation and Thermal Incineration were deleted. 4. Added Section 301, Material Application Methods. 5. Revised sev eral VOC Limits for Adhesives, Sealants or Primer table in Section 302. Several new Categories were added. The limits for Floor Covering Installation (Except Ceramic Tile), which was separated into indoor and outdoor flooring in this version, increased fro m 150 grams/liter to 250 grams/liter. In addition, the PVC/CPVC Welding limit increased from 500 grams/liter to 510 grams/liter. The 1998 limit for Thin Metal Laminating which was 250 grams/liter, noted as a technology forcing value, is now 780 grams/liter

. 6. No values in the Adhesive Applications onto Substrates table were changed but the categories “Wood” and “Reinforced Plastic Compounds” were added in Table 302

- 2

. 5



7. Table 303

- 1 for VOC Limits or Aerosol Adhesives was added to Section 303 and Table 304

- 1 for VOC Content Limits for Surface Preparation, Cleanup, and St r ipper Solvents was added to Section 304. 8. Sections 305, A Work Practices, and 306, Emission Control Equipment were added. Section 309, Adhesive Strippers, Section 310, Primers, S ealants or Adh esive Containers, Section 311, Prohibition of Specification, Section 312, C ompliance Statement Requirement, and Section 313, Prohibition of Sales, were incorporated into several new sections. 9. Section 400 was expanded to include Prohibition of Sales and Specification, to include the calculation for determining percent control efficiency and VOC mass emission rate and also to include labeling requirements. 10. Section 500, Monitoring and Records was expa nded to include several more test methods and to clarify the recordkeeping criteria.

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), the Little Bluebook ( Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, Augus t 21, 2001), and State Implementation Plans, General Preamble for the Implementation of Title I of the Clean Air Amendments of 1990 (57 FR 13498, April 16, 1992) were used to help evaluate compliance with the CAA §110(a)(2)(A) requirement for enforceabilit y. 2. Stringency – The EPA’s CTG s titled Miscellaneous Industrial Adhesives , ( EPA 453/R

- 0 8

- 00 5 , September 2008 ) and Industrial Cleaning Solvents ( EPA 453/R

- 06

- 001, September 2006 ) and CARB’s Determination o f Reasonable Available Control Tech nol ogy (RACT) and Best Available Retrofit Control Technology (

BARCT) for Adhesives and Sealants (December 1998) were used to establish RACT for adhesives and sealants

. Other district s’ 6

 analogous rules for this category were used as the basis for RACT including: South Coast Air Quality Management District ( SC AQMD) Rule 1168 , Adhesive and Sealant Applic ations , amend ed January 7 , 20 05 , and S an Joaquin Valley Unified A ir Pollution Control District ( S JVU A PC D) Rule 4653 , Adhesives and Sealants , amended September 16 , 201 0

. 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

- The recordkeeping requirements for Rule 235 are detailed and have clear time frames. G enerally , they are analogous to that of S C A QMD’s rule 1168 , SJVUAPCD’s rule 4653 and CARB’s Determination of RACT and BARCT for Adhesives and Sealants

. Recordkeeping requirements have been strengthened and now include recordkeeping of key control system parameters and record retention has been inc reased to three years. All test methods resemble th e CARB’s Determination of RACT and BARCT for Adhesives and Sealants

. C apture, Overall and Transfer efficienc ies are adequately defined and the minimum Overall efficiency percentage of 85 percent is equal to that of the 2008 CTG and SJVUAPCD’s rule. Work Practices, Section 305, has been added to clearly define storage and conveyance requirements. Test Methods was revised to add testing for Determination of Collection Efficiency (502.6), Determination of VOC Content of Emissions (502.7), Determination of Plasticizer Content (502.8), Determination of VOC Content of Cyanoacrylate Adhesives (502.11) and Determination of Viscosity (502.12). Therefore, we propose to determine that submitted Rul e 235 is sufficiently clear and enforceable.

Stringency – We believe Rule 235 generally meets RACT. Overall, it is as stringent as, and in many cases more stringent than , the 2008 CTG and CARB’s 1998 7



“Determination of RACT and BARCT for Adhesives and Sealants ”

. The only exception is the Plastic Solvent Welding (PVC) limit of 510 grams per liter which is slightly higher than the CTG 500 grams per limit for Plastic Solvent Welding (except ABS). P CAPCD’s Rule 235 resembles SCAQMD’s Rul e 1168 and AVAQMD ’s Rule 1168 for VOC limits for adhesives , adhesive primer s, sealants and sealant primers and for solvent cleaning activities

. P CAPCD’s Rule 235 also addresses limits for aerosol adhesive s which the CTG, CARB determination and other district rules do
not. The exceptions in which this rule meets the CTG or the CARB RACT/BARCT limit , but is not as stringent as other SIP rules are:

 Ceramic Tile (wall and floor) Adhesive with a limit of 13 0 gr ams/liter: Although the CTG and CARB Determination of RACT and BARCT indicate

a 130 gram s /liter limit , SCAQMD Rule 1168 , AVAQMD Rule 1168 and SJVUAPCD 4653 have 65 grams/liter limits for th ese same categories

.

 Computer Diskette Jacket Manufacturing adhesive, with a limit of 850 grams /liter: T his lim it resembles the limit in the CARB Determination of RACT and BARCT, but both SCAQMD Rule 1168 and AVAQMD Rule 1168 have 3 50 grams/liter limits for this same category.

 Cove Base adhesive, with a limit of 150 grams/liter: SCAQMD Rule 1168 , AVAQMD Rule 1168 and SJVUAPCD Rule 4653 have 50 grams/liter limits for this same category.

 Indoor Carpet and Indoor Floor Covering, with a limit of 150 grams/liter: SCAQMD Rule 1168, SJVUAPCD Rule 4653 and proposed Rule VCAPCD 74.20 all propose a much lower limit of 5 0 grams/liter.

 Multipurpose Architectural/Construction Adhesive, with a limit of 200 grams/liter: Although this limit resembles the limits in the CTG and the CARB Determination of RACT and BARCT, both SCAQMD Rule 1168 and AVAQMD Rule 1168 have 70 grams/liter limits for this same category. 8



 Outdoor Carpeting/Outdoor Floor Covering Adhesive, with a limit of 250 grams/liter: Although this limit resembles the limits in the CTG and the CARB Deter mination of RACT and BARCT, both SCAQMD Rule 1168 and AVAQMD Rule 1168 have 150 grams/liter limits for this same category.

 Rubber Flooring, with a limit of 150 grams/limit: There is no analogous category in the CTG or in the CARB Determination of RACT and B ARCT. However, SCAQMD Rule 1168 and SJVUAPCD Rule 4653 both have a limit of 60 grams/liter for this category.

 Top and Trim Adhesive, with a limit of 540 grams/liter: SCAQMD Rule 1168 has a limit of 250 grams/liter for this category.

 ABS We lding with a limit of 400 grams /liter: Although this limit resembles the limits in the CTG and the CARB Determination of RACT and BARCT, both SCAQMD Rule 1168 and SJVUAPCD Rule 4653 have 325 grams/liter limits for this same category.

 Other P lastic Welding with a limit of 45 0 grams/liter: SCAQMD Rule 1168, SJVUAPCD Rule 4653 and AVAQMD Rule 1168 and proposed rule SBAPCD Rule 353 have established limits of 250 grams/liter for this category.

 Fiberglass Substrate with a limit of 200 grams/liter: SCAQMD Rule 1168, SJVUAPCD Rule 4653 , AVAQMD Rule 1168 and proposed rule VCAPCD Rule 74.20 have established limits of 80 grams/liter for this category.

 Plastic Foam and Porous Material Substrate s with a limit of 12 0 grams/liter: SCAQMD Rule 1168, SJV UAPCD Rule 4653 and proposed

ru le VCAPCD Rule 74.20 have limits of 50 grams/liter for those two categories

. In addition to the adhesive and sealant categories, this rule has limits for various surface preparation, clean

- up and stripper solvents which have VOC limits that range from 70 to 800 grams/liter. Several other substrate surface preparation solvents

were added including those for Electronic Components, Medical Devices and 9



Pharmaceuticals and Solvent Stripping of Wood Substrates. Some districts have reduced the solvent limits for this usage to 25 grams/liter. However, the CTG for Industrial Cleaning Solvent 3 recommends that solvents used in adhesive application operations be excluded from the CTG’s strict 50 grams/liter VOC limit for solvents. Since PCAPCD Rule 235 complies with the 2008 CTG , we propose to determine that submitted Rule 2 35 is sufficiently st ringent

.

SIP Relaxation – The new submittal generally complies with CAA § 110(l) and § 193 regarding SIP relaxations. Comparing this version with the SIP

- approved rule , t wo categories of adhesives and primers ; Indoor Floor Covering Installation and Plastic Cement Welding Primers have lowered limits. There is a n increase in the VOC limit for Outdoor Floor Covering to 250 grams/liter from the previous general Floor Covering category of a 150 grams/liter limit. However the new limit for outdoor flooring adhesi ves meets RACT limits and other flooring adhesive limits are lower than RACT

. There is also a slight increase in the VOC limit for ABS Welding to 400 grams/liter from the previous ABS Welding limit of 370 grams/liter . However the ABS welding meet s RACT lim its. There is also a significant increase in the Thin Metal Laminating category from 250 grams/liter (effective January, 1998) to the 780 grams/liter in this rule. The 250 grams/liter limit was stat ed to be technology forcing and the 780 grams/liter limit is analogous to CARB’s RACT/BARCT and to other district limits. Despite these three limit increases , the staff report states that the application of all the other lower limit compliant adhesives and sealants will generally result in lower VOC emissions. T herefore, we propose to determine that submitted Rule 74.20 has not relaxed the SIP rule.

3

. EPA

- 453/R

- 0 6

- 00 1 Control Techniques Guidelines fo r Industrial Cleaning Solvent s, September 200 6 10



ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION – 1. Section 302 , Requirements – VOC Limits, Adhesive, Adhesive Primers, Sealants and Sealant Primers, w e recommend that the following limits be considered , based on the discussion above :
a. 65 grams/liter for Ceramic Tile Adhesive b. 350 grams/liter for Computer Diskette Jacket Manufacturing Adhesive

c. 80 grams/liter for Contact Adhesive d. 50 grams/liter for Cove Base Adhesive

e. 50 grams/liter for Indoor Floor Covering Installation Adhesive f. 70 grams/liter for Multipurpose Architectural / Construction Adhesive g. 150 grams/liter for Outdoor Floor Covering Installation Adhesive h. 60 grams/liter for Rubber Flooring Adhesive i. 250 gr ams/liter for Top and Trim Adh esive j. 50 grams/liter for VCT and Asphalt Tile k. 325 grams/liter for ABS Welding l. 25 0 grams/liter for Other Plastic (cement) Welding

m. 8 0 grams/liter for Fiberglass Substrate Applications 2. In Table 302

- 1, please correct “Structural Wood Member Glazing” to “Structural Wood Member Adhesive.” In Table 302

- 2, consider changing “Metal” to “Metal

- to
- Metal” if that is the correct substrate combination.

EPA ACTION

- EPA staff recommends a full approval of P CAPCD Rule 235 pursuant to CAA §1 10(k) (4) and §301(a). 11



ADDITIONAL REFERENCES

– 1. P CAPCD Rule 235, Adhesives , Adopted June 8, 1995

. 2. P CAPCD Rule 235, Adhesives , Amend ed October 11 , 2012. http://www.placer.ca.gov/~/media/apc/documents/Rules/Reg%202/Rule 235Adhesives.ashx 3. S C AQMD Rule 1168 , Adhesive and Sealant Applications, amended January 7, 2005

. http://www.aqmd.gov/rules/reg/reg11/r1168.pdf 4. SJVUAPCD Rule 4653, Adhesives and Sealants, amended September 16, 2010. http://www.valleyair.org/rules/currntrules/r4653.pdf 5. Control Techniques Guidelines for Miscellaneous Industrial Adhesives, EPA 453/R

- 0 8

- 00 5 , September 200 8

. http://www.epa.gov/airquality/ozonepollution/SIPToolkit/ctg_act/200809_v oc_epa453_r

- 08

- 005_miscellaneous_industrial_adhesives.pdf 6. Control Techniques Guidelines : Industrial Solvent s, EPA

- 453/R

- 06

- 001 , September 2006

. http://www.epa.gov/airquality/ozonepollution/SIPToolkit/ctg_act/200609_v oc_epa453_r

- 06

- 001_ind_cleaning_solvents.pdf 7. State of C alifornia Air Resources Board Determination of Reasonably Available Control Technology and Best Available Retrofit Control Technology for Adhesives and Sealants, December 1998. http://www.arb.ca.go v/ractbarc/adhfinal.pdf 8. “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 9. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001. http://www.epa.gov/region9/air/sips/littlebluebook2001.pdf