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 321 , Solvent Cleaning Machines and Solvent Cleaning

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

August 201 3 2



RULE IDENTIFICATION

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

- Approved Rule: Rule 321
– Solvent Cleaning Machines and Solvent Cleaning
A mend ed
– September 20, 2010
Submitted
– April 5, 2011 Approved
– September 29, 2011 ( 76 FR 60376 ) Subject of this TSD: Rule 321
– Solvent Cleaning Machines and Solvent Cleaning
Amended
– June 21 , 201 2
Submitted
– September 21 , 201 2

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 Recordkee ping and Reporting requirements, and establishes a compliance schedule. The changes incorporated by the June 21, 2012
amendment are minor and only incorporate a change to the rule title for Rule 337
in Section B

- 6

- d from “Surface Coating Aircraft or Aerosp ace Vehicle Parts and Products” to “Surface Coating Aerospace Vehicles Components” and the addition of
the caveat:

” Notwithstanding this exemption, the applicable Rule 321 requirements apply if a rule for any above process specifies a solvent cleaning mac hine shall comply with the applicable provisions of Rule 321

. ”

EPA EVALUATION

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

-

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 M etal Cleaning” (EPA

- 450/2

- 77

- 022, November 1977) and “Control Techniques Guidelines for Industrial Cleaning Solvents” (EPA

453/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).

RULE EVALUATION

1. Enforceability

– SBCAPCD ’s Rule 321 specifies clear, unambiguous terminology and ROC limits. Each type of solvent cleaning machin e 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 System Requirements (section N) does not specify equipment, it does clearly indicate th e 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- 4

- (section Q) further strengthens this rule’s en forceability through procedures and recordkeeping.

2. Stringency
– SB CAPC D’s Rule 321 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 ROC levels as analogous rules in
other districts including South Coast AQMD rules 1122 a nd 1171 and San Joaquin Valley APCD rules 4661, 4662 and 4663. SB C A PC D is in attainment with the national ambient air quality standards (NAAQS) and, therefore, more stringent requirements are not required a t this time under national requirements for RACT (CAA § 182(b) (2)) or RACM (CAA § 172(c) (1)).

3. The changes to Rule 321 do not constitute a relaxation and they actually extend the applicability of Rule 321 to any other operation

- specific rule that
inclu des the use of a solvent cleaning machine.

Therefore, we propose to determine that our approval of the submittal would comply
with CAA § 110(l), because the changes made were administrative in nature and are not expected to have an adverse effect on emis sion reductions . CAA § 193 does not apply to this proposed action because SBAQMD is designated attainment for VOC’s.

RULE DEFICIENCIES
– We have identified no deficiencies in submitted Rule 3 21 sufficient for EPA to propose less than full approval.- 5

-

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

- 2, B

- 13, B

- 15, G

- 3, H

- 7, I

- 7, J

- 11, 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.
2. Consider reducing the solvent 900 grams/liter ROC limit in section B

- 8

- d to 100 grams/liter for electronic apparatus and 800 grams/liter for medical
devices similar to that in South Coast AQMD ’s rule 1171. Similarly, consider using South Coast AQMD ’s rule 1171’s 600 grams/liter limit for disinfecting and decontaminating the surfaces described in section B

- 14.
3. The limit of 800 grams/liter ROC for solvent cleaning of crude oil machines and equipment is unusual ly high . Please consider a lower limit and include
this item in the Table 1 of Section M.

4. 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 Manufacturing 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)- 6

-

(iii) Medical Devices & Pharmaceuticals 900 (7.51) 800 (6.7) (b) Repair Cleaning and Maintenance Cleaning: (i) General 50 (0.42) 25 (0.21) (ii) E lectrical 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) Aerospace 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, a lignment jigs, fuel and oxidizer loading carts and associated transfer lines).

5. For clarity, please change the phrase in subsection M

- 2 from “

... grams per liter of material...” to “

... grams of reactive organic compound per liter of
material ...” Also, subsection M

- 2

- a would be more complete if the requirement to store wipes in containers was added.

6. 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, Appe ndix 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.- 7

- d. The EPA approved version of AS TM E169, referenced in subsection 7,
is 199 3. For consistency indicate as ASTM E169

- 93 (2004).

7. In Section R, d aily recording should be required for all non

- compliant solvents
used including those which satisfy the requirements of Section B

- 15.

EPA ACTION

- EPA staff recomm ends a full approval of Rule 321 pursuant to CAA §110(k) (4) and §301(a).

ADDITIONAL REFERENCES

– 1. SBCAPCD Rule 3 21
– Solvent Cleaning Machines and Solvent Cleaning
submitted April 5 , 201 1
2. SBCAPCD Rule 321
– Solvent Cleaning Machines and Solvent Cleaning submitted Sep tember 2 1 , 201 2
3. “Control of Volatile Organic Emissions from Solvent Metal Cleaning,” EPA

450/2

- 77

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

- 77

- 022_solvent_metal_cleaning.pdf

4. Control Techniques Guidelines (CTG): Industrial Cleaning 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.pdf
5. “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.pdf
6. 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.