**UNITED STA TES ENVIRONMENTA** **L PROTECTION A GENCY**  **REGION IX A IR DIVISION**  Technical Support Document

for EPA’ s Proposed Rulemaking

f or the California State Implementation Plan San Joaquin Valley Unified Air Pollution Control District,

Rule 46 53 , Adhesives and Sealants Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel September 20 1 1 2 

**RULE IDENTIFICA TION**  - **Ag ency**  **:** San Joaquin Valley Unified Air Pollution Control District (S JV U APCD ) **SIP A pproved Rule:**  Rule 46 53 – Adhesives Ad opted – Dece mber 20, 200 7 Submitted - March 7 , 200 8 EPA Approved – October 15, 2009 ( 74 FR 52894 ) **Previous Submitted Rule:** Rule 4653 – Adhesives Adopted – September 17, 2009 Submitted - May 17, 2010 **Subject of this TSD:** Rule 46 53 – Adhesives and Sealants Amend ed – September 1 6 , 20 10 Submitted – April 5 , 201 1 **RULE SUMMA RY**  **-** SJV U APCD Rule 46 53 , Adhesives and Sealants, is a rule amended to reduce emissions of volatile organic compound s (VOCs ) from the application of adhesive products, sealant products an d associated solvent cleaning operations . The rule describes related recordkeeping, reporting, and monitoring requirements and test methods for determining various VOC content and emissions . The submitted changes to Rule 46 53 are largely made to adopt the new content limits of the 2008 CTG prior to the effective date of January 1, 2011. Changes from the approved SIP submittal include: 1. Change d the title from “Adhesives” to “Adhesives and Sealants” and include d sealant products, as needed, in each section. 2. Add ed several definitions in Section 3.0 to clarify the current rule , to add sealant products and to include new adhesives categories to the rule language. 3. Clarified exemptions, add ed sealant exemptions and sales restrictions and include d effective dates for complying with the rule limits in Section 4.0 . 4. Revised Section 5.0 Table 1, adding columns for VOC limits for effective dates through December 31, 2010 and after January 1, 2011. 5. Added Section 5.0 Table 2 indicating lower VOC limits for adhesives effective January 1, 2012. 6. Revised Section 5.0 Table 3 to include VOC limits for adhesives effective January 1, 2011 and January 1, 2012. Added Reinforced Plastic and Fiberglass categories. 7. Included Section 5.0 Tables 4 and 5 for sealant and sealant prim er limits. 3 

8. Added Airless Spray to the list of application in Section 5.2. 9. Revised the requirement for transfer efficiency of any new application methods to be equivalent to the efficiency of the HVLP method instead of at least 65%. 10. Added Section 5.3, W ork Practices fo r Adhesive and Sealant Products . 11. Revised Table 6, VOC Limits for Organic Solvents Used in Cleaning Operations, to list only the September 21, 2008 limits. 12. Replaced the section for Solvent Storage and Disposal Requirements with a Wo rk Practices for Solvent Cleaning. 13. Added Section 5.8, Sell -through of Adhesives and Sealants and Section 5.9, Prohibition of Specification. 14. Removed the requirement of daily records of all adhesives, primers and solvents used in each operation and added the req uirement to record the VOC content of all sealant materials stored at a stationery source. 15. Clarified labelling requirements in Section 6.2 to include all three requirements and to add sealant products, effective January 1, 2012. **EPA EV** **AL UA** **TION -**  The fol lowing 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, August 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 enforceability. 2. Stringency – EPA’ s Control Technique Guideline (CTG) titled “ Control Techniques Guidelines for Miscellaneous Industrial Adhesives” (EPA-453/R08 - 005, September 2008), CARB’s RACT/BARCT guidance titled, “D etermination of Reasonably Available Control Technology and Best Available Retrofit Control Technology for Adhesives and Sealants” (December 1998), SJV U APCD’s 2009 RACT SIP Demonstration (April 16, 2009), and other state and local rules for this category we re used to help evaluate the RACT requirements of CAA § 182(b)(2) . 3. SIP Relaxation - Wehave evaluated this SIP revision to determine whether it would interfere with any applicable requirement concerning attainment and reasonable further progress (RFP) or a ny other applicable requirement of 4  CAA §110(l) or modify any SIP -approved control requirement in effect before November 15, 1990 (CAA §193). Enforceability – The recordkeeping of coatings and control system parameters, test methods and other requirements generally ensure that the submitted rule can be enforced. Since section 6.1.1 of the rule requires records of the VOC content of all adhesive materials, solvents and sealant materials used and stored, we do not believe the absence of a requirement of a materials listing makes the rule un enforceable. However, Rule 4653 could be improved by adopting language similar to that of BAAQMD Rule 8 -51 which specifi es a requirement for manufacturer’s product number, mix ratios of components in the product used, and final VOC content as applied. Stringency – Rule 46 53 closely resembles the 2008 CT G for Miscellaneous Industrial Adhesives ( EPA-453/R-08 - 005) and CARB’s Determination of RACT and BARCT for Adhesives and Sealants (December 1998), which we believe are gen erally reliable source s for identifying RACT. In addition, several adhesive and sealant categories in Rule 4653 have VOC limits lower than the CTG . Further, Rule 46 53 is generally as stringent as analogous requirements in Bay Area ( BAAQMD Rule 8 -51 ( 7 - 16 -0 2 ) ) and South Coast ( SCAQMD’s Rule 1168 (1 - 7 -2005) ), and we are not aware of more stringent requirements adopted elsewhere . For these reasons, we believe Rule 46 53 implements RACT and complies with CAA §182(b ) (2). SIP Relaxation – The VOC limits for seve ral categories , effective January 1, 2012, were reduced significantly . These categories include Multi - purpose Construction Adhesive, Ceramic Tile Adhesive, Cove Base Installation , Single - ply Roof Material Installation and Contact Adhesive, ABS W elding Adhe sive, Plastic Cement We lding Adhesive Primer, Other Plastic Cement W elding Adhesive and Plastic Foam. Consequently we believe that the submitted rule is more stringent than the version previously approved into the SIP . Wepropose to determine that our ap proval of the submittal would comply with CAA §193 and CAA §110 and part D requirements, because the SIP revision would not interfere with the on -going process for ensuring that the requirements for RFP and attainment of the NAAQS are met, and the submitte d SIP revision is more stringent than the rule previously approved into the SIP. **RULE DEFICIENCIES** – Wehave not identified any deficiency in Rule 4653 sufficient for EPA to propose less than a full approval . **AD DITIONA** **L RECOMMENDA TIONS 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. 5 

1. Please consider making the following changes to definition s in Section 3.0 : a. CARB’s definition of airless sp ray in the 1991 Automobile Refinishing Coating compliance assistance program states that the Airless Spray operates under high flui d pressure between 1500 and 3000 psi. Please verify if the larger range indicated in the definition in Subsection 3.9 is accu rate. b. Please clarify whether cove base should be included in the Floor Covering Installation definition of Subsection 3.43 . 2. In Subsection 3.85, for accuracy, we recommend that you add “as determined by ASTM Method E260 -96 .” after “distensibility.” as SM AQMD has done in their definition of plasticizer. 3. For clarity, please add the following statement to Subsection 4.1.6: Effective on and after January 1, 2011, users must comply with the applicable requirements of Section 4.2. 4. For completeness, and to b e consistent with Section 5.7, please revise Subsection 4.3.2 to be: “Adhesive products and sealant products sold to any person who complies with the requirements of Section **5.1 or** 5.4.” 5. Consider the possibility of lowering the limits in Table 2 of Secti on 5.1 :

a. The CARB Determination of RACT and BARCT for Adhesives and Sealants has a technology forcing standard limit of 250 g/l for the Sheet Applied Rubber Installation category. Since , by definition, this seems to be the same as Rule 4653’s category, Rub ber Vulcanization Adhesive/Primer, consider the possibility of lowering this limit to 250 g/l. b. The Motor Vehicle W eatherstrip Adhesive should be included in the “All other Substrates” category of Table 3. Consider lowering this limit to the 250 g/l limit indicated on Table 3. c. BAAQMD’s Rule 8 -51 limits the VOC for Immersible Product Manufacturing to 650 g/l. Since the definition of BAAQMD’s Immersible Product Manufacturing is comparable to SJVUAPCD’s Elastomeric Adhesive, it would seem possible that the limit for Elastomeric Adhesive can be lowered from 750 g/l to 650 g/l. d. Consider lowering the limit for PVC W elding adhesive to 500 g/l which is consistent with the CTG. 6 

6. Based on the Table in the 2009 SJUAPCD RACT SIP rule analysis ( page 3 -309 through 4 - 311) , SCAQMD’s Rule 1168 has lower limits in four categories: a. Ceramic Tile Installation - SCAQMD has a 65 g/l limit compared to SJVUAPCD’s 130 g/l limit. b. Cove Base Installation - SCAQMD has a 50 g/l limit compared to SJVUAPCD’s 150 g/l limit . c. Mul t ipurpose Construction - SCAQMD has a 70 g/l limit compared to SJVUAPCD’s 200 g/l limit . d. Top and Trim Installation - SCAQMD has a 250 g/l limit compared to SJVUAPCD’s 540 g/l limit. 7. The VOC limit for the cleaning solvent for the Surface Preparation Prior to Rubber Vulcanization Process indicated in Table 6 of Section 5.5 is 850 g/l. The CARB Determination of RACT and BARCT for Adhesives and Sealants does not have a comparable category. W e recommend the District consider lowering the limit for this category . 8. The CAR B guidance recommends a material list complete with catalysts, reducers or other components used and the mix ratio. Please consider adding this in subsections 6.1.1.1, 6.1.1.2 and 6.1.1.3 to complete the information available. 9. For clarity, please revise subsections 6.1.3.1 and 6.1.3.1 to include “adhesive products and sealant products...” in the recordkeeping requirements. 10. Please make the following changes for clarity and consistency as defined in the Little Bluebook: a. Per CARB Determination of RACT/BARCT f or Adhesives and Sealants, Test 24 is applicable for non -aerosol adhesives. Please consider adding “non -aerosol” before “ adhesive products ” in Subsection 6.3.1 . b. CARB recommends SCAQMD Method 305 -91, Determination of VOC in Aerosol Applications, June 1 993, or ARB Method 310, Determination of VOC in Consumer Products and reactive Organic Compounds in Aerosol Coating Products, June 22, 2000, for determining the VOC content of aerosol adhesives. Please refer to these test methods for aerosol adhesive and s ealant products in Section 6.3 . c. CARB recommends SCAQMD Method 316A- 92, Determination of VOC in Materials Used for Pipes and Fittings , October 1996 , for any 7  plastic cement adhesives or primers. Please refer to th i s test method for plastic cement adhesive p roducts in Section 6.3. d. The 2008 CTG recommends that the procedure for determining VOC content for reactive adhesives in Appendix A of the NESHAP for surface coating of plastic parts (40 CFR 63, PPPP) be used for reactive adhesives. The manufacturer’s formulation data is acceptable but, if there is a disagreement between manufacturer’s formulation data and the results of the subsequent test, the test results should be used unless the facility can demonstra te that the manufacturer’s data are correct. Please consider adding a test procedure for reactive adhesives , with the appropriate caveat for variations between test results and manufacturer’s data, in Section 6.3. e. In S ubs ection 6. 3.3 , the ARB method 422 reference should have the date of the EPA-approved version which is Sept. 12, 1990 . **EPA A** **CTION** - EPA staff recommends a full approval of Rule 46 53 pursuant to CAA §110(k) (3) and §301(a). **AD DITIONA** **L REFERENCES**  **–** 1. SJVAPCD Rule 46 53 , Adhesives and Sealants , as submitted on September 16 , 2010 . 2. SJVAPCD R ule 46 53 , Adhesives , as submitted on September 17, 2009 . 3. Control Technique Guideline (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_r08 - 005_miscellaneous_industrial_adhesives.pdf. 4. CARB’s RACT/BARCT guidance titled, “Determination of Reasonably Available Control Technology and Best Available Retrofit Control Technology for Adhesives and Sealants” (December 1998) http://www.arb.ca.gov/ractbarc/adhfinal.pdf. 5. SJVUAPCD’s 2009 RACT SIP Demonstration (April 16, 2009) . 6. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988. 7. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001.