SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX E: Technical Support Document June 16, 2011 

Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4605

E-1

APPENDIX E 

EPA Technical Support Document (TSD) 

June 16, 2011 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX E: Technical Support Document June 16, 2011 

Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4605

E-2

This page intentionally blank. 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX AIR DIVISION

Technical Support Document 

for 

EPA’s Proposed Rulemaking 

for the 

California State Implementation Plan 

San Joaquin Valley Air Pollution Control District, Rule 4605, Aerospace 

Assembly and Component Coating Operations 

Prepared by: Nicole Law 

Reviewed by: Andrew Steckel

June 2009 

APPENDIX E: Technical Support Document SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT June 16, 2011 E - 3 Final Draft Staff Report with Appendices 

For Proposed Amendments to Rule 4605
-2- 

RULE IDENTIFICATION - 

Agency: San Joaquin Valley Unified Air Pollution Control 

District (SJVAPCD) 

SIP Approved Rule: Rule 4605 – Aerospace Assembly and Component 

Coating Operations 

Adopted – December 20, 2001; Submitted – February 

20, 2002 

EPA Approved – November 14, 2003 (68 FR 64537) 

Subject of this TSD: Rule 4605 - Aerospace Assembly and Component 

Coating Operations 

Amended – September 20, 2007; Submitted – March 

7, 2008 

RULE SUMMARY - Rule 4605 establishes VOC content limits and workplace 

standards for industrial sites engaged in manufacturing, assembling, coating, 

masking, bonding, paint stripping, surface cleaning, service, and maintenance of 

aerospace components, the cleanup of equipment, and the storage and disposal 

of solvents and waste solvent materials associated with these operations. It also 

describes related recordkeeping, reporting, and monitoring requirements. 

Changes from the approved SIP rule include: 

1. Edited several definitions in Section (3) and made numerous other 

editorial changes to improve clarity. 

2. Removed expired exemptions. 

3. Standardized the language in the requirements section (5) and 

administrative requirements section (6). 

EPA EVALUATION - The following criteria and guidance documents 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. RACT – EPA’s Control Technique Guideline (CTG) titled, “Surface Coating 

Operations at Aerospace Manufacturing & Rework Operations” (EPA453/R-97-004, December 1997), SJVAPCD’s 2009 RACT SIP 

Demonstration (April 16, 2009), “Preamble, Final Rule to Implement the 8-

APPENDIX E: Technical Support Document SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT June 16, 2011 E - 4 Final Draft Staff Report with Appendices 

For Proposed Amendments to Rule 4605
-3- 

hour Ozone National Ambient Air Quality Standard” (70 FR 71612 

November 29, 2005), Letter from William T. Hartnett to Regional Air 

Division Directors, “RACT Qs & As – Reasonable Available Control 

Technology (RACT) Questions and Answers,” (May 18, 2006),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 - Where previous versions of rules have been SIP approved, 

new submittals must comply with CAA §110(l) and §193 regarding SIP 

relaxations. 

On April 16, 2009, SJVAPCD adopted its “2009 RACT SIP,” which provides the 

District’s demonstration that RACT is implemented for all appropriate activities. 

This includes several pages discussing Rule 4605 (cover and applicable pages 

attached). In summary, SJVAPCD states that: 

- Rule 4605 is at least as stringent overall as the 1997 CTG titled, 

“Surface Coating Operations at Aerospace Manufacturing and Rework 

Operations.” This is based on VOC limits being more stringent in the 

rule for 34 categories and less stringent in the rule for 19 categories. 

- Rule 4605 is at least as stringent as the 1977 CTG titled, “VOC 

Emissions from Solvent Metals Cleaning.” 

- The NESHAP for aerospace manufacturing and rework facilities is not 

directly comparable to the limits in Rule 4605. 

- Rule 4605 imposes very similar requirements to those in other large 

California nonattainment areas. 

The monitoring, recordkeeping, reporting and other requirements generally ensure 

that the submitted rule can be enforced. In addition, 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 §110(l) and §193. However, we do not 

believe that SJVAPCD has adequately demonstrated that the rule implements 

RACT, as discussed in the rule deficiencies section below. 

RULE DEFICIENCIES - The following deficiency precludes full approval of the 

rule into the SIP. 

The 1997 CTG “Surface Coating Operations at Aerospace Manufacturing 

Rework Operations” defined presumptive RACT in 1997, and RACT may have 

become even more stringent if technology improved since then. Table 1 of 

Rule 4605 does not include 17 of the specialty VOC coating limits provided in 

the CTG and has a higher limit for two other specialty limits listed in the CTG. 

SJVAPCD has not demonstrated that any of the CTG limits are infeasible in 

San Joaquin or otherwise adequately demonstrated that Rule 4605 

implements RACT consistent with CAA §182 (b)(2). 

APPENDIX E: Technical Support Document SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT June 16, 2011 E - 5 Final Draft Staff Report with Appendices 

For Proposed Amendments to Rule 4605
-4- 

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. In section 6.2, state that a violation determined by either test method shall 

constitute a violation of the rule. For example, please see SCAQMD Rule 

1124, section f.5. 

2. In section 6.2, include full titles to the ASTM methods. 

EPA ACTION - The submitted changes to Rule 4605 are largely administrative 

and clarify the SIP rule. The rule largely fulfills the relevant CAA §110 and part D 

requirements, but the deficiencies discussed above preclude full SIP approval. 

We do not believe the deficiencies undermine emission reductions claimed for the 

Rule by the district. EPA staff recommends a simultaneous limited approval and 

limited disapproval of Rule 4605 pursuant to CAA §110(k)(3) and §301(a). 

ATTACHMENTS – 

1. SJVAPCD Rule 4605, Aerospace Assembly and Component Coating 

Operations, as submitted on March 7, 2008. 

2. SJVAPCD Rule 4605, Aerospace Assembly and Component Coating 

Operations, as approved into the SIP on November 14, 2003. 

3. “Surface Coating Operations at Aerospace Manufacturing & Rework 

Operations,” EPA-453/R-97-004, December 1997. 

 http://www.epa.gov/ttn/naaqs/ozone/ctg_act/199712_voc_epa453_r-97-

004_aerospace_rework.pdf 

4. “Control of Volatile Organic Emissions from Solvent Metal Cleaning,” EPA450/2-77-022, November 1977. 

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/197711_voc_epa450_2-77-

022_solvent_metal_cleaning.pdf 

5. “Reasonably Available Control Technology (RACT) Demonstration for 

Ozone State Implementation Plans (SIP)” SJVAPCD, April 16, 2009. 

ADDITIONAL REFERENCES - 

1. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and 

Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988. 

2. “Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001. 

3. Portions of the proposed post-1987 ozone and carbon monoxide policy that 

concern RACT, 52 FR 45044, November 24, 1987. 

4. “State Implementation Plans, General Preamble for the Implementation of 

Title I of the Clean Air Amendments of 1990” 57 FR 13498, April 16, 1992. 

5. “Preamble, Final Rule to Implement the 8-hour Ozone National Ambient Air 

Quality Standard” 70 FR 71612; Nov. 29, 2005. 

6. Letter from William T. Hartnett to Regional Air Division Directors, “RACT 

Qs & As – Reasonable Available Control Technology (RACT) Questions 

and Answers,” May 18, 2006. 

APPENDIX E: Technical Support Document SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT June 16, 2011 E - 6 Final Draft Staff Report with Appendices 

For Proposed Amendments to Rule 4605