UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

f or EPA ’ s Proposed Rulemaking

f or the California State Implementation Plan

San Joaquin Valley Air Pollution Control District, Rule 4603

, Surface Coating of

Metal Parts and Products , Plastic Parts and Products and Pleasure Crafts

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

Dece mber, 20 102

RULE IDENTIFICATION

-

Agency: San Joaquin Valley Air Pollution Control District (S JV APCD )

SIP Approved Rule: Rule 4603

– Surface Coating of Metal Parts and

Products Adopted

– October 16, 2008

Submitted

- December 23, 2008 EPA Approved

– January 19, 2010 (75 FR 2796)

Subject of this TSD: Rule 4603

– Surface Coating of Metal Parts and

Products , Plastic Parts and Products and Pleasure

Crafts

Amended

– September 17, 2009

Submitted

– May 17, 2010

RULE SUMMARY

- SJV APCD Rule 4603, Surface Coating of Metal Parts and

Products , Plastic Parts and Products and Pleasure Crafts is a rule designed to

limit volatile organic compound (VOC ) emissions from facilities engaged in coating of metal parts and products , large appliances parts or products , and

metal furniture and automotive/tr ansportation and business machine plastic parts and products and pleasure craft

. It also limits VOC emissions from organic solvent cleaning and storage and disposal of solvents and waste solvent materials associated with such coating. The rule describes r elated recordkeeping, reporting, and monitoring requirements and test methods for determining various VOC content and emissions . Changes from the approved

SIP rule include:

1. Added plastic parts and products, automotive/transportation and business

machine plastic parts and products and pleasure crafts to the listing of coatings that this rule regulates.

2. Established VOC limits for several coating categories including Section 5.4 for VOC limits for large appliance parts or products and metal furniture coating operations, Section 5.5 for VOC limits for plastic parts and products coating operations, Section 5.6 for VOC for automotive/transportation and business machine plastic parts and products coating operations and Section 5.7 for VOC for pleasure craft

coati ng operations.

3. Provided exemptions for certain types of coatings in Section 4.0

. 4. Included work practice standards for all coating operations covered by this rule in Section 5.9 and for cleaning solvents in Sections 5.10 and 5.11

. 5. Established lower VOC con tent limits for cleaning solvents in Section 5.10.

6. Updated several definitions of terms used in the rule, which are consistent with the recommendations by the CTG3

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, 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 s (CTG s ) titled, “ Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings ” ( EPA

- 453/R

- 08

- 003, September 2008 ) , “Control Techniques Guidelines for Large Appliance Coatings” (EPA

- 453/R

- 07

- 004

, September 2007), “Control Techniques Guidelines for Metal Furniture Coatings” (EPA

- 453/R

- 07

- 005, September 2007), 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.

The monitoring, recordkeeping, reporting and other rule provisions are generally

clear and otherwise fulfil CAA § 110(a ) ( 2 ) ( A) enforceability requirements. The VOC limits and other requirements are as stringent as the 2007 and 2008 CTGs

issued for t his a ctivity , so we believe the rule fulfils CAA §182(b ) ( 2). RACT requirements. Lastly, t he 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 CAA §110(l) and §193.

RULE DEFICIENCIES

– We have identified no deficiencies with Rule 4603 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. Please consider removing the exemption for stripping a gents used for cured coatings, adhesives and ink in S ection 4.12 . See, for example, Sacramento Metropolitan Air Quality Management District ( S M AQMD ) Rul e
451 in Section 30 3

, and South Coast Air Quality Management District ( SCAQMD ) Rule 1107 in Section (c)(3)

. 2. Please consider making the following formatting and editor ial changes:

a. The AAMA reference in S ection 3.42 should be 2604

- 05 and 2605

- 05 as listed in the 2008 CTG.4 b. To avoid referencing S ection 5.2 within S ect ion 5.2, consider revising S ection 5.2 to “S pecialty Coating or Metal Parts and Products, except for Large Appliance or Products and Metal Furniture subject to S ection 5.4.1 shall not apply to any metal part or product specialty coating with a VOC content in excess of the limits

in Table 1.”

c. The Sec tion following S ubsection 5.12.10 should be 5.13, not 5.12.

d. In the definition of D c in S ection 5.8.4.1, please clarify that this factor is either a variable or a constant of 880 gram/liter.

e. Please also only use those ASTM methods that ha ve been approved by the EPA in 40 CFR 60.17. ASTM D5478

- 98 and ASTM

D5125

- 97 listed in Section 6.3.3 and ASTM D1613

- 96 listed in Section 6.3.5 are not approved

. f. We also recommend full titles all EPA

- approved te st methods be

added to S ection 6.3. For exampl e, please see SCAQMD Rule

1107 S ection (e) (1) (A) and Placer County Air Pollution Control District ( PCAPCD ) Rule 245, Section 503.3

.

EPA ACTION

- The rule largely fulfils the relevant CAA §110 and CAA part D requirements. EPA staff recommends full approval of Rule 4603 pursuant to CAA § 110(k) (3) and § 301(a).

ATTACHMENTS

- 1. SJV APCD Rule 4603

, Surface Coating of Metal Parts and Products, as

submitted on May 17, 2010

.

ADDITIONAL REFERENCES

–

1. “Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings,” EPA

- 453/R

- 08

- 003, September 2008. http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200809_vo c_epa453_r

- 08

- 003_misc_metal_plasticparts_coating.pdf

2. “Control Techniques Guidelines for Large Appliance Coatings,” EPA

453/R

- 07

- 004, September 2007. http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200709_voc_epa453_r

- 07

- 004_lg_appliance_coating.pdf

3. “Control Techniques Guidelines for Metal Furniture Coatings,” EPA

- 453/R

07

- 005, September 2007. http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200709_voc_epa453_r

- 07

- 005_metal_furniture_coating.pdf

4. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

5. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001