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, 2011SAN 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 Im plementation 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 2009-2- 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 c ontent limits and workplace standards for industrial sites engaged in m anufacturing, assembling, coating, masking, bonding, paint stripping, surfac e cleaning, service, and maintenance of aerospace components, the cleanup of equi pment, and the storage and disposal of solvents and waste solvent materials associated with these operations. It also describes related recordkeeping, repor ting, 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 t he 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 Implement ation 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 Guide line (CTG) titled, “Surface Coating Operations at Aerospace Manufac turing & Rework Operations” (EPA453/R-97-004, December 1997) , SJVAPCD’s 2009 RACT SIP Demonstration (April 16, 2009), “Preambl e, Final Rule to Implement the 8--3- hour Ozone National Ambient Air Q uality Standard” (70 FR 71612 November 29, 2005), Letter from Willia m 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 ve rsions 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 requi rements 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 demons trated 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 Operat ions at Aerospace Manufacturing Rework Operations” defined presumptiv e 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 spec ialty 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).-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 violat ion 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 di scussed 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 t he 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/o zone/ctg_act/199712_voc_epa453_r-97- 004_aerospace_rework.pdf 4. “Control of Volatile Organic Emissi ons from Solvent Metal Cleaning,” EPA450/2-77-022, November 1977. http://www.epa.gov/ttn/naaqs/oz one/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 Corre cting 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, Gener al 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 Implem ent 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.