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 Unified Air Pollution Control District, Rule 4605, Aerospace Assembly and Component Coating Operations

Prepared by: Adrianne Borgia Reviewed by: Andrew Steckel

August 2011- 2

-

RULE IDENTIFICATION

Agency: San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD)

SIP

- Approved Rule: Rule 4605

– Aerospace Assembly and Component Coating Operations

Amended

– September 20, 2007

Submitted

– March 7, 2008 Approved

– January 26, 2010, effective February 25, 2010 (75 FR 3996)

Subject of this TSD: Rule 4605

- Aerospace Assembly and Compone nt Coating Operations

Amended

– June 16, 2011

Submitted

– July 28, 2011

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

mo nitoring requirements.

On January 7, 2010, EPA finalized a limited approval/limited disapproval of SJVUAPCD Rule 4605. EPA identified the following rule deficiencies which prevented full approval: (1) the rule did not include seventeen of the specialty c oating limits that were included in

the relevant Control Technique Guideline (CTG), and (2) for two other specialty coatings the rule had higher limits than those provided in the CTG. EPA’s limited approval/limited disapproval action started sanctions cloc ks under section 179 of the Clean Air Act and 40 CFR 52.31. Unless EPA approves a subsequent SIP revision which corrects the deficiencies, offset sanctions will become effective August 25, 2011, and highway sanctions will become effective February 25, 2012

.

The primary purpose of the June 2011 rule amendment is to correct deficiencies identified by EPA in the January 26, 2010 (75 FR 3996) final rulemaking on the previous version of this rule. Changes from the approved SIP rule include the following:

1. New definitions were added in Section 3.0 including those for: Ablative Coating, Bearing Coating, Calking and Smoothing Compounds, Chemical Agent

- resistant Coating (CARC), Electromagnetic Interference (EMI) Coating, Intermediate Release Coating, Lacquer, M etalizing Epoxy Coating, Mold Release, Part Marking Coating, Rocket Motor Nozzle Coating, Screen Print Ink, Silicone Insulation Material, Specialized Function Coating, Thermal Control Coating and Wet Fastener Installation Coating.- 3

-

2. The following seventeen new products and corresponding VOC content limits were added to Table 1 of Section 5.1: Ablative, Bearing Coating, Caulking and Smoothing Compounds, Chemical Agent Resistant Coating, Electromagnetic Interference Coating, Intermediate Release Coating, Lacqu er, Metalized Epoxy Coating, Mold Release, Part Marking Coating, Rocket Motor Nozzle Coating, Screen Print Ink, Silicone Insulation Material, Specialized Function Coating, Thermal Control Coating, Epoxy Polyamide Topcoat and Wet Fastener Installation

Coati ng. Relabeled the header “Before January 1, 2013” and included a column for VOC limits effective after January 1, 2013. Footnotes were added exempting from certain limits coatings designated as “classified” by the Department of Defense and coatings used on space vehicles.

3. Lowered the VOC limits for two products in Table 1 of Section 5.1: (1) Fastener Sealants and (2) Sealant (Extrudable/Rollable/Brushable), effective January 1,

2013.

RULE EVALUATION CRITERIA

- We primarily used the following criteria to

e valuate the submitted rule:

1. Enforceability

- CAA section 110(a)(2)(A) requires that regulations submitted to EPA for approval into a SIP must be clear and legally enforceable.

2. Rule Stringency

– CAA section 172(c)(1) requires nonattainment areas to implem ent all reasonably available control measures (RACM), including such

reductions in emissions from existing sources in the area as may be obtained through the adoption, at a minimum, of reasonably available control technology (RACT), as expeditiously as pra cticable. In addition, under CAA section 182(b)(2)

, ozone nonattainment areas classified as moderate or above must implement RACT

for all VOC sources covered by a CTG document and all other major sources of

VOCs

. The SJVUAPCD regulates an ozone nonattainme nt area that is classified as

Extreme under both the one

- hour ozone and eight

- hour ozone standards. 40 C.F.R. § 81.305 (2010). 1 EPA’s CTG titled C ontrol of Volatile Organic Compound Emissions from Coating Operations at Aerospace Manufacturing and Rework Op erations (EPA

- 453/R

- 97

- 004, December 1997) (hereinafter “Aerospace CTG ”) covers many of the source s regulated under Rule 4605. In addition, EPA’s CTG

titled Control of VOC Emissions from Solvent Metal Cleaning (EPA

- 450/2

- 77

- 022, November 1977) (hereinafte r “Solvent Metal Cleaning CTG”) covers certain solvents regulated under Rule 4605. T herefore, submitted Rule 4605 must fulfill RACT requirements for VOCs.

3. SIP Revisions

- CAA section 110(l) prohibits EPA from approving any SIP

revision that would interfere with any applicable requirement concerning attainment

1 SJVUAPCD also regulates a nonattainment area under the 2006 24

- Hour PM 2.5 National Ambient Air Quality Standard (NAAQS) (40 C.F.R. § 81.305 (2010)). By December 14, 2012, California must submit a revision to the State Implementation Plan (SIP) for this nonattainment area that provides for, among other things, imple mentation of all RACM as expeditiously as practicable (CAA § 172(a)(2)(A), (b) & (c)(1), 74 FR 58689 (Nov. 13, 2009)). EPA will take action on this RACM demonstration in a separate rulemaking.- 4

- and reasonable further progress (RFP) or any other applicable requirement of the CAA. In addition, CAA section 193 prohibits the modification of any SIP

- approved control requirement in effect before No vember 15, 1990, in a nonattainment area.

In applying these criteria to the submitted rule, we referred to the following guidance and policy documents:

Issues Relating to VOC Regulation, Cutpoints, Deficiencies, and Deviations (the "Blue Book"), US EPA, OAQPS (May 25, 1988). Guidance Document for Correcting Common VOC and Other Rule Deficiencies

, EPA Region IX (August 21, 2001, the “Little Bluebook”). State Implementation Plans; General Preamble for the Implementation of Title I of

the Clean Air Act Amend

ments of 1990, 57 FR 13498 (April 16, 1992); 57 FR 18070 (April 28, 1992). Final Rule To Implement the 8

- Hour Ozone NAAQS

– Phase 2 , 70 FR 71612 ( Nov. 25, 2005).

EPA’s Aerospace CTG

. EPA’s Solvent Metal Cleaning CTG

.

In addition, we reviewed SJVUAPCD’s 20 09 RACT SIP Demonstration (April 16, 2009), as well as other state and local rules for this source category.

RULE EVALUATION

Enforceability

– The recordkeeping requirements for coatings and control system parameters, test methods and other requirements g enerally ensure that the submitted rule

can be enforced. Therefore, we propose to determine that submitted Rule 4605 is sufficiently clear and enforceable.

Stringency

– The Aerospace CTG contains EPA’s most recent identification of national presumptive RA CT for this industry. The VOC limits in amended Rule 4605 are as or more stringent than the VOC limits in this CTG, and we are not aware of significantly more stringent requirements in other analogous regulations.

Rule 4605 also identifies VOC content li mits for solvents that are not addressed by the Aerospace CTG

. Section 5.6 of the rule allows

, as an alternative to compliance with these

limits

, the use of a control system with efficiencies of at least 90% capture and 95%

control

. These efficiencies exce ed those of the Solvent Metal Cleaning CTG . In addition, compliance through use of such a control system must not result in emissions greater than

the VOC emissions that would have resulted if materials in compliance with the applicable

VOC limits had been used

.

Based on this and on information provided in SJVUAPCD’s 2009 RACT SIP analysis regarding other local and national rules and guidance , we believe that this rule fulfills CAA RACT requirements.- 5

-

SIP Revisions

- Because the seventeen coating categori es were added and VOC limits for two categories were lowered, the submitted rule is more stringent than the version previously approved into the SIP. We therefore propose to determine that our approval of the submittal would comply with CAA sections 110(l) and 193 because the submitted SIP

revision : (1) is more stringent than the rule previously approved into the SIP, (2) will insure equivalent or greater emission reductions of VOCs, and (3) will not interfere with the on

going process for ensuring that req uirements for RFP and attainment of the NAAQS are

met.

RULE DEFICIENCIES

– We have identified no deficiencies in submitted Rule 4605 sufficient for EPA to propose less than full approval. As a result, we believe relief from sanctions should be provided as quickly as possible.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION

- The following recommendations are not currently the basis for rule disapproval, but we encourage SJVUAPCD to consider them the next time the rule is amended:

1. Please consider m aking the following editorial changes in Section 3.0 to provide clear and complete definitions:

a. For consistency with subsection 3.10, refer to Rule 1020 (Definitions) for

the definition of ARB in subsection 3.11.

b. Remove “a” in the beginning of the definiti on of “Caulking and Smoothing Compounds” in subsection 3.16 as this definition is for the plural

“materials”.

c. Revise subsection 3.30 to define Wire Coating which is an application for both electrical and electronic wire and is consistent with the category in

Table 1 of Section 5.0.

d. In subsection 3.31, please correct the statement so that “the electrostatic applications are operated at a minimum 60 kV voltage

.

e. For consistency with the definition in the CTG, please change “component” to “components” in the definition of Non

- structural Adhesive in subsection

3.55.

f. For thoroughness, please add definitions for the following terms used in the rule: Epoxy Polyamide Coating, Electrical Radiation Coating, Electrostatic Discharge Protection, Wire Coating (unless cha nge noted in “c”) and Pre

Bonding Etching Wire Coating.

2. For consistency with the CTG exemptions, consider adding touch

- up operations to

Section 4.0.

3. For consistency and completeness please consider making the following changes

to Table 1 in Section 5.0:

a. T he staff report indicates that this rule applies to sprayable sealant but only

“extrudable/rollable/brushable” sealant is indicated in item 35. Please add a category for sprayable sealant in Table 1 or remove this category from the staff report.

b. For consis tency with the definition and with the CTG, please revise the category in item 43 as “Epoxy Polyamide Topcoat”.- 6

- c. Consider expanding sub

- item “a” of item 47 to be “ Electrical and Electronic” as it is likely both types of wiring will require coating.

d. The Dist rict has noted that the emission inventory for the source category of Aerospace Assembly and Component Coating Operations is 0.02 tons per day. Nevertheless, there are three instances where other districts have considerably lower VOC limits than SJVAPCD’s rule 4605. Consider adopting the lower VOC limits:

i. High Temperature Coating

- SMAQMD’s Rule 456 has a 420 g/l limit compared to SJVUAPCD’s 850 g/l.

ii. Rain Erosion Resistant Coating

– SMAQMD’s Rule 456 has a 600 g/l limit and VCAPCD’s Rule 74.13 has a 420 g/l limit compared to SJVUAPCD’s 800 g/l.

iii. Sealant (Extrudable/Rollable/Brushable)

- SCAQMD’s Rule 1124

has a 280 g/l limit compared to SJVUAPCD’s 600 g/l.

e. We recommend that the District add t hree specialty coating categories that

are listed in the CTG but not in the rule: Corrosive Prevention Compound, Cryoprotective Coating and Insulation Covering. The lack of these limits is not a deficiency that interferes with rule approval because t he District has confirmed both that these specialty coatings are not in us e at this time, and that the more stringent general category limit would be applied to any source which uses these specialty coatings. 2

4. In section 6.0, per the Little Bluebook (page 13), references to EPA

- approved state or local (i.e. district) methods s hould include the full title but may or may not specify the date of the version:

a. In Subsection 6.2.1, provide the title for ARB Method 432, “ Determination of Dichloromethane and 1, 1, 1

- Trichloroethane in Paints and Coatings .” (EPA approved date is Septemb er 12, 1989)

b. In Subsection 6.2.2, correct the title for ASTM Method D1613 to (Standard

Test Method ....)

c. In Subsection 6.2.6, provide the title for ARB Method 422, “ Determination of Volatile Organic Compounds in Emissions from Stationary Sources.” (EPA approv ed date is September 12, 1990).

EPA ACTION

- The submitted changes to Rule 4605 adequately correct deficiencies identified by the limited disapproval on the previous version of this rule and otherwise

fulfill the relevant CAA criteria for the reasons dis cussed above. As a result, EPA staff recommends a full approval of Rule 4605 pursuant to CAA section 110(k)(3).

2 Email from Sami r Sheikh (SJVUA PC D) to Andrew Steckel (EPA) da ted August 9, 2011.- 7

-

ADDITIONAL REFERENCES

– 1. SJVUAPCD Rule 4605, Aerospace Assembly and Component Coating Operations, as submitted on July 28, 2011.

2. SJVUAPCD Rule 4605, Aerospace Assembly and Component Coating Operations, as approved into the SIP on March 7, 2008.

3. “ Control of Volatile Organic Compound Emissions from Coating Operations at Aerospace Manufacturing and Rework Operations

, ” EPA

- 453/R

- 97

- 004,

Decem ber 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 Solv ent Metal Cleaning,” EPA

450/2

- 77

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

- 77

- 022_solvent_metal_cleanin g.pdf

5. “Reasonably Available Control Technology (RACT) Demonstration for Ozone State Implementation Plans (SIP)” SJVUAPCD, April 16, 2009.

6. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 19 88.

7. “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.