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 4653, Adhesives and Sealants 

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel 

	September 2011

RULE IDENTIFICATION - 

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

SIP Approved Rule:	Rule 4653 – Adhesives 

Adopted –December 20, 2007

Submitted- March 7, 2008 

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 4653 – Adhesives and Sealants 

	Amended – September 16, 2010 

Submitted – April 5, 2011

RULE SUMMARY - SJVUAPCD Rule 4653, Adhesives and Sealants, is a rule
amended to reduce emissions of volatile organic compounds (VOCs) from
the application of adhesive products, sealant products and 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 4653
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:

Changed the title from “Adhesives” to “Adhesives and Sealants”
and included sealant products, as needed, in each section.

Added 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.

Clarified exemptions, added sealant exemptions and sales restrictions
and included effective dates for complying with the rule limits in
Section 4.0.

Revised Section 5.0 Table 1, adding columns for VOC limits for effective
dates through December 31, 2010 and after January 1, 2011. 

Added Section 5.0 Table 2 indicating lower VOC limits for adhesives
effective January 1, 2012.

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. 

Included Section 5.0 Tables 4 and 5 for sealant and sealant primer
limits.

Added Airless Spray to the list of application in Section 5.2.

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%. 

Added Section 5.3, Work Practices for Adhesive and Sealant Products.

Revised Table 6, VOC Limits for Organic Solvents Used in Cleaning
Operations, to list only the September 21, 2008 limits.

Replaced the section for Solvent Storage and Disposal Requirements with
a Work Practices for Solvent Cleaning. 

Added Section 5.8, Sell-through of Adhesives and Sealants and Section
5.9, Prohibition of Specification.

Removed the requirement of daily records of all adhesives, primers and
solvents used in each operation and added the requirement to record the
VOC content of all sealant materials stored at a stationery source.

Clarified labelling requirements in Section 6.2 to include all three
requirements and to add sealant products, effective January 1, 2012.

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.  

Stringency – EPA’s Control Technique Guideline (CTG) titled
“Control Techniques Guidelines for Miscellaneous Industrial
Adhesives” (EPA-453/R-08-005, September 2008), CARB’s RACT/BARCT
guidance titled, “Determination of Reasonably Available Control
Technology and Best Available Retrofit Control Technology for Adhesives
and Sealants” (December 1998), SJVUAPCD’s 2009 RACT SIP
Demonstration (April 16, 2009),and other state and local rules for this
category were used to help evaluate the RACT requirements of CAA
§182(b)(2).

SIP Relaxation - We have evaluated this SIP revision to determine
whether it would interfere with any applicable requirement concerning
attainment and reasonable further progress (RFP) or any other applicable
requirement of  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 unenforceable.
However, Rule 4653 could be improved by adopting language similar to
that of BAAQMD Rule 8-51 which specifies a requirement for
manufacturer’s product number, mix ratios of components in the product
used, and final VOC content as applied. 

Stringency – Rule 4653 closely resembles the 2008 CTG 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 generally reliable sources for identifying
RACT. In addition, several adhesive and sealant categories in Rule 4653
have VOC limits lower than the CTG. 

Further, Rule 4653 is generally as stringent as analogous requirements
in Bay Area (BAAQMD Rule 8-51(7-16-02)) 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 4653 implements
RACT and complies with CAA §182(b) (2).

SIP Relaxation – The VOC limits for several 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 Welding Adhesive, Plastic Cement Welding Adhesive Primer,
Other Plastic Cement Welding Adhesive and Plastic Foam. Consequently we
believe that the submitted rule is more stringent than the version
previously approved into the SIP. 

We propose to determine that our approval 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
submitted SIP revision is more stringent than the rule previously
approved into the SIP.

RULE DEFICIENCIES – We have not identified any deficiency in Rule 4653
sufficient for EPA to propose less than a 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.  

Please consider making the following changes to definitions in Section
3.0:

CARB’s definition of airless spray in the 1991 Automobile Refinishing
Coating compliance assistance program states that the Airless Spray
operates under high fluid pressure between 1500 and 3000 psi. Please
verify if the larger range indicated in the definition in Subsection 3.9
is accurate.

Please clarify whether cove base should be included in the Floor
Covering Installation definition of Subsection 3.43. 

In Subsection 3.85, for accuracy, we recommend that you add “as
determined by ASTM Method E260-96.” after “distensibility.” as
SMAQMD has done in their definition of plasticizer.  

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.

For completeness, and to be 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.” 

Consider the possibility of lowering the limits in Table 2 of Section
5.1:

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, Rubber Vulcanization Adhesive/Primer,
consider the possibility of lowering this limit to 250 g/l. 

The Motor Vehicle Weatherstrip 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. 

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.

Consider lowering the limit for PVC Welding adhesive to 500 g/l which is
consistent with the CTG. 

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:

Ceramic Tile Installation - SCAQMD has a 65 g/l limit compared to
SJVUAPCD’s 130 g/l limit.

Cove Base Installation - SCAQMD has a 50 g/l limit compared to
SJVUAPCD’s 150 g/l limit.

Multipurpose Construction - SCAQMD has a 70 g/l limit compared to
SJVUAPCD’s 200 g/l limit.

Top and Trim Installation - SCAQMD has a 250 g/l limit compared to
SJVUAPCD’s 540 g/l limit.

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. We recommend the District
consider lowering the limit for this category.

The CARB 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. 

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.

Please make the following changes for clarity and consistency as defined
in the Little Bluebook:

Per CARB Determination of RACT/BARCT for Adhesives and Sealants, Test 24
is applicable for non-aerosol adhesives. Please consider adding
“non-aerosol” before “adhesive products” in Subsection 6.3.1. 

CARB recommends SCAQMD Method 305-91, Determination of VOC in Aerosol
Applications, June 1993, 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
sealant products in Section 6.3.

CARB recommends SCAQMD Method 316A-92, Determination of VOC in Materials
Used for Pipes and Fittings, October 1996, for any plastic cement
adhesives or primers. Please refer to this test method for plastic
cement adhesive products in Section 6.3.

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 demonstrate  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.

In Subsection 6.3.3, the ARB method 422 reference should have the date
of the EPA-approved version which is Sept. 12, 1990. 

EPA ACTION - EPA staff recommends a full approval of Rule 4653 pursuant
to CAA §110(k) (3) and §301(a). 

ADDITIONAL REFERENCES – 

SJVAPCD Rule 4653, Adhesives and Sealants, as submitted on September 16,
2010.

SJVAPCD Rule 4653, Adhesives, as submitted on September 17, 2009.

Control Technique Guideline (CTG) titled “Control Techniques
Guidelines for Miscellaneous Industrial Adhesives” (EPA-453/R-08-005,
September 2008)	 HYPERLINK
"http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200809_voc_epa453_r-08-005_m
iscellaneous_industrial_adhesives.pdf"
http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200809_voc_epa453_r-08-005_mi
scellaneous_industrial_adhesives.pdf .

CARB’s RACT/BARCT guidance titled, “Determination of Reasonably
Available Control Technology and Best Available Retrofit Control
Technology for Adhesives and Sealants” (December 1998)	

	 HYPERLINK "http://www.arb.ca.gov/ractbarc/adhfinal.pdf"
http://www.arb.ca.gov/ractbarc/adhfinal.pdf .

SJVUAPCD’s 2009 RACT SIP Demonstration (April 16, 2009).

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

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

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