                                                                                                                                                                                                       






                                       
                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                            REGION IX AIR DIVISION












                          Technical Support Document 
                                      for
                              EPA's Rulemaking
                                    for the
                     California State Implementation Plan
                                       
               San Diego County Air Pollution Control District 
             Rule 67.21, Adhesive Material Application Operations












                              
                        Prepared by: Christine Vineyard
                                September 2019





RULE IDENTIFICATION - 
Agency
San Diego County Air Pollution Control District (SDCAPCD)

New Rule Subject of this TSD
Rule 67.21  -  Adhesive Material Application Operations
Amended  -  May 14, 2008
Effective  -  November 14, 2008 

Submitted  -  August 9, 2017

Completeness Finding
Complete by operation of law: February 9, 2018


BACKGROUND  -  SDCAPCD regulates air quality in San Diego County, which is classified as a "Moderate" nonattainment area for the 2008 8-hour ozone National Ambient Air Quality Standard (NAAQS).  The Clean Air Act (CAA) requires that for areas classified as Moderate nonattainment or greater, the State must submit provisions to the State Implementation Plan (SIP) to require implementation  of reasonably available control technology (RACT)  for major sources of volatile organic compounds (VOCs), as well as all sources covered by a Control Techniques Guideline (CTG).  The following Environmental Protection Agency (EPA) CTG document covers a category of VOC sources regulated by Rule 67.21: "Control Techniques Guidelines for Miscellaneous Industrial Adhesives," EPA-453/R-08-005, September 2008.

RULE SUMMARY  -  Rule 67.21 establishes VOC content limits and workplace standards for the application of adhesives, sealants, and adhesive and sealant primers. It also describes related recordkeeping, reporting, and monitoring requirements. 

Rule 67.21 contains the following requirements:
1.	Applicability  -  includes all steps in adhesive material application operations including application, drying, and/or curing, surface preparation, stripping, cleanup materials and cleaning application equipment. 
                                          
2.	Exemptions  -  the VOC content, control equipment, and recordkeeping requirements shall not apply to:

	a.  adhesive materials used in single or multi-unit packages having a net weight of one pound or less or containing 16 fluid ounces or less; self-curing materials containing reactive diluents; adhesive materials containing less than 20 grams of VOC per liter; low-solids adhesive materials containing less than 20 grams of VOC per liter; aerosol adhesive materials.

	b.  The following adhesive material application operations are exempt from this rule:  tire repair; assembly and manufacture of undersea-based weapon systems; testing or evaluating of adhesive materials in any quality assurance or analytical laboratory; and plastic welding products used to manufacture medical devices.

	c.  The VOC content limit requirements for general adhesive materials shall not apply to any stationary source which uses less than 55 gallons per calendar year of all adhesive materials.

	d.  The VOC content limit shall not apply to non-compliant adhesive material usage in volumes less than 55 gallons per calendar year.

3.	Definitions are included to clarify the rule.

4.	Standards --Standards include VOC content limits for general adhesive materials, specialty adhesive materials, substrate-specific adhesives, and all other adhesive materials. (See section (d)(1) of rule 67.21.) There are also standards for surface preparation, stripping and clean up materials and adhesive bonding agents, cleaning of application equipment, and prohibitions of specification and sale. (See section (d)(2) of rule.) These provisions are summarized below:

	a.  Surface preparation materials requirements include <70 grams VOC per liter; 190 degrees C. or higher boiling point; and >45 mm Hg VOC vapor pressure at 20 degrees C.

	b.  Cleaning of application equipment is limited to VOC materials containing <70 grams VOC per liter; 190 degrees C. boiling point; and <45 mm Hg VOC vapor pressure.  A total enclosure shall be used during the washing, rinsing, and draining processes; or an alternative application cleaning method that is demonstrated to be as effective.

	c.  Prohibition of Specification  -  no adhesive material shall be specified for any operation subject to Rule 67.21 if it results in a violation of any provision of the rule.

	d.  Prohibition of Sale  -  Rule 67.21 prohibits the supply, sell, or offer for sale any adhesive materials listed in the General Adhesive Materials which exceeds the VOC limits listed, and where the adhesive materials will be applied in San Diego County.

5.	Control Equipment  -  in lieu of the requirements in the Standards section, a source may use an air pollution control system which:
	a.  Shall be installed in accordance with an Authority to Construct;
	b.  Includes an emission collection system;
	c.  Has a combined emissions capture and control device efficiency of at least 85% by weight; and
	d.  Implements an approved Operation and Maintenance Plan.

6.	Recordkeeping  -  all record shall be retained on site for at least 3 years and shall be made available upon request.  
	a.  anyone subject to the requirements for specialty adhesives, substrate-specific adhesives, all other adhesives, surface preparation, stripping and cleanup materials and adhesive bonding agents shall maintain the following records:
	- a current list of each material used;
	- daily or monthly records of the amount of each adhesive material used;
	- maintain monthly inventory records for each solvent used as an adhesive bonding agent, or stripping, surface preparation, or cleaning.

	b.  any person using control equipment shall:
	- maintain records in accordance with requirements for applicable adhesives, and daily records of key operating parameters as approved in the operation and maintenance plan.  Records must be sufficient to demonstrate compliance.

7.	Test Methods  -  measurement of VOC content, initial boiling point, capture efficiency, control device efficiency and calculations are determined by test methods included in the rule.

EVALUATION CRITERIA  -  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) and 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.	Stringency  -  SIPs must require RACT for each category of sources covered by a CTG document as well as each major source of VOCs in ozone nonattainment areas classified as moderate or above (see sections 182(b)(2)). EPA's CTG titled, "Control Techniques Guidelines for Miscellaneous Industrial Adhesives," (EPA-453/R-08-005, September 2008) ("2008 Industrial Adhesive CTG"), and other rules for this category were used to help evaluate the rule for compliance with the RACT requirements of CAA §182(b)(2). 

      3.	SIP Revisions  -  CAA §110(l) prohibits EPA from approving any SIP revision that would interfere with any applicable requirement concerning attainment or reasonable further progress (RFP) or any other applicable requirement of the CAA. In addition, CAA §193 prohibits the modification of any SIP-approved control requirement in effect before November 15, 1990, in a nonattainment area, unless the modification ensures equivalent or greater emission reductions of the relevant pollutant(s).
      
EPA EVALUATION  -  A summary of our evaluation of the three criteria follows:

      1. 	Enforceability  -  To help ensure enforceability, the rule requirements (VOC content limits) and applicability are clear, and the monitoring, recordkeeping, and other provisions sufficiently ensure that affected sources and regulators can consistently evaluate and determine compliance with Rule 67.21.  

      2. 	Stringency  -  The submitted rule is consistent with the 2008 Industrial Adhesive CTG requirements for applicability, adhesive and adhesive primer VOC content limits, work practices for adhesive related activities, work practices for cleaning materials, and 85% overall control efficiency.  Rule 67.21 has comparable recordkeeping requirements and test methods as San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) Rule 4653, Adhesives and Sealants and South Coast Air Quality Management District (SCAQMD) Rule 1168.  As a result, we propose to determine that this rule fulfills RACT requirements. 
      
      3. 	SIP Revisions  -  We propose to determine that our approval of the submittal would comply with CAA §§110(l) and 193 because (1) the proposed SIP revision adds VOC content limits, work practice standards, and would not interfere with any CAA requirements, including requirements for RFP and attainment of the NAAQS, and (2) the rule does not modify any pre-1990 requirements, therefore, §193 is not applicable. 

RULE DEFICIENCIES  -  The EPA finds no deficiencies that preclude full approval of the rule into the SIP. 

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.	Consistent with the 2008 Industrial Adhesive CTG and some local air districts, we recommend the next time Rule 67.21 is revised a requirement is included that one of the following application methods be used with the low-VOC adhesives and adhesive primers:
 HVLP spray.
 Flow coat.
 Roll coat or hand application, including non-spray application methods like hand or mechanically powered caulking gun, brush, or direct hand application.
 Dip coat (including electrodeposition).
 Airless spray.
 Air-assisted airless spray.
 Other adhesive application method capable of achieving a transfer efficiency equivalent to or better than that achieved by HVLP spraying.

EPA ACTION - The submitted Rule 67.21 strengthens the SIP, and the associated District staff report projects it will reduce VOC emissions from adhesive material application operations by approximately 390 tons per year (31%) (1.11 tons per day).  The rule meets the relevant CAA § 110 and part D requirements. Therefore, EPA staff recommends approval of Rule 67.21 pursuant to CAA §§ 110(k)(3) and 301(a). 

REFERENCES 

 "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.
 "Control Techniques Guidelines for Miscellaneous Industrial Adhesives," EPA-453/R-08-005, September 2008. http://www.epa.gov/ozonepollution/SIPToolkit/ctgs.html)
 SCAQMD Rule 67.21, Adhesive Material Application Operations, as amended on May 14, 2008 (effective November 14, 2008) and submitted to EPA on August 9, 2017.
 SJVUAPCD Rule 4653, Adhesives and Sealants, adopted September 16, 2010.
 SCAQMD Rule 1168, Adhesive and Sealant Applications, amended October 6, 2017.


