




                                       
                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                            REGION IX AIR DIVISION















                          Technical Support Document 
                                      for
                              EPA's Rulemaking
                                    for the
                     California State Implementation Plan
                                       
            Feather River Air Quality Management District Rule 3.14
                       Surface Preparation and Clean-Up









                              
                              Christine Vineyard
                                   July 2020
                                       
                                       





RULE IDENTIFICATION  -  
Agency
Feather River Air Quality Management District (FRAQMD)

SIP Approved Rule
Rule 3.14  -  Surface Preparation and Clean-Up
Amended  -  August 1, 2011 
Submitted  -  February 10, 2014
EPA Approved  -  April 23, 2015 (80 FR 22646)

Subject of this TSD
Rule 3.14  -  Surface Preparation and Clean-Up
Amended - August 1, 2016 
Submitted  -  January 24. 2017

Completeness Finding
Determination of Completeness letter:  April 17, 2017
              

BACKGROUND  -  The Feather River Air Quality Management District (FRAQMD or "District") is a bi-county agency that administers local, state, and federal air quality management programs for Yuba and Sutter Counties. Portions of the District have been designated as Severe nonattainment for failure to meet the federal 8-hour ground-level ozone national ambient air quality standard. See 40 CFR 81.305.  The Clean Air Act (CAA) requires the District to implement measures to reduce ozone precursors.  The District has committed as part of the 2009 Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan ("Sacramento Regional 2009 Ozone Plan") to reduce volatile organic compound (VOC) emissions from the use and application of automotive coatings.

RULE  SUMMARY  -   Rule 3.14, Surface Preparation and Clean-Up (SP&CU) limits volatile organic compound (VOC) emissions from operations associated with surface preparation, clean-up-and disposal of the materials used in SP&CU by using aqueous technologies, solutions using either compliant solvents and cleaning process techniques that limit VOC emissions.   

The FRAQMD revised Rule 3.14 to strengthen the SIP by incorporating the California Air Resources Board (CARB) Suggested Control Measure (SCM) for Automotive Coatings and Components.  The SCM adopted by CARB on October 20, 2005, combined coating categories and established lower VOC limits. The SCM recommended lowering the VOC limit to 25 from 50 grams per liter for solvents used in surface preparation, cleanup and cleaning of application equipment.  Not only do the solvents have to be compliant with the District limits, but recordkeeping and application requirements have to be satisfied. 

RULE REVISION  -  The following revisions were made to the SIP-approved rule:
1.  Lower the VOC limit to 25 grams per liter for solvents used in surface preparation and cleanup. (A.3.a.)
2.  Removes the 20 gallons or less use per calendar year exemption. 
3.  Adds Prohibition of Possession and Prohibition of Sale or Manufacturer. (D.1. and D.2. respectively).
4.  Adds active and passive solvent losses. (B.1, B. 31, and F.9)

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) 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 Control Technique Guideline (CTG) document as well as each major source of NOx or VOCs in ozone nonattainment areas classified as moderate or above (see sections 182(b)(2) and 182(f)).  Rule 3.14 was partially evaluated against EPA's Control Technique Guidelines (CTGs) titled, "Control of Volatile Organic Emissions from Solvent Metal Cleaning" (EPA-450/2-77-022, November 1977), "Control Techniques Guidelines for Industrial Cleaning Solvents" (EPA-453/R-06-001 September 2006), "Control of Volatile Organic Compound Emissions from Coating Operations at Aerospace manufacturing and Rework Operations" (EEPA-453/R-97-004), CARB's RACT/BARCT guidance titled, "Organic Solvent Cleaning and Degreasing Operations" (July 18, 1991), and other state and local rules for this category to help evaluate stringency.      
 
3.  SIP Revisions  -  CAA §110(l) prohibits EPA from approving any SIP revision that would interfere with any applicable requirement concerning attainment and 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  -  Rule 3.14 requirements and applicability are clear, and the monitoring, recordkeeping, reporting and other provisions sufficiently ensure that affected sources and regulators can consistently evaluate and determine compliance with the rule.    

2.   Stringency  -  The submitted rule lowers the VOC content limits to 25 grams per liter for solvents used in surface preparation and cleanup, removes the 20 gallons or less use per calendar year exemption, and prohibits the possession, manufacture, or sell of noncompliant products, making it more stringent than the SIP-approved rule.  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 would not interfere with any CAA requirements, including requirements for RFP and attainment of the NAAQS, and (2) the emission limits in the submitted rule are more stringent than the existing SIP-approved control requirements that they would replace.

RULE DEFICIENCIES  -  We have identified no deficiencies with Rule 3.14 sufficient for EPA to propose less than full approval.

EPA RECOMMENDATION
The following revision is not currently the basis for rule disapproval but is recommended for the next time the rule is amended:
      1.  Lower the VOC content limit for Aerospace Component product cleaning in paragraph C.1, Table 1, from 900 grams/liter (g/l) to 200 g/l or <= 45 mm Hg consistent with South Coast AQMD Rule 1171.

EPA ACTION
Rule 3.14 strengthens the SIP because Product Cleaning and Product Cleaning of Application Equipment VOC content limit was lowered from 50 g/l to 25 g/l. making it more stringent than the SIP-approved rule regulating surface preparation and clean-up with solvents.  The FRAQMD projects that Rule 3.14 will result in a reduction of 1.5 tons of VOC per year in the Sacramento Federal Nonattainment Area (SFNA) portion of the district.  The remaining northern portion of FRAQMD is projected to achieve a 28 ton per year VOC reduction.  The rule satisfies relevant CAA §110 and part D requirements. EPA staff recommends full approval into the SIP.

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 of Volatile Organic Emissions from Solvent Metal Cleaning," EPA-450/2-77-022, November 1977 (http://www.epa.gov/ozonepollution/SIPToolkit/ctgs.html )
 "Control Techniques Guidelines for Industrial Cleaning Solvents," EPA-453/R-06-001, September 2006 (http://www.epa.gov/ozonepollution/SIPToolkit/ctgs.html)
 SCAQMD Rule 100, Organic Solvents, as amended May 1, 2009 and submitted to EPA on June 1, 2009.
 SCAQMD Rule 100, Organic Solvents, as adopted on January 1, 2005, and approved into the SIP on May 1, 2005 (70 FR 47500). 
 "Organic Solvent Cleaning and Degreasing Operations," CARB, July 18, 1991.
