SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

APPENDIX C: RACT Analysis June 16, 2011

Final Draft Staff Report with Appendices For Proposed Amendments to Ru le 4605 C - 1 

## APPENDIX C

Reasonably Available Control Technology

(RACT) Analysis

June 16, 2011SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

APPENDIX C: RACT Analysis June 16, 2011

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APPENDIX C: RACT Analysis June 16, 2011

Final Draft Staff Report with Appendices For Proposed Amendments to Ru le 4605 C - 3 I. REQUIREMENTS OF ANALYSIS

The Clean Air Act (CAA) Section 182(b)(2) states th at ozone attainment plans shall assure that RACT for volatile organic compounds (VO C) is applied at certain sources. A RACT analysis requires an examination of a rule a gainst Federal rules, regulations, and technology guidelines as well as comparing it a gainst rules from other Districts in California. District Rule 4605 was compared to fed eral and state regulations and guidance. The following is a discussion of that an alysis.

II. ANALYSIS

EPA – Control Technique Guidelines (CTG)

1. The CTG EPA-453/R-97-004 1997/12 applies to Surface Coating Operations at Aerospace Manufacturing and Rework Operations located in marginal, moderate,

serious or severe ozone nonattainment areas that ha s the potential to emit greater than or equal to 25 tons/year of VOC, and equal to great er than 10 tons/year of VOC for

extreme ozone nonattainment areas. District Rule 46 05 is more stringent than the CTG limits for 34 categories. The proposed amendments to Rule 4605 will make it as stringent as the CTG in the 19 remaining categories . As such, District staff concludes that District Rule 4605 is more stringent than the CTG.

2. The CTG EPA-450/2-77-034 1977/12 applies to Surface Coating of Large Appliances operations located in marginal, moderate, serious o r severe ozone nonattainment areas that have the potential to emit greater than or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of V OC for extreme ozone

nonattainment areas.

Since this CTG applies to large appliance coating; therefore, it will not be compared to SJVAPCD Rule 4605 which covers aerospace coating.

3. The CTG EPA-450/2-77-022 1977/11 applies to VOC Emissions from Solvent Metal Cleaning operations located in marginal, moderate, serious o r severe ozone nonattainment areas that have the potential to emit greater than or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of V OC for extreme ozone

nonattainment areas.

This CTG applies to the use of the following degrea sing equipment: cold cleaners, open top vapor degreasers, and conveyorized degreasers. Identified in the CTG are design and work practice standards for cold cleaners, open top vapor degreasers, and conveyorized degreasers, for example: cover the sol vent tank, have a facility for waste solvent and draining cleaned parts, permanent label s on operating parts, close degreaser when not in use, drain parts until drippi ng ceases, no excessive splashing ifSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

APPENDIX C: RACT Analysis June 16, 2011

Final Draft Staff Report with Appendices For Proposed Amendments to Ru le 4605 C - 4 solvent is sprayed. The CTG also identifies add-on controls such as refrigeration

chillers and carbon control.

SJVACPD Rule 4605 identifies solvent VOC content li mits or a control system with efficiencies of at least 90% capture and 95% contro l, and that would not allow more emissions than if compliant materials were utilized . The general solvent limit is 200 g/L; the coating stripper solvent limit is currently 300 g/L.

Since the CTG does not identify control requirement s any more stringent than SJVACPD Rule 4605, District staff considers Rule 46 05 at least as stringent as the

CTG.

EPA – Alternative Control Technology (ACT) There is no ACT for this source category.

Standards of Performance for New Stationary Sources (NSPS) There is no NSPS for this source category.

National Emission Standards for Hazardous Air Pollu tants (NESHAPs) and Maximum Achievable Control Technologies (MACTs) NESHAPs and MACTs are requirements contained in 40 Code of Federal Regulations (CFR) Part 61 and 40 CFR Part 63. Since EPA has del egated the authority to implement NESHAP requirements to the District, NESH APs and MACTs promulgated by EPA are usually incorporated by reference into D istrict Rule 4002 (National Emission Standards for Hazardous Air Pollutants). It is imp ortant to mention that the District implements NESHAPs and MACTs by incorporating the e mission standards as conditions of the Permits to Operate issued to affe cted sources.

1. 40 CFR 63 Subpart GG (National Emission Standard s for HAPs: Aerospace Manufacturing and Rework Facilities) The requirements in this subpart are not directly c omparable to the District Rule 4605

VOC limits. The NESHAP HAP emission limits which ar e expressed in terms of percent HAP, HAP emission concentration, and mass (kg) of H AP per mass (kg) of solids are not directly comparable to the coatings VOC limit w hich is expressed in terms of grams (or lb) of VOC per liter (or gallons) of coatings, less water and exempt compounds, as applied. In addition, some HAPs may be exempt VOCs , and some VOCs may be
HAPs; therefore, there is no direct correlation bet ween the NESHAP limit versus District

Rule 4605 VOC limits.

How does District Rule 4605 compare to rules in oth er air districts?

District staff compared District Rule 4605 with the rules of other California ozone nonattainment air districts’ rules (listed below) f or aerospace operations in the 2009 RACT SIP, Chapter 4. The other major California no nattainment areas with similar

rules are as follows:SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

APPENDIX C: RACT Analysis June 16, 2011

Final Draft Staff Report with Appendices For Proposed Amendments to Ru le 4605 C - 5 A. South Coast Air Quality Management District (SCA QMD) Rule 1124 - Aerospace Assembly and Component Manufacturing Operations (Am ended September 21, 2001) B. Bay Area Air Quality Management District (BAAQMD ) Regulation 8 Rule 29 - Adhesive and Sealant Products (Amended December 20, 1995) C. Sacramento Metropolitan Air Quality Management D istrict (SMAQMD) Rule 456 - Aerospace Assembly and Component Coating Operations (Amended October 23, 2008) D. Ventura County Air Pollution Control District (V CPCD) Rule 74.13 - Aerospace Assembly and Component Manufacturing Operations (Am ended November 11, 2003)

No rule amendments have occurred since the 2009 RAC T Analysis was conducted. The 2009 analysis concluded that the District rule meet s RACT compared to other districts’ aerospace coating rules. The EPA TSD also concluded that Rule 4605 imposes very similar requirements to those in other large Califo rnia nonattainment areas. Even though Rule 4605 varies in stringency when compared to other Districts’ adhesive requirements, District staff concludes that Rule 46 05 is as stringent as or more stringent

than the other District Rules.

III. RESULTS OF ANALYSIS

After careful evaluation of federal rules and regul ations as well as prohibitory rules in other California nonattainment areas, District staf f concludes that District Rule 4605 satisfies RACT for aerospace assembly and component coating operations.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

APPENDIX C: RACT Analysis June 16, 2011

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