SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

 

Final Staff Report for 

 

PROPOSED AMENDED RULE 1132 – FURTHER CONTROL OF VOC

EMISSIONS FROM HIGH-EMITTIING SPRAY BOOTH FACILITIES 

May 2006 

Deputy Executive Officer 

Planning, Rule Development & Area Sources 

Elaine Chang, DrPH 

Assistant Deputy Executive Officer 

Planning, Rule Development & Area Sources

Laki Tisopulos, Ph.D., P.E. 

Planning and Rules Manager 

VOC Rule Development 

Larry Bowen, P.E. 

AUTHOR: Helmy Sultan, Ph.D. - Air Quality Specialist 

REVIEWED BY: Edward M. Muehlbacher, P.E. - Program Supervisor 

 Frances Keeler, Senior Deputy District Counsel 
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

GOVERNING BOARD 

Chair: WILLIAM A. BURKE, Ed.D. 

 Speaker of the Assembly Appointee 

Vice Chair: S. ROY WILSON, Ed.D. 

 Supervisor, Fourth District 

 Riverside County Representative 

MEMBERS:

MICHAEL D. ANTONOVICH 

Supervisor, Fifth District 

Los Angeles County Representative 

JANE W. CARNEY 

Senate Rules Committee Appointee 

BEATRICE J. S. LAPISTO-KIRTLEY 

Mayor, City of Bradbury 

Cities Representative, Los Angeles County/Eastern Region 

RONALD O. LOVERIDGE 

Mayor, City of Riverside 

Cities Representative, Riverside County 

GARY OVITT 

Supervisor, Fourth District 

San Bernardino County Representative 

JAN PERRY 

Councilmember, 9th District 

Cities Representative, Los Angeles County, Western Region 

MIGUEL PULIDO 

Mayor, City of Santa Ana 

Cities Representative, Orange County 

JAMES SILVA 

Supervisor, Second District

Orange County Representative 

CYNTHIA VERDUGO –PERALTA 

Governor’s Appointee 

DENNIS YATES 

Mayor, City of Chino 

Cities Representative, San Bernardino County 

 EXECUTIVE OFFICER

BARRY R. WALLERSTEIN, D.Env. 
TABLE OF CONTENTS 

Page 

 

I EXECUTIVE SUMMARY ..........................................................................1 

II BACKGROUND ..........................................................................................2 

III AFFECTED SOURCES ...............................................................................2 

IV CONTROL TECHNOLOGY .......................................................................3 

V PROPOSED AMENDMENTS.....................................................................5 

VI EMISSION IMPACTS .................................................................................5 

VII OPERATIONAL IMPACTS ........................................................................6 

VIII COST IMPACTS..........................................................................................6 

IX ENVIRONMENTAL IMPACT ASSESSMENT .........................................6 

X SOCIOECONOMIC ANALYSIS ................................................................7 

XI COMPARATIVE ANALYSIS.....................................................................7 

XII FINDINGS....................................................................................................7 

XIII COMMENTS AND RESPONSES...............................................................8 

XIV REFERENCES ............................................................................................10 
Final Staff Report 

PAR 1132 1 May 2006 

I. EXECUTIVE SUMMARY 

Proposed Amended Rule (PAR) 1132 – Further Control of VOC Emissions from HighEmitting Spray Booth Facilities was adopted on January 19, 2001, to reduce the volatile 

organic compounds (VOC) emissions from large aerospace, metal, plastics, wood 

products and composite manufacturing facilities. The rule applies to spray booth 

facilities that emit more than 20 tons per year (tpy) of VOC and requires 65 percent 

emission reductions. Rule 1132 allows a facility to demonstrate compliance through the 

use of an Alternative Compliance Plan and allows composite manufacturing facilities to 

use the Unified Emission Factors (UEF) table to calculate emissions under the plan. 

Composite manufacturing facilities are also subject to Rule 1162 - Polyester Resin 

Operations. Spray applications of resins and gel coats, in composite manufacturing, 

release a significant amount of monomer, resulting in VOC emissions. Emission rates 

are the highest when such materials are applied through atomized spraying techniques. 

Past amendments to Rule 1162 sought to reduce VOC emissions by limiting the 

allowable monomer content of resins and gel coats and requiring the use of nonatomizing 

spray application techniques. 

The AQMD conducted a Gel Coat Testing Program in 2004 to support implementation of 

Rule 1162 to develop a more appropriate and enforceable definition for the nonatomizing 

spray application technique of gel coats. Testing also demonstrated that emission 

reductions from the use of nonatomizing spray equipment at levels suggested by the UEF 

table (July 23, 2001) were not technically feasible. When operated at pressures necessary 

to obtain the UEF in the table, the product was inferior. When operated at pressures 

under which the product specifications could be met, no measurable emission reductions 

were obtained. On July 8, 2005, the Board adopted amendments to Rule 1162 that 

deleted the requirement to apply gel coats solely with nonatomizing spray application 

techniques and deleted the UEF table. 

To maintain consistency with the Board’s determinations in the Rule 1162 process, staff 

proposes to discontinue the emission rates for the gel coat nonatomizing spray 

application. In Rule 1132, the UEF table is used for approved emission factors to 

calculate emissions under an Alternative Compliance Plan. To date, no composite 

facility is using the nonatomized gel coat emission factor to demonstrate compliance 

under the Alternative Compliance Plan option or to report annual emissions to the 

AQMD. There is no actual impact other than preventing the use of an incorrect emission 

factor in the future. Staff also proposes to add a new definition and modify other 

definitions and rule requirements to enhance rule language accuracy, clarity and 

enforceability. 

The proposed amendments to Rule 1132 result in no impact on air quality or emissions 

limitations and will have no cost impacts. 
Final Staff Report 

PAR 1132 2 May 2006 

II. BACKGROUND 

Rule 1132 was developed to implement Phase I of Control Measure CTS-09 of the 1999 

Amendments to the 1997 Ozone State Implementation Plan (SIP). The rule applies to 

spray booth facilities that emit more than 20 tpy of VOC emissions in any emission 

inventory year beginning in 1999. Rule 1132 requires facilities to reduce plant-wide 

emissions by 65 percent through the use of an air pollution control system, reformulation 

of the sprayed materials to reduce the VOC emissions or a combination of a control 

system and reformulation. 

The rule was amended twice, on March 5 and May 7, 2004, to comply with U.S. EPA 

guidance for implementing section 110 of the federal Clean Air Act, which requires 

emissions reduction protocols, specifies criteria for determining source compliance and 

limits Executive Officer discretion. The 2004 amendments specified the calculation 

methods that facilities must use to demonstrate the 65 percent emissions reduction. 

These calculation methods rely on the use of the approved emission factors such as the 

UEF table to determine emissions. U.S. EPA has adopted the use of the UEF table that 

the composite industry may use to demonstrate compliance with the National Emission 

Standards for Hazardous Air Pollutants (NESHAP) for Reinforced Plastic Composite 

Production (40CFR, Part 63, Subpart WWWW) and for Boat Manufacturing (40CFR, 

Part 63, Subpart VVVV). 

The UEF table includes emission factors for nonatomizing gel coat applications that 

represent approximately 40 percent emissions reduction over the conventional gel coat 

spray application. The AQMD, from August through October 2004, conducted a testing 

program to develop an enforceable means to assure that in practice, nonatomized gel coat 

spray guns are being operated in a manner that achieves the emission reductions as 

represented by the UEF table. The AQMD Gel Coat Testing Program found that in order 

to obtain the emission reductions anticipated by the UEF table for nonatomized gel coat 

spray application, the application equipment would have to be operated at pressures that 

produced an inferior product surface that is not marketable. When nonatomizing 

application equipment is operated at pressures that produce products that meet composite 

industry specifications, the application equipment produced essentially the same 

emissions as conventional application methodology. Thus, the UEF table significantly 

underestimates emissions from nonatomized gel coat applications. On July 8, 2005, the 

Board adopted amendments to Rule 1162 that deleted the requirement to apply gel coats 

solely with nonatomizing spray application techniques. As a result of the AQMD study, 

U.S. EPA is re-evaluating the use of the UEF table for nonatomized gel coat application. 

III. AFFECTED SOURCES 

Proposed Amended Rule 1132 applies to spray booth facilities that emit more than 20 tpy 

of VOC in any emissions inventory year beginning in 1999. There are approximately 

seventy nine (79) spray booth facilities in the AQMD that are subject to PAR 1132. 

These facilities comprise aerospace, metal, plastic and wood products coatings, and open 

molding composite manufacturing operations. Based on the 1998-99, emissions 
Final Staff Report 

PAR 1132 3 May 2006 

inventory, staff has identified nineteen (19) composite manufacturing facilities that are 

subject to PAR 1132 (Rule 1132 Staff Report-2001). 

The annual VOC emissions inventory of the facilities subject to Rule 1132 includes 

emissions from coatings, solvents, adhesives, gel coats, resins and other VOC-containing 

materials. The VOC emissions from composite manufacturing facilities represent 

approximately 33 percent of the total emissions inventory of the PAR 1132 universe 

(10.5 tpd). These facilities are also subject to AQMD Rule 1162 - Polyester Resin 

Operations as well as Rule 1171 - Solvent Cleaning Operations. 

Since no composite manufacturing facilities are currently using the nonatomizing gel coat 

emission factor, the removal of this factor will have no impact on current alternative 

compliance plans. 

IV. CONTROL TECHNOLOGY 

In general, the most effective control of VOC emissions from the use of VOC-containing 

materials involves a combination of source reduction measures and the use of emission 

control systems. Source reduction includes a variety of measures that may be 

implemented at variable levels of effectiveness and difficulties due to factors such as 

complexity of operation, standards and specifications of the industry, and regulatory 

requirements. An efficient emission control system, on the other hand, requires the 

optimization of two main components, capture systems and control equipment. The 

overall efficiency of an emission control system is the product of the capture efficiency 

times the control efficiency. The following sections discuss each of the technologies that 

may potentially be used by the affected facilities to comply with the requirements of the 

proposed rule. 

Source Reduction

Reduction of VOC emissions at the source is perhaps the most preferred approach for 

many facilities. While source reduction alone may be limited in reducing facility-wide 

VOC emissions by a high percent, it may be, however, adequate to meet the proposed 

rule’s requirement in many cases. Typical source reduction measures include lower VOC 

gel coats and resins (filled resins and gel coats and vapor suppressed resins); high transfer 

efficiency application methods, such as nonatomizing spray application equipment for 

resin application; and other operation or production changes or limits. Although the 

feasibility, effectiveness and appropriateness may vary from facility to facility, the source 

reduction measures are usually examined first before considering add-on controls to 

comply with rule requirements. Add-on controls for composite manufacturing operations 

have high operating costs and normally would be considered only as a last resort. 

Capture of VOC-Laden Air

VOC-laden air from process area or emission points must be captured before it is directed 

to the air pollution control equipment. Capture efficiency refers to the ability of a 

ventilation system to capture and transfer any VOC released from a process area or 
Final Staff Report 

PAR 1132 4 May 2006 

emission point to the control device. If an emission point is in an enclosed area that 

meets the criteria set forth in U.S. EPA Method 204 for permanent total enclosures 

(PTE), the capture efficiency can be assumed to be 100 percent. Otherwise, source tests 

must be conducted to determine the capture efficiency. 

Control Equipment

Many control technology options are available for VOC emission controls including 

adsorption, thermal oxidation and catalytic oxidation. It is likely that only thermal 

oxidation would be considered for composite manufacturing operations since the gel coat 

and resin would foul the adsorption media or catalyst. 

Thermal oxidation is the process of oxidizing VOC by raising the temperature of the 

material above its auto-ignition point in the presence of oxygen, and maintaining it at 

high temperature for sufficient time to complete combustion to carbon dioxide and water. 

Time, temperature, turbulence (for mixing), and availability of oxygen all affect the 

performance of VOC oxidation systems. 

There are three basic types of thermal oxidation: direct flame, recuperative, and 

regenerative, each distinguished by its presence or lack of heat recovery as well as the 

type of heat recovery device utilized. 

Direct flame systems or flares rely on contact of the waste stream with a flame to achieve 

oxidation of the VOCs. These systems are the simplest thermal oxidizers and the least 

expensive to install, but require the greatest amount of auxiliary fuel to maintain the 

oxidation temperature, thus entailing the highest operating cost. Flares are useful for 

destruction of intermittent streams. 

Recuperative thermal oxidation systems use a tube or plate heat exchanger to preheat the 

effluent stream prior to oxidation in the combustion chamber. Thermal recovery 

efficiencies typically are limited to 40 percent to 70 percent to prevent auto-ignition in 

the heat exchange package, which could damage the package. Supplemental fuel 

therefore is usually required to maintain a high enough temperature for the desired 

destruction efficiency. Recuperative systems are more expensive to install than flares, 

but have lower operating costs. 

Regenerative thermal oxidation systems typically incorporate multiple ceramic heat 

exchanger beds to produce heat recovery efficiencies as high as 95 percent. An incoming 

gas stream passes through a hot bed of ceramic or other material, which simultaneously 

cools the bed and heats the stream to temperatures above the auto-ignition points of its 

organic constituents. Oxidation thus begins in the bed, and is completed in a central 

combustion chamber, after which the clean gas stream is cooled by passage through 

another ceramic heat exchanger. Periodically the flow through the beds is reversed, 

while continuous flow through the unit is maintained. Regenerative thermal oxidation 

systems are the most expensive thermal oxidizers to build, but savings in auxiliary fuel 

offset the added capital expense. 
Final Staff Report 

PAR 1132 5 May 2006 

V. PROPOSED AMENDMENTS 

PAR 1132 includes the following amendments: 

• Change the “APPROVED EMISSION FACTORS” definition (b)(1) to exclude 

the UEFs emission rates for gel coat nonatomizing application. The change is 

based on the AQMD Gel Coat Testing Program which demonstrated that when 

the nonatomizing spray equipment is operated at a pressure sufficient to meet 

the composite industry specifications, the emission reductions obtained were not 

statistically significant.

 The purpose of this amendment is to prevent the use of the UEF table for 

nonatomizing gel coat application in alternative compliance plans which staff 

has determined underestimates emissions from this application.

• Add a new definition “COMPOSITE MATERIAL” (b)(3) to include gel coat 

materials and clarify that the bonding between gel coat, resin and reinforcement 

elements can be of mechanical and/or chemical nature. Additionally, change 

definition (b)(4) “COMPOSITE MANUFACTURING FACILITY” for 

clarification.

• Change definition (b)(12) to read “RESIN is any thermosetting polymer...” 

instead of “RESIN is any thermosetting resin...” to enhance accuracy and 

clarity. 

• Delete the allowable method of fiberglass application from subparagraph (d)(1), 

since the chopper gun is the sole fiberglass application for the open molding 

composite operations. Rule 1162 (c)(1)(A) lists a number of allowable 

nonatomizing resin application methods that do not require the use of a chopper 

gun. 

• Delete the degree of roll-out from the subparagraph (d)(1) as it is practically 

infeasible to have different emission rates for different degrees of roll-out. 

Furthermore, the roll-out degrees are not a common practice in open molding 

composite operations. 

VI. EMISSION IMPACTS 

The proposed amendment will have no emissions impacts. The purpose of the 

amendment is to prevent facilities from underestimating emissions through the use of an 

inaccurate UEF. Thus, the amendment will ensure the emission reductions the original 

rule was designed to achieve. 
Final Staff Report 

PAR 1132 6 May 2006 

VII. OPERATIONAL IMPACTS 

AQMD records identify four (4) composite manufacturing facilities in the AQMD that 

have submitted an application to use the Alternative Compliance Plan option, Rule 1132 

paragraph (d)(1), to achieve compliance with PAR 1132. The final date to submit an 

application for an alternative compliance plan to demonstrate compliance with Rule 1132 

was July 1, 2004. None of these four facilities that submitted an application for use of 

the Alternative Compliance Plan option rely on the nonatomizing gel coat spray emission 

rates to demonstrate compliance with Rule 1132. 

Staff has also analyzed the emissions reported by Rule 1132 facilities for 2003/2004 and 

has determined that no existing facilities used the nonatomizing spray application 

emission factor to calculate and report emissions from gel coat spray operations. 

Therefore, no existing facility would emit at or above the 20 ton VOC per year Rule 1132 

applicability threshold solely as a result of the staff’s proposal to disallow the use of the 

nonatomizing spray application emission factor. 

Since no facilities are currently using the nonatomizing gel coat emission factor, the 

removal of this factor will have no impact on current alternative compliance plans. The 

main reason this amendment is needed is to prevent composite manufacturing facilities 

from using this emission factor in the future and thus underestimating actual emissions. 

VIII. COST IMPACTS 

The proposed amendments constitute no change to composite operations equipment, 

materials or processing requirements. Based on the composite manufacturing facilities 

that have utilized the alternative compliance option, none have used the nonatomized 

application emission factor to comply with Rule 1132. Removal of this factor will not 

have a cost impact since no existing facilities are using the nonatomized gel coat 

emission factor to demonstrate compliance under the alternative compliance plan option 

of Rule 1132. Therefore, there will be no cost impacts associated with the proposed 

amendments. 

IX. ENVIRONMENTAL IMPACT ASSESSMENT 

Staff has reviewed the proposed project pursuant to California Environmental Quality 

Act (CEQA) Guidelines §15002(k)(1). PAR 1132 would exclude the use of 

nonatomizing gel coat Unified Emission Factors (UEF) to calculate emissions for 

Alternative Compliance Plans, since the emission reductions were demonstrated not to be 

technically feasible by the Gel Coat Testing Program in 2004. SCAQMD staff has 

reviewed Alternative Compliance Plans submitted by composite manufacturing facility 

operators and found that nonatomizing gel coat emission factors has not been used to 

demonstrate compliance; therefore, the exclusion of the nonatomizing gel coat UEF 

emission factors would have no impact on alternative compliance plans. Therefore, it can 
Final Staff Report 

PAR 1132 7 May 2006 

be seen with certainty that there is no possibility that the proposed project may have a 

significant effect on the environment and, therefore, is exempt from CEQA pursuant to 

CEQA Guidelines §15061(b)(3). Upon approval of the proposed project, a notice of 

exemption will be prepared pursuant to CEQA Guidelines §15062 and sent for posting to 

the county clerks in the four counties within the jurisdiction of the SCAQMD. 

X. SOCIOECONOMIC ANALYSIS 

Since the proposed amendments to Rule 1132 result in no impact on air quality or 

emissions limitations and will have no cost impact, a socioeconomic impact analysis is 

not required. 

XI. COMPARATIVE ANALYSIS 

As required by California Health and Safety Code Section 40727.2, the following 

comparative analysis identifies and analyzes any federal or other AQMD rules that apply 

to the same equipment or source type as the proposed amendments. In addition to PAR 

1132, all composite operations in the AQMD, regardless of their yearly VOC emissions 

are also subject to Rule 1162-Polyester Resin Operations and the National Emission 

Standards for Hazardous Air Pollutants (NESHAP) for Reinforced Plastic Composite 

Production (40CFR, Part 63, Subpart WWWW) and for Boat Manufacturing (40CFR, 

Part 63, Subpart VVVV). A comparative analysis of these requirements with the 

proposed amendments is summarized in Table 1. 

XII. FINDINGS 

Before adopting, amending or repealing a rule, the AQMD shall make findings of 

necessity, authority, clarity, consistency, non-duplication, and reference, as defined in 

Health and Safety Code Section 40727. The draft findings are as follows: 

Necessity - The AQMD Governing Board finds and determines that it is necessary to 

amend Rule 1132 to disallow use of emission factor that could underestimate actual 

emissions. 

Authority - The AQMD Governing Board obtains its authority to adopt, amend or repeal 

rules and regulations from Health and Safety Code §§40000, 40001, and 40440. 

Clarity - The AQMD Governing Board finds and determines that Proposed Amended 

Rule 1132 is written and displayed so that the meaning can be easily understood by 

persons directly affected by it. 

Consistency – The AQMD Governing Board finds and determines that Proposed 

Amended Rule 1132 is in harmony with, and not in conflict with or contradictory to, 

existing statutes, court decisions, or federal or state regulations. 

Non-Duplication – The AQMD Governing Board has determined that Proposed 

Amended Rule 1132 does not impose the same requirements as any existing state or 
Final Staff Report 

PAR 1132 8 May 2006 

federal regulation, and the extent they overlap with NESHAP requirements are necessary 

to carry out the duty to adopt rules implementing the AQMP. 

Reference - In adopting these proposed amendments, the AQMD Governing Board 

references the following statutes which AQMD hereby implements, interprets or makes 

specific: Health and Safety Code Sections 40001 and 40440. 

XIII. COMMENTS AND RESPONSES 

The following comments were received after the public consultation meeting held on 

March 23, 2006: 

Comment 1 

We recommend for accuracy and consistency that several definitions reference the same 

or similar definitions in Rule 1162. 

Response 1 

With some exceptions, while the terms are used universally, such as definition of VOC 

and exempt compounds, the definitions in a specific rule typically do not reference 

another source specific rule so that the reader may understand the applicable terms 

without reading the entire rulebook. Often the term, for one rule may have different 

specific meaning than for other rules. The subject definition in Rule 1132 may have 

slightly different wording than similar definitions in Rule 1162 but are just as clear and 

accurate for the purpose of Rule 1132. 

Comment 2 

The new proposed footnote to Attachment A (the UEF emission factor table) should 

clarify that, for the purpose of demonstrating compliance with Rule 1132, the factors for 

atomized gel coat application except Gelcoat Non-atomized Application may be used for 

all gel coat spray operations. 

Response 2 

The footnote only prohibits the use of the Gelcoat Non-atomized Application emission 

factor. It does not apply to the other gelcoat emission factors listed. The other listed 

emission factors can continue to be used.

Comment 3 

We strongly disagree with the conclusion [as derived from the Preliminary Draft Staff 

Report] that the [nonatomized spray application] equipment is not capable of being 

operated to produce both lower emissions and acceptable product quality. While the 

current UEF system lacks an mechanism that ensures that non-atomizing gel coat 

application equipment is operated at the spray pressures needed to achieve the emission 

rates shown in the UEF table, ACMA is currently testing equipment to develop 

enforceable application parameters. The District should leave open the possibility that 

procedures will be developed that will allow sources to satisfy reasonable enforceability 

requirements while using the equipment to achieve both lower emissions and acceptable 

product quality. 
Final Staff Report 

PAR 1132 9 May 2006 

Response 3 

We may disagree on the interpretation of the results obtained from the AQMD Gel Coat 

Testing Program (April 2005) but staff believes the results clearly indicate that the 

nonatomizing spray application techniques of gelcoat did not produce an emission 

reduction compared to the use of conventional spray equipment when an acceptable 

surface quality was produced. Staff looks forward to working with the composite 

industry in developing a testing protocol and reviewing any data that demonstrates that 

gel coat application equipment can achieve lower emissions with acceptable product 

quality, as compared to the other emission factors listed in the UEF table. 

Comment 4

The staff report implies the use of non-atomized gel coat application is not allowed as a 

compliance option under the U.S. EPA NESHAP for composite manufacturing (40 CFR 

63 Subpart WWWW). 

Response 4 

PAR 1132 disallows the use of the nonatomizing gelcoat emission factor, as stated in the 

UEF table, to demonstrate compliance with Rule 1132 (and other AQMD rules and 

regulation such as reporting emissions pursuant to Regulation III - Fees). AQMD has 

received delegation authority from U.S. EPA to implement the NESHAP for composite 

manufacturing (which currently allows the use of the gelcoat nonatomizing emission 

factor, as stated in the UEF table). Notwithstanding District Rules and Regulations, 

AQMD will enforce the NESHAP as promulgated by U.S. EPA, including the use of the 

UEF Gelcoat Non-atomized Application emission factor unless U.S. EPA takes action to 

disallow it. 
Final Staff Report 

PAR 1132 10 May 2006 

XIV. REFERENCES 

South Coast Air Quality Management District, “Final Report for AQMD Gel Coat 

Testing Program Report” April 2005. 

South Coast Air Quality Management District, “Final Staff Report For Proposed 

Amended Rule 1162-Polyester Resin Operations,” July 9, 2004. 

South Coast Air Quality Management District, “Final Staff Report For Proposed 

Amended Rule 1162-Polyester Resin Operations,” July 11, 2003. 

South Coast Air Quality Management District, “Final Staff Report For Proposed 

Amended Rule 1162-Polyester Resin Operations,” November 9, 2001. 

South Coast Air Quality Management District, “Final Staff Report For Proposed 

Amended Rule 1132-Further Control of VOC Emissions from High-Emitting Spray 

Booth Facilities,” January 4, 2001. 

South Coast Air Quality Management District, “Final Staff Report For Proposed 

Amended Rule 1132-Further Control of VOC Emissions from High-Emitting Spray 

Booth Facilities,” May 7, 2004. 

R.A. Haberlein, “Technical Discussion of the United Emission Factors for Open Molding 

Composite,” Engineering Environmental, July 17, 2001. 
PAR 1132 11 

Table 1 - Comparative Analysis 

PAR 1132 AQMD BACT AQMD REGULATION 

XI 

40 CFR PART 63 

Subpart VVVV 

40 

Sub

Objective 

Further controls of VOC and HAP emissions beyond Regulation XI rules. 

Control VOC emissions from new and modified sources. 

Control VOC emissions. from different industrial operations. 

Control HAP emissions. Control H

Applicability

Applies to spray booth facilities, which emit > 20 

tpy of VOCs. 

Applies to new and modified equipment, such as a spray booth, which cause increase in VOC emissions. 

Rules 1107, 1145, 1124, 1136 and 1162 apply to coatings on metal, plastic, aerospace, wood products and composite operations, respectively. 

Applies to boat manufacturing composite facilities, which represent major source of HAPs. 

Applies treinforceplastic cointermed

Main Requirements

Reduces the VOC emissions from spray booth facilities by 65%. 

Maintains VOC emissions from spray booth facilities < 39 lb/day. 

Establishes VOC/monomer content standards for coatings, solvents, gel coat, resin and other VOC containing materials. 

Reduces 36% of HAP from a major source which emits 10 tpy of a single HAP or 25 tpy of combined HAPs. 

Reduces major sou100 tpy osingle HAcombined 

Compliance Options

- Pollution Prevention (P2) technologies 

 - Add-on control  - Combination between 

Pollution Prevention Technologies and Add-on Controls. 

Reduces VOC emissions by 90% using add - on control or low VOC materials. 

- Pollution Prevention (P2) technologies which include low VOC-containing materials and/or low emitting applications. - Use add-on control as an alternative compliance option. 

- Compliant materials - Add-on Control - Point Value Averaging 

-HAP limfor sourc- 95 % cosources ≤-Allows aHAP emi
PAR 1132 12 

Table 1 – Comparative Analysis (Cont’d) 

PAR 1132 AQMD BACT AQMD REGULATION 

XI 

40 CFR PART 63 

Subpart VVVV

4S

VOC/Monomer Content

Provides an Alternative Compliance Plan for composite operations with set forth monomer content for clear, white and off-white and pigmented gel coats. 

N/A Set forth different VOC 

requirements for coatings, solvents, adhesives, gel coats, resins and other VOC-containing materials. 

Describes the maximum Hap content (MHC) for Clear, white and off-white, nonwhite, pigmented gel coats and corrosion resistant resins. 

Descclearnonwgel cretarresisresin

Compliance Determination

Laboratory testing for monomer/VOC contents and source testing for add-on control system. 

Laboratory testing for VOC contents and source testing for add-on control systems. 

Laboratory testing for VOC contents and source testing for add-on control systems. 

Laboratory testing for monomer/VOC contents, source testing for add-on control system (every five years) and semi-annual compliance report. 

Labomonsourcontannu
 Table 2 

PAR 1132 13 

*Rule 1132 prohibits the use of the Gel Coat Non-Atomized Application emission

factors to calculate emissions