SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

Final Staff Report for

PROPOSED AMENDED RULE 1132 – FURTHER CONTROL OF VOC

EMISSIONS FROM HIGH-EMITTIING SPRAY BOOTH FACILITIE S

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 CounselSOUTH 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 R egion

RONALD O. LOVERIDGE Mayor, City of Riverside Cities Representative, Riverside County

GARY OVITT Supervisor, Fourth District San Bernardino County Representative

JAN PERRY Councilmember, 9 th 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 .....................................

................................................... ....10Final 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 Janu ary 19, 2001, to reduce the volatile organic compounds (VOC) emissions from large aerosp ace, metal, plastics, wood products and composite manufacturing facilities. T he rule applies to spray booth facilities that emit more than 20 tons per year (tp y) of VOC and requires 65 percent emission reductions. Rule 1132 allows a facility t o demonstrate compliance through the use of an Alternative Compliance Plan and allows co mposite manufacturing facilities to use the Unified Emission Factors (UEF) table to cal culate emissions under the plan.

Composite manufacturing facilities are also subject to Rule 1162 - Polyester Resin Operations. Spray applications of resins and gel c oats, in composite manufacturing, release a significant amount of monomer, resulting in VOC emissions. Emission rates are the highest when such materials are applied thr ough atomized spraying techniques. Past amendments to Rule 1162 sought to reduce VOC e missions by limiting the allowable monomer content of resins and gel coats a nd requiring the use of nonatomizing spray application techniques.

The AQMD conducted a Gel Coat Testing Program in 20 04 to support implementation of Rule 1162 to develop a more appropriate and enforce able definition for the nonatomizing spray application technique of gel coats. Testing also demonstrated that emission reductions from the use of nonatomizing spray equip ment 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 inf erior. 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 w ith nonatomizing spray application techniques and deleted the UEF table.

To maintain consistency with the Board’s determinat ions 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 f or 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 prevent ing 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 l anguage accuracy, clarity and enforceability.

The proposed amendments to Rule 1132 result in no i mpact 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 Con trol Measure CTS-09 of the 1999 Amendments to the 1997 Ozone State Implementation P lan (SIP). The rule applies to spray booth facilities that emit more than 20 tpy o f VOC emissions in any emission inventory year beginning in 1999. Rule 1132 requir es facilities to reduce plant-wide emissions by 65 percent through the use of an air p ollution control system, reformulation of the sprayed materials to reduce the VOC emission s or a combination of a control system and reformulation.

The rule was amended twice, on March 5 and May 7, 2 004, to comply with U.S. EPA guidance for implementing section 110 of the federa l Clean Air Act, which requires emissions reduction protocols, specifies criteria f or determining source compliance and

limits Executive Officer discretion. The 2004 amen dments specified the calculation

methods that facilities must use to demonstrate the 65 percent emissions reduction. These calculation methods rely on the use of the ap proved emission factors such as the

UEF table to determine emissions. U.S. EPA has ado pted the use of the UEF table that the composite industry may use to demonstrate compl iance with the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Reinforced Plastic Composite Production (40CFR, Part 63, Subpart WWWW) and for B oat Manufacturing (40CFR, Part 63, Subpart VVVV).

The UEF table includes emission factors for nonatom izing gel coat applications that represent approximately 40 percent emissions reduct ion over the conventional gel coat spray application. The AQMD, from August through O ctober 2004, conducted a testing program to develop an enforceable means to assure t hat in practice, nonatomized gel coat spray guns are being operated in a manner that achi eves the emission reductions as represented by the UEF table. The AQMD Gel Coat Te sting Program found that in order to obtain the emission reductions anticipated by th e 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 ma rketable. 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 techniqu es. 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 f acilities 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 AQM D 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, emissionsFinal Staff Report

PAR 1132 3 May 2006 inventory, staff has identified nineteen (19) compo site manufacturing facilities that are subject to PAR 1132 (Rule 1132 Staff Report-2001).

The annual VOC emissions inventory of the facilitie s subject to Rule 1132 includes emissions from coatings, solvents, adhesives, gel c oats, resins and other VOC-containing materials. The VOC emissions from composite manufa cturing facilities represent approximately 33 percent of the total emissions inv entory of the PAR 1132 universe (10.5 tpd) . These facilities are also subject to AQMD Rule 11 62 - Polyester Resin Operations as well as Rule 1171 - Solvent Cleaning Operations.

Since no composite manufacturing facilities are cur rently using the nonatomizing gel coat emission factor, the removal of this factor will ha ve no impact on current alternative compliance plans.

IV. CONTROL TECHNOLOGY

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

materials involves a combination of source reductio n measures and the use of emission control systems. Source reduction includes a varie ty of measures that may be implemented at variable levels of effectiveness and difficulties due to factors such as complexity of operation, standards and specificatio ns of the industry, and regulatory requirements. An efficient emission control system , on the other hand, requires the optimization of two main components, capture system s and control equipment. The overall efficiency of an emission control system is the product of the capture efficiency times the control efficiency. The following sectio ns 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 r eduction measures include lower VOC gel coats and resins (filled resins and gel coats a nd vapor suppressed resins); high transfer efficiency application methods, such as nonatomizin g spray application equipment for resin application; and other operation or productio n changes or limits. Although the feasibility, effectiveness and appropriateness may vary from facility to facility, the source reduction measures are usually examined first befor e considering add-on controls to comply with rule requirements. Add-on controls for composite manufacturing operations have high operating costs and normally would be con sidered 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 ef ficiency refers to the ability of a ventilation system to capture and transfer any VOC released from a process area orFinal Staff Report

PAR 1132 4 May 2006 emission point to the control device. If an emissi on 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 efficien cy.

Control Equipment

Many control technology options are available for V OC emission controls including adsorption, thermal oxidation and catalytic oxidati on. It is likely that only thermal oxidation would be considered for composite manufac turing operations since the gel coat and resin would foul the adsorption media or cataly st.

Thermal oxidation is the process of oxidizing VOC b y raising the temperature of the material above its auto-ignition point in the prese nce of oxygen, and maintaining it at high temperature for sufficient time to complete co mbustion to carbon dioxide and water. Time, temperature, turbulence (for mixing), and ava ilability of oxygen all affect the performance of VOC oxidation systems.

There are three basic types of thermal oxidation: d irect 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 t he waste stream with a flame to achieve oxidation of the VOCs. These systems are the simpl est thermal oxidizers and the least expensive to install, but require the greatest amou nt of auxiliary fuel to maintain the oxidation temperature, thus entailing the highest o perating cost. Flares are useful for

destruction of intermittent streams.

Recuperative thermal oxidation systems use a tube o r plate heat exchanger to preheat the effluent stream prior to oxidation in the combustio n 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 p ackage. Supplemental fuel therefore is usually required to maintain a high en ough temperature for the desired destruction efficiency. Recuperative systems are m ore expensive to install than flares, but have lower operating costs.

Regenerative thermal oxidation systems typically in corporate multiple ceramic heat exchanger beds to produce heat recovery efficiencie s as high as 95 percent. An incoming gas stream passes through a hot bed of ceramic or o ther 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 strea m is cooled by passage through another ceramic heat exchanger. Periodically the f low through the beds is reversed, while continuous flow through the unit is maintaine d. 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 a pplication. The change is based on the AQMD Gel Coat Testing Program which de monstrated that when the nonatomizing spray equipment is operated at a p ressure sufficient to meet the composite industry specifications, the emission reductions obtained were not statistically significant.

The purpose of this amendment is to prevent the us e of the UEF table for nonatomizing gel coat application in alternative co mpliance plans which staff

has determined underestimates emissions from this a pplication.

• 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 natur e. Additionally, change definition (b)(4) “COMPOSITE MANUFACTURING FACILITY ” for

clarification.

• Change definition (b)(12) to read “RESIN is any the rmosetting polymer...” instead of “RESIN is any thermosetting resin... ” to enhance accuracy and clarity.

• Delete the allowable method of fiberglass applicati on from subparagraph (d)(1), since the chopper gun is the sole fiberglass applic ation for the open molding composite operations. Rule 1162 (c)(1)(A) lists a n umber 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 dif ferent 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 impac ts. The purpose of the amendment is to prevent facilities from underestima ting emissions through the use of an inaccurate UEF. Thus, the amendment will ensure th e 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 manufactur ing facilities in the AQMD that have submitted an application to use the Alternativ e Compliance Plan option, Rule 1132 paragraph (d)(1), to achieve compliance with PAR 11 32. The final date to submit an application for an alternative compliance plan to d emonstrate compliance with Rule 1132 was July 1, 2004. None of these four facilities th at 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 R ule 1132 facilities for 2003/2004 and has determined that no existing facilities used the nonatomizing spray application emission factor to calculate and report emissions f rom gel coat spray operations. Therefore, no existing facility would emit at or ab ove the 20 ton VOC per year Rule 1132 applicability threshold solely as a result of the s taff’s proposal to disallow the use of the nonatomizing spray application emission factor.

Since no facilities are currently using the nonatom izing gel coat emission factor, the removal of this factor will have no impact on curre nt 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 t hus underestimating actual emissions.

VIII. COST IMPACTS

The proposed amendments constitute no change to com posite operations equipment, materials or processing requirements. Based on th e composite manufacturing facilities that have utilized the alternative compliance optio n, none have used the nonatomized application emission factor to comply with Rule 113 2. 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 imp acts 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 re ductions were demonstrated not to be technically feasible by the Gel Coat Testing Progra m in 2004. SCAQMD staff has reviewed Alternative Compliance Plans submitted by composite manufacturing facility operators and found that nonatomizing gel coat emis sion factors has not been used to demonstrate compliance; therefore, the exclusion of the nonatomizing gel coat UEF emission factors would have no impact on alternativ e compliance plans. Therefore, it canFinal 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, therefor e, 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 Guideli nes §15062 and sent for posting to the county clerks in the four counties within the j urisdiction of the SCAQMD.

X. SOCIOECONOMIC ANALYSIS

Since the proposed amendments to Rule 1132 result i n 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 Se ction 40727.2, the following comparative analysis identifies and analyzes any fe deral or other AQMD rules that apply to the same equipment or source type as the propose d amendments. In addition to PAR 1132, all composite operations in the AQMD, regardl ess of their yearly VOC emissions are also subject to Rule 1162-Polyester Resin Opera tions and the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Reinforced Plastic Composite Production (40CFR, Part 63, Subpart WWWW) and for B oat 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-dup lication, and reference, as defined in Health and Safety Code Section 40727. The draft fi ndings are as follows:

Necessity - The AQMD Governing Board finds and determines th at 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 t o adopt, amend or repeal rules and regulations from Health and Safety Code § §40000, 40001, and 40440.

Clarity - The AQMD Governing Board finds and determines th at Proposed Amended Rule 1132 is written and displayed so that the mean ing can be easily understood by persons directly affected by it.

Consistency – The AQMD Governing Board finds and determines th at Proposed Amended Rule 1132 is in harmony with, and not in co nflict with or contradictory to, existing statutes, court decisions, or federal or s tate regulations.

Non-Duplication – The AQMD Governing Board has determined that Pro posed Amended Rule 1132 does not impose the same requirem ents as any existing state orFinal Staff Report

PAR 1132 8 May 2006 federal regulation, and the extent they overlap wit h NESHAP requirements are necessary to carry out the duty to adopt rules implementing t he 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 publ ic consultation meeting held on March 23, 2006:

Comment 1
We recommend for accuracy and consistency that seve ral definitions reference the same

or similar definitions in Rule 1162.

Response 1
With some exceptions, while the terms are used univ ersally, 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 ter m, 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 comp liance with Rule 1132, the factors for atomized gel coat application except Gelcoat Non-a tomized 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 emi ssion factors listed. The other listed

emission factors can continue to be used.

Comment 3 We strongly disagree with the conclusion [as derive d from the Preliminary Draft Staff Report] that the [nonatomized spray application] eq uipment is not capable of being operated to produce both lower emissions and accept able product quality. While the current UEF system lacks an mechanism that ensures that non-atomizing gel coat application equipment is operated at the spray pres sures needed to achieve the emission rates shown in the UEF table, ACMA is currently tes ting equipment to develop enforceable application parameters. The District sh ould leave open the possibility that procedures will be developed that will allow source s to satisfy reasonable enforceability requirements while using the equipment to achieve b oth lower emissions and acceptable product quality.Final Staff Report

PAR 1132 9 May 2006 Response 3 We may disagree on the interpretation of the result s obtained from the AQMD Gel Coat Testing Program (April 2005) but staff believes the results clearly indicate that the nonatomizing spray application techniques of gelcoa t 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 revie wing any data that demonstrates that gel coat application equipment can achieve lower em issions 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 ge l coat application is not allowed as a compliance option under the U.S. EPA NESHAP for com posite manufacturing (40 CFR 63 Subpart WWWW).

Response 4 PAR 1132 disallows the use of the nonatomizing gelc oat 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 impl ement the NESHAP for composite manufacturing (which currently allows the use of th e gelcoat nonatomizing emission factor, as stated in the UEF table). Notwithstandi ng 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 facto r 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,” Nove mber 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, 200 1.Final Staff ReportPAR 113211May 2006Table 1 - Comparative AnalysisPAR 1132AQMD BACTAQMD REGULATIONXI40 CFR PART 63Subpart VVVV40 CFR PART 63Subpart WWWWObjectiveFurther controls of VOC andHAP emissions beyondRegulation XI rules.Control VOC emissionsfrom new and modifiedsources.Control VOC emissions.from different industrialoperations.Control HAP emissions.Control HAP emissions.ApplicabilityApplies to spray boothfacilities, which emit>20tpy of VOCs.Applies to new andmodified equipment, suchas a spray booth, whichcause increase in VOCemissions.Rules 1107, 1145, 1124,1136 and 1162 apply tocoatings on metal, plastic,aerospace, wood productsand composite operations,respectively.Applies to boatmanufacturingcomposite facilities,which represent majorsource of HAPs.Applies to the production ofreinforced and non-reinforcedplastic composite, as well asintermediate compounds.Main RequirementsReduces the VOC emissionsfrom spray booth facilities by65%.Maintains VOC emissionsfrom spray booth facilities< 39 lb/day.Establishes VOC/monomercontent standards forcoatings, solvents, gel coat,resin and other VOCcontaining materials.Reduces 36% of HAPfrom a major sourcewhich emits 10 tpy of asingle HAP or 25 tpy ofcombined HAPs.Reduces 43% of HAP from amajor source which emits >100 tpy of VOC or 10 tpy of asingle HAP or 25 tpy ofcombined HAPs.Compliance Options- Pollution Prevention (P2)technologies- Add-on control- Combination betweenPollution PreventionTechnologies and Add-onControls.Reduces VOC emissionsby 90% using add - oncontrol or low VOCmaterials.- Pollution Prevention (P2)technologies which includelow VOC-containingmaterials and/or lowemitting applications.- Use add-on control as analternative complianceoption.- Compliant materials- Add-on Control- Point Value Averaging-HAP limits listed in Table 1for sources < 100 tpy- 95 % control required forsources≤100 tpy-Allows average weightedHAP emissions limits.Final Staff ReportPAR 113212May 2006Table 1 – Comparative Analysis (Cont’d)PAR 1132AQMD BACTAQMD REGULATIONXI40 CFR PART 63Subpart VVVV40 CFR PART 63Subpart WWWWVOC/Monomer ContentProvides an AlternativeCompliance Plan for compositeoperations with set forthmonomer content for clear, whiteand off-white and pigmented gelcoats.N/ASet forth different VOCrequirements for coatings,solvents, adhesives, gelcoats, resins and otherVOC-containing materials.Describes the maximumHap content (MHC) forClear, white and off-white,nonwhite, pigmented gelcoats and corrosion resistantresins.Describes the MHC foeclear, white and off-white,nonwhite, and pigmentedgel coats and fireretardant, corrosionsresistant and high strengthresins.Compliance DeterminationLaboratory testing formonomer/VOC contents andsource testing for add-on controlsystem.Laboratory testing forVOC contents andsource testing for add-oncontrol systems.Laboratory testing forVOC contents and sourcetesting for add-on controlsystems.Laboratory testing formonomer/VOC contents,source testing for add-oncontrol system (every fiveyears) and semi-annualcompliance report.Laboratory testing formonomer/VOC contents,source testing for add-oncontrol system and semiannual compliance report.Final Staff ReportTable 2PAR 113213May 2006*Rule 1132 prohibits the use of the Gel Coat Non-Atomized Application emissionfactors to calculate emissions