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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX

Technical Support Document

for

EPA’s Notice of Proposed Rulemaking

for the

California State Implementation Plan

Santa Barbara Air Pollution Control District

Rule 349, Polyester Resin Operations

August 27, 2013
SBCAPCD Rule 349 – Technical Support Document

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Rule Identification

Agency: 

Santa Barbara County Air Pollution Control District (SBCAPCD or District)

SIP Approved Rule: 

Rule 349, Polyester Resin Operations, Adopted April 27, 1993, Submitted to EPA 

November 18, 1993, Approved by EPA January 6, 1995 (60 FR 2025)

Subject of this Technical Support Document (TSD): 

Rule 349, Polyester Resin Operations, Amended June 21, 2012, Submitted to EPA 

September 21, 2012.

Rule Summary

This rule applies to any person owning or operating a commercial or industrial polyester 

resin operation. The amended rule includes lower polyester resin material monomer 

content limits and a higher add-on control equipment overall efficiency limit. It allows a 

24-month phase-in period. The rule is also amended to reflect revisions to Rule 330, 

Surface Coating of Metal Parts and Products and Rule 321, Solvent Cleaning Machines 

and Solvent Cleaning, which were also revised and submitted to EPA for approval on 

September 21, 2012. We are proposing approval of Rules 321, 330, and 349 in the same 

federal register notice. Please see the TSDs for Rules 321 and 330. 

Minimum requirements for Rule 349 include complying with specific limits on “asapplied” monomer content (percentage by weight) for polyester resin material and gel 

coats, or specialty resins, or polyester resin materials when using the open molding resin 

and gel coat process, or resins containing a vapor suppressant. Alternatively, the 

owner/operator may use a closed mold system, or install and operate an add-on control 

system. The rule specifies the types of spray allocation methods allowed and general

operating procedures, including cleaning, waste solvent disposal, spills, handling and 

transfer, and storage of polyester resin material, solvents or any waste material containing 

reactive organic compounds. The rule includes EPA-approved test methods and

recordkeeping and reporting requirements. It also includes requirements for solvent 

cleaning machines and cleaning. 

Exemptions include styrene use at less than 50 gallons per year, cleaning products with 

2% or less of VOCs or toxic air contaminants, operations with polyester resin materials 

that contain no VOC, solvents used in limited amounts for satellite and aerospace 

vehicles and components, and polyester resins used in lab operations. 

Santa Barbara County is attainment for the 1997 8-hour ozone National Ambient Air 

Quality Standard (NAAQS). The District lists 64 companies that may be affected by Rule 

349. (See Staff Report PARs 330, 337, 349, & 353, Table 1, June 21, 2012)

EPA Evaluation Criteria

The following criteria were used to help evaluate the control requirements in Rule 349:
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1. Enforceability – Section 110(a)(2)(A) of the Clean Air Act (CAA) requires that 

regulations submitted to EPA for incorporation into the SIP must be clear and 

legally enforceable.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 – CAA section 172(c)(1) specifies that SIPs for nonattainment areas 

must include RACT for sources of emissions. Section 182(b)(2) specifically 

provides that for nonattainment areas classified as moderate or worse, states must 

revise their SIP to include RACT for sources of VOC emissions covered by a 

Control Technologies Guideline (CTG) document issued after November 15, 

1900 and prior to the area’s date of attainment.

3. Non-interference - 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. 

EPA Evaluation

1. Enforceability – Rule 349 includes test methods, recordkeeping and reporting 

requirements similar to other SIP-approved rules in nonattainment areas, such as 

San Joaquin Valley Unified Air Pollution Control District Rule 4684 (77 FR 

5709), and adequately fulfills the CAA enforceability requirements.

2. Stringency – Santa Barbara County is in attainment for the federal ozone 

standard, therefore RACT requirements do not apply. However, we note that Rule 

349 includes requirements similar to those in other SIP-approved rules determined 

to meet RACT, such as SJVUAPCD Rule 4684. 

3. Non-interference – The revisions strengthen the SIP so this action will not 

interfere with the District’s ongoing efforts to ensure maintenance of the NAAQS. 

EPA Action

The submitted revisions to Rule 349 will help strengthen and clarify the SIP. 

SBCAPCD projects no significant emission impacts from these changes. The rule 

largely fulfills the relevant CAA section 110 requirements. EPA staff recommends 

approval of Rule 349 pursuant to CAA section 110(k)(3) and section 301(a).

References

1. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” 

(a.k.a., Bluebook) EPA OAQPS, May 25, 1988 (web citation).

2. “Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001 

(http://www.epa.gov/region09/air/sips/littlebluebook2001.pdf)
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3. State Implementation Plans; General Preamble for the Implementation of Title 

I of the Clean Air Act Amendments of 1990, 57 FR 13498 (April 16, 1992); 

57 FR 18070 (April 28, 1992). 

4. State Implementation Plans for Serious PM10 Nonattainment Areas, and 

Attainment Date Waivers for PM10 Nonattainment Areas Generally; 

Addendum to the General Preamble for the Implementation of Title I of the 

Clean Air Act Amendments of 1990, 59 FR 41998 (August 16, 1994). 

5. Rule 349, Polyester Resin Operations, SBCAPCD Staff Reports, June 21, 

2012