1 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 2 7 , 2013SBCAPCD Rule 349

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2 Rule Identification Agency:

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

SIP Approved Rule : Rule 349, Polyester Resin Operations

, A d opted 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 , S ubmitted to EPA September 21, 2012

.

Rule Summary This rule applies to any person owning or operating a commerc ial or indus trial polyester resin operation

. The amended rule includes lower polyester resin material monomer content limits and a higher add

- on control equipmen t overall efficiency limit. It allow s a 24

- month phase

- in period. The rule is also amended to r eflect 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 requirement s for Rule 349 include complying with specific limits on “as

applied” 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 ma terial 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 cont ain no VOC, solvents used in limited amounts for satellite and aero s pace vehicles and components, and polyester res ins 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 compa nies that may be affected by Rule

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

EPA Evaluation Criteria

T he following criteria were used to help evaluate the control requirements in Rule 349:SBCAPCD Rule 349

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3 1. Enforceability

– Section 110(a)(2)(A) of the Clean Air Act (CAA) requires that regulations submitted to EPA for incorporatio n 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 secti on 172(c) (1) specifies that SIP s for nonattainment areas

must include RACT for sources of emissions. Section 182(b)(2) specifically provides that for nonattainment areas classified as moderat e or wor se, states must
revise their SIP to include RACT for sources of VOC emissions co vered by a Control Technologies Guideline (CTG) doc u ment issued after November 15,

190 0 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 othe r 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 Uni fi ed Air Pollution Con trol District Rule 4684 ( 7 7 FR 5709) , and adequately fulfills the CAA enforceability requirements.

2. Stringency

– Santa Barbara County is in attainment for the federal oz one standard, therefore RACT requirements do not apply. However, we note that Rule

349 includes requirements similar to those in other SIP

- approved rules determine d 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 ma intenance 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

app roval 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 Docum ent 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 )SBCAPCD Rule 349

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4 3. Stat e 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, J une 21,

2012