SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix C: Cost Effectiveness Analysis September 16, 2010

C-1 Final Staff Report with Appendices For Proposed Amendments to Ru le 4653 

## APPENDIX C

Cost Effectiveness Analysis

September 16, 2010SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix C: Cost Effectiveness Analysis September 16, 2010

C-2 Final Staff Report with Appendices For Proposed Amendments to Ru le 4653 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix C: Cost Effectiveness Analysis September 16, 2010

C-3 Final Staff Report with Appendices For Proposed Amendments to Ru le 4653 I. SUMMARY

Rule 4653 applies to any person who supplies, sells , offers for sale, or applies any adhesive product, or associated solvents for use wi thin the San Joaquin Valley Air Basin (SJVAB). Amendments to Rule 4653 would make the VOC content limits of some types of adhesives more stringent than they current ly are to fulfill commitments in the District 2007 Ozone Plan. Amendments to Rule 4653 will also add sealants and sealant primers to rule language as newly regulated sources

. The California Health and Safety Code 40920.6(a) re quires the San Joaquin Valley Unified Air Pollution Control District to conduct b oth an "absolute" cost effectiveness analysis and an “incremental” cost effectiveness an alysis of available emission control options prior to adopting each Best Available Retro fit Control Technology (BARCT) rule. The purpose of conducting a cost effectiveness anal ysis is to evaluate the economic reasonableness of the pollution control measure or rule as it applies to operators in the San Joaquin Valley Air Basin. The analysis also se rves as a guideline in developing the control requirements of a rule.

Incremental cost effectiveness is intended to measu re the change in costs (in $/year) and emissions reductions (in tons reduced/year) bet ween two progressively more effective control options or technologies. For thi s rule project, the limits are considered the lowest achieved in practice, therefore, no incr emental cost effectiveness analysis was conducted.

For this project the compliance costs are associate d with purchasing new adhesive, adhesive primer, sealant and sealant primer product s with complaint VOC content limits. District staff used available cost informa tion obtained from Internet searches, store visits, and staff reports from other Air Dist ricts to conduct a cost effectiveness analysis of the proposed-amendments to Rule 4653. Products with proposed adhesive and sealant VOC content limits are readily availabl e at the same price points as adhesives products with current VOC content limits that will become non-compliant upon rule implementation on January 1, 2012. Avail ability of product, combined with the proposed sell through period of 12 months for exist ing products and 24 month provision for use of no longer compliant materials has led st aff to conclude that there would be no significant adverse impacts on the profitability of businesses affected by the rule.

II. COST EFFECTIVENESS ANALYSIS

A. Absolute Cost Effectiveness Analysis

Absolute cost effectiveness of a control option is the added cost of a control technology or technique, divided by the emission reduction ach ieved (in tons reduced per year). The costs typically include capital equipment costs , engineering costs, labor and maintenance costs.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix C: Cost Effectiveness Analysis September 16, 2010

C-4 Final Staff Report with Appendices For Proposed Amendments to Ru le 4653 This cost effectiveness analysis accounts for the c osts associated with this ruleamending project. Proposed rule language indicates that the VOC content limits for certain adhesive categories will become more string ent on and after January 1, 2011. The costs associated with the amendments effective on and after January 1, 2011 were accounted for during the previous rule-amending pro ject to adopt EPA CTG requirements.

It is important to note that the proposed VOC conte nt limits for Adhesives and Adhesive Primers are not more stringent than existing VOC co ntent limits of the same adhesive categories in other air districts. The proposed VO C content limits have been in effect for several years in other air districts, for examp le, South Coast Air Quality Management District (SCAQMD), Bay Area Air Quality Management District (BAAQMD), San Diego Air Pollution Control District (SCAPCD), and Ventur a County Air Pollution Control District (VCAPCD). As indicated in table C-1, the proposed VOC content limits have been in rule language of adhesives rules in other a ir districts for five to eight years. Therefore, these products are readily available and currently sold in stores. Searches have indicated that the adhesives with the proposed VOC content limits are available in stores, and at the same price points as adhesives w ith VOC contents that will become non-compliant upon rule implementation on January 1 , 2012.

Table C-1 Adhesives Rules in Other Air Districts

Air District Adhesive Rule Number Rule Adoption Date Last Amendment

Date

BAAQMD Regulation 8 Rule 51 11/18/92 7/17/02 SDAPCD 67.21 12/16/98 5/14/08 SCAQMD 1168 4/7/89 1/7/05 VCAPCD 74.2 6/8/93 1/11/05

The following tables illustrate the adhesive produc t categories that would become more stringent with this rule-amending project effective on and after January 1, 2012. Also, Table C-4 indicates the new categories of sealants and sealant primers that would be added to rule language as newly regulated categorie s. The tables include current VOC content limits, as appropriate, and new VOC content limits that would become effective on and after January 1, 2012.

In Table C-2 some of the adhesive products listed a re currently regulated as a different adhesive category. These adhesive categories would be new to regulation even though the product is currently regulated under a differen t category. In such instances, the previous adhesive product category is listed in the second column of the table. Adhesives with an “n/a” listed for the 2011 VOC con tent limit are categories that are new to regulation and were previously unregulated.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix C: Cost Effectiveness Analysis September 16, 2010

C-5 Final Staff Report with Appendices For Proposed Amendments to Ru le 4653 Table C-2 Adhesive Categories with Current and P roposed VOC Content Limits

VOC Limit Effective on and after January 1, 2011 VOC Limit

Effective on and after January 1, 2012 Adhesive Category Previous Adhesive Category (Grams per Liter) (Grams per Liter) Multipurpose Construction 200 70
Ceramic Tile Adhesive 130 65
Cove Base Installation 150 50 Dry Wall and/or Panel Adhesive Multipurpose Constru ction 200 50
Ceramic Floor Tile Installation 130 65 Indoor Carpet Adhesive Floor Covering Installation 150 50 Carpet Pad Adhesive Floor Covering Installation 150 50 Rubber Flooring Adhesive Floor Covering Installatio n 150 60 Subfloor Adhesive Floor Covering Installation 150 5 0 VCT and Asphalt Tile Adhesive Floor Covering Instal lation 150 50 Wood Flooring Adhesive Floor Covering Installation 150 100
Non-Membrane Roof Adhesive n/a 300
Structural Wood Member Adhesive Multipurpose Construction 200 140
Contact Adhesive 250 80 Motor Vehicle Weatherstrip Adhesive n/a 750 Traffic Marking Tape Adhesive/ Primer Contact Adhesive/Adhesive Primer 250 150 Top and Trim Adhesive n/a 540 Thin Metal Laminating Adhesive n/a 780
Elastomeric Adhesive n/a 750 ABS Welding Adhesive 400 325 Cellulosic Plastic Welding Adhesive n/a 100 Styrene-Acrylonitrile Welding Adhesive n/a 100 Plastic Cement Welding Adhesive Primer 650 400 Other Plastic Cement Welding Adhesive 450 250
Automotive Glass Primer n/a 700SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix C: Cost Effectiveness Analysis September 16, 2010

C-6 Final Staff Report with Appendices For Proposed Amendments to Ru le 4653 Table C-3 VOC Content Limits for Adhesive Products

VOC Limit Effective on and after January 1, 2011 VOC Limit Effective on

and after January 1, 2012 Material Bonded
[Grams Per Liter] [Grams Per Liter]

Porous Materials 120 50

Plastic Foam 120 50 Fiberglass 250 80

Table C-4 VOC Content Limits for Sealants and Seal ant Primers VOC Limit Sealant Product (grams per liter) Architectural Sealant 250 Architectural Non Porous Sealant Primer 250 Architectural Porous Sealant Primer 775 Marine Deck Sealant and Sealant Primer 760 Modified Bituminous Sealant Primer 500 Non-Membrane Roof Sealant 300 Single-Ply Roof Sealant 450 Roadway Sealant 250 Other Sealants 420 Other Sealant Primers 750

B. Incremental Cost Effectiveness Analysis

Incremental cost effectiveness (ICE) is intended to measure the change in costs (in $/year) and emissions reductions (in tons reduced/y ear) between two progressively more effective control options or technologies. IC E compares the differences in costs and the differences in emissions reductions of cand idate control options. ICE does not reveal the emission reduction potential of the cont rol options. Unlike the absolute cost effectiveness analysis that identifies the control option with the greatest emission reduction, ICE does not present any correlation bet ween emission reductions and cost effectiveness. Therefore, the relative values pro duced in the ICE analysis and the absolute cost effectiveness values are not comparab le and cannot be evaluated similarly.

The District is required to conduct an ICE analysis for BARCT rules or emission reduction strategies in accordance with Health and Safety Code Section 40920.6 when there is more than one control option. No incremen tal cost increases are expected to occur since there are no other lower emission contr ol options. As such, staff did not conduct an ICE analysis.