SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

Final Staff Report for

PROPOSED AMENDED RULE 1162 - POLYESTER RESIN OPERAT IONS

July 8, 2005

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 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.Proposed Amended Rule 1162 i July 2005 TABLE OF CONTENTS

Page

EXECUTIVE SUMMARY ..................................

................................................... ............1

BACKGROUND .........................................

................................................... .....................2

AFFECTED SOURCES ...................................

................................................... ................3

PROPOSED AMENDMENTS................................

................................................... .........3

CONTROL TECHNOLOGY .................................

................................................... ..........4

EMISSIONS INVENTORY AND EMISSIONS FOREGONE......... .................................9

COST IMPACTS.......................................

................................................... .....................14

ENVIRONMENTAL ASSESSMENT ...........................

................................................... 14

SOCIOECONOMIC ANALYSIS .............................

................................................... .....15

COMPARATIVE ANALYSIS...............................

................................................... ........15

CONCLUSIONS AND RECOMMENDATIONS .................... ........................................15

DRAFT FINDINGS.....................................

................................................... ...................18

COMMENTS AND RESPONSES.............................

................................................... ....18

REFERENCES .........................................

................................................... ......................21

ATTACHMENT A: FINAL REPORT FOR AQMD GEL COAT TESTIN G PROGRAM

ATTACHMENT B: UNIFIED EMISSION FACTORS TABLE, July 23, 2001Final Staff Report

Proposed Amended Rule 1162 

### 1 July 2005 

### EXECUTIVE SUMMARY

The proposed amendments for South Coast Air Quality Management District (AQMD) Rule 1162 - Polyester Resin Operation will delete the re quirement to apply gel coats solely with nonatomizing spray application for gel coats and im prove rule language clarity.

On July 1, 2003, Rule 1162 required composite fabri cators to operate their nonatomizing spray application equipment at conditions that result in volatile organic compound (VOC) emissions at

or below the values stated in the Unified Emission Factors (UEF) table attached to the rule. The industry had documented to the AQMD that they were experiencing difficulty in implementing the requirement to apply gel coat with nonatomizing spray application equipment. Rule 1162 was last amended by the AQMD Governing Board on Jul y 9, 2004, to extend the effective date of the requirement for gel coat nonatomizing spray application from July 1, 2004, to July 1, 2005. The extension also allowed implementation of the March 2004, AQMD Governing Board directive to staff to conduct testing of equipment used in the nonatomizing spray application of gel coats (Rule 1132 Amendment Resolutions 2004) fo r the purpose of verifying the effectiveness of the nonatomizing application techn ique and selecting a more appropriate

definition for it.

In an effort to implement the Governing Board’s dir ection for testing, staff, in cooperation with American Composite Manufacturers Association (ACMA) , spray equipment manufacturers, gel coat manufacturers, and major composite fabricators developed the AQMD Gel Coat Testing Program Protocol. The objective of the testing pro gram was to develop a more appropriate and enforceable definition for the nonatomizing spray a pplication technique of gel coats. Testing included VOC emission and surface quality measureme nts (porosity, gloss, orange peel and water resistance tests) of gel coat sprayed materia ls. The four (4) major spray equipment manufacturers participated in the testing program, which was conducted from August through October 2004. Volatile Organic Compound (VOC) emiss ions were measured by AQMD staff. Surface quality analyses were conducted by staff of California Polytechnic State University, San Luis Obispo.

The Gel Coat Testing Program verified that the pres sure at the tip of the spray gun is a critical parameter affecting emission rates and quality of t he gel coat finish. Testing demonstrated that emission reductions from the use of nonatomizing sp ray equipment at levels suggested by UEF were not technically feasible. When operated at pr essures necessary to obtain UEF in the rule, the product was inferior. When operated at pressur es under which the product specifications could be met, the emission reductions obtained were not statistically significant. Based on the testing results, staff is proposing to delete the r equirement of application gel coats solely with nonatomizing spray application techniques.

The AQMD had previously estimated that the use of t he nonatomizing application equipment would reduce VOC emissions from gel coats sprayed b y Rule 1162 operations by approximately 0.43 ton per day. Additionally, a small use exempt ion of one gallon per day per facility has been added for an application that has been demonstrated to require the use of air spray equipment. Therefore, this amendment will result in foregone V OC emissions reductions of 0.45 tons per day.Final Staff Report

Proposed Amended Rule 1162 

### 2 July 2005 

### BACKGROUND

Rule 1162 requires open molding composite fabricato rs in the AQMD to use nonatomizing spray application techniques in applying resins and gel c oats by July 1, 2002 and July 1, 2005, respectively. Gel coat is a surface coating, formu lated from quick-setting polyester resin, that provides a cosmetic enhancement and protection to t he composite product. The emissions reduction of the nonatomizing spray application tec hnique was documented in several studies, in particular, the Composite Manufacturers Association (CFA) and Clean Manufacturing Technology and Safe Materials Institute (CMTI) test ing program. The CFA/CMTI studies included resins and gel coats in atomizing and nona tomizing applications. The CFA emission rates were measured as pounds of VOC per ton of spr ayed gel coats or resins. The results were published in the UEF table (2001). UEF rates estim ate the VOC emission reduction of the nonatomizing spray application technique of gel coa ts to be approximately 40% by weight as compared to the atomized applications.

Rule 1162 (b) (19) defines the nonatomizing spray a pplication technique as “any application technique in which resin or gel coat flows from the applicator, in a steady and observable coherent flow, without droplets, for a minimum dist ance of three (3) inches from the applicator

orifices”.

During the implementation of Rule 1162, gel coat no natomizing spray applications encountered difficulties in achieving the required three (3) in ches coherent flow, as specified in the definition. Staff also confirmed the same difficulties during R ule 1162 Technical Assessment study (January 2003) that addressed the feasibility of ge l coat nonatomizing application.

On July 11, 2003, the AQMD Governing Board amended the effective date for nonatomizing spray application for gel coats in Rule 1162 from J uly 1, 2003, to July 1, 2004, to allow for more testing of the gel coat nonatomizing spray applicat ion technique. The Gel Coat Testing Program was scheduled to be completed in March 2004. Howev er, on February 12, 2004, the spray equipment manufacturers unexpectedly withdrew from the program and the testing was suspended.

On July 9, 2004, the AQMD Governing Board amended t he effective date for the gel coat nonatomizing spray application requirement in Rule 1162 from July 1, 2004, to July 1, 2005, to allow for additional time to implement the Gel Coat Testing Program and develop an appropriate definition of the nonatomizing spray application te chnique of gel coat. At that time, an additional requirement was added that the nonatomiz ing spray application equipment be operated under conditions that ensure American Composite Man ufacturers Association (ACMA)

recommended UEF be obtained.

Throughout 2004, staff in cooperation with the ACMA , spray equipment manufacturers, gel coat manufacturers and major composite fabricators devel oped and conducted the Gel Coat Testing Program from August through October 2004. These te sts conclude that it is infeasible to meet the rule requirements with the technology specified . Staff does not have any indication that technology is being developed that will enable emis sion reductions anticipated for the rule to be obtained. The test report is included as Attachmen t A in this Staff Report.Final Staff Report

Proposed Amended Rule 1162 

### 3 July 2005 

### AFFECTED SOURCES

Proposed Amended Rule 1162 applies to all composite operations in the AQMD, which include but are not limited to, the manufacturers of the fo llowing:

• Bathtub, shower and vanity installations;

• Hulls for recreational and commercial watercraft;

• Bodies for recreational vehicles;

• Building panels and appliances;

• Sporting equipment and power tools;

• Automotive, aerospace and aircraft components; and

• Structural components for chemical process equipmen t and storage tanks.

Based on the1998-99 AQMD Emissions Inventory, staff has identified 81 composite facilities in the AQMD subject to Rule 1162. The annual emissions inventory of these facilities, based on the UEF (1999), is estimated to be 7.98 tons per day of VOC. Additionally, the 1998-99 Emissions Inventory indicates that 24 of the composite facili ties in the AQMD emit greater than 20 tons of VOC per year and utilize spray booth(s) in their op erations. These 24 facilities represent approximately 78% of the total VOC emissions from c omposite operations in the AQMD.



### PROPOSED AMENDMENTS

PAR 1162 includes the following amendments:

 Add paragraphs (b)(1), (b)(4) and (b)(15), the defi nition of the air-assisted airless spray, electrostatic application and high-volume, l ow-pressure spray, respectively. These techniques and other similar application tech niques that result in equivalent emission reductions are required to apply gel coat to an open mold surface.

 Delete paragraph (b)(20), the definition of nonatom izing spray application technique of gel coat. This technique is allowed but no long er required to apply gel coat materials to an open mold surface,

 Modify subparagraph (c)(1)(B) to delete the require ment of gel coat nonatomizing spray application technique, and the modified versi on of the U.S. EPA definition for nonatomizing application technique for gel coats as found in the National Emission Standard for Hazardous Air Pollutants (NESHAP) for Reinforced Plastic Composites Production (40CFR63 Subpart WWWW) and add the requi rement to apply gel coats using any applicable nonatomizing applications tech niques listed in subparagraph (c)(1)(A), air-assisted airless spray, electrostati c application or high-volume, low pressure spray application techniques.

 Modify paragraph (c)(4) to read “...hand-held spray g un which has a container for resin or gel coat ...” The amendment clarifies that a hand-held spray gun can also be used for gel coat touch-up and repair since such pr ocesses can not be performed using a paint brush application.Final Staff Report

Proposed Amended Rule 1162 

### 4 July 2005  Add subdivision (h), a small usage exemption for th e application of pin striping gel coat. This exemption will allow the use of air spr ay equipment in an application where lower emitting application techniques have not been successfully demonstrated to date.



### CONTROL TECHNOLOGY

Generally for coatings, nonatomizing spray applicat ion techniques reduce VOC emissions by applying the sprayed materials at significantly low er spray gun operation pressures with relatively larger droplets, minimizing significantl y the droplet numbers and their surface area, as compared to the atomized application. The nonatomiz ing application technologies include, nonatomizing spray application technologies, flow c oaters, pressure-fed rollers, resin impregnators and hand lay-up.



### CFA/CMTI Studies

Several recent studies were conducted to evaluate t he control efficiency of the nonatomizing application technologies. CFA/CMTI studies represe nt the most comprehensive evaluation of the emission rates of gel coats and resins applicat ions. These studied were conducted at the Clean Manufacturing Technology and Safe Materials I nstitute (CMTI), Purdue University.

These studies indicated that the use of the nonatom izing spray application technique to apply gel coats at certain operating pressures achieves an av erage VOC emissions reduction of about 40 percent, by weight. The emission rates of differen t applications of resins and gel coats were published in the UEF tables (1999 & 2001). The CFA /CMTI tests were conducted in a temperature controlled environment where the gel co at application temperature ranged from 69

to 80 o F. Also, the spray application performance or the surface quality of the composite products

was not included in the DFA/CMTI tests.



### AQMD Gel Coat Testing Program

In 2004, the AQMD conducted the Gel Coat Testing Pr ogram. The objective of the testing program was to determine the minimum range of press ure values at the tip of the nonatomizing spray gun that produces gel coat sprayed products w ith a satisfactory surface quality. The surface quality of the applied gel coat was also to be no less than the surface quality achieved when using an atomizing spray gun in accordance wit h the composite industry standards and

achieves the emissions rates stated in the UEF tabl e (2001) for composite manufacturers operating in the AQMD.

The program measured VOC emission rates, pressure a t the tip of the spray gun and surface quality using air-assisted airless and nonatomizing spray application equipment. The gel coats sprayed included clear, san bright white, midnight blue and sandable gray gel coats. The AQMD

tests utilized conditions as close to what are used in Southern California facilities as possible.Final Staff Report

Proposed Amended Rule 1162 

### 5 July 2005 AQMD Gel Coat Testing Program Protocol - Comparison to CFA Protocol

The AQMD determined that in order to meet the objec tive of the Gel Coat Testing Program, it was critical to develop a testing protocol that wou ld yield results and subsequent conclusions that are representative of gel coat spray applications a t composite manufacturing operations in the AQMD. Unlike many other regions of the United Sate s where composite manufacturing operations are conducted in temperature controlled environments to address wider variations in ambient temperature and humidity, operations in the AQMD do not air condition the manufacturing work areas. To address the seasonal temperature variations in southern California, it is becoming common practice for comp osite manufacturers to heat their gel coat prior to application. The heating of the gel coat lowers the viscosity, which according to the manufacturers, improves the consistency of the flow characteristics of the gel coat application.

With the testing program objective in mind, the AQM D worked with the Rule 1162 Testing Subgroup from July 2002 through June 2004 to develo p the AQMD Test Protocol for Nonatomizing Spray Application Techniques for Gel C oats to be used for the Gel Coat Testing Program (Attachment A). The AQMD protocol incorpor ated key elements of the CFA Styrene Emissions Test Protocol & Facility Certification Pr ocedures Revision 2.2 (March 1999), except for the following modifications:

Test Facility - Temperature of the Working Area

The CFA protocol states that the test chamber must be located in a temperature controlled environment. Previous CFA tests applied gel coat m aterials in a temperature controlled laboratory where the temperature ranged from 69 to 80 o F. The AQMD test applied gel coat in ambient temperatures, which ranged from 74 to 85 o F because that temperature range is representative of the conditions in the work areas for composite fabricators operating in the AQMD.

Test Enclosure

The cross sectional area of the spray booth doorway was reduced using 12 mil thick clear plastic in order to meet U.S. EPA Test Method 204 requireme nts for a temporary permanent enclosure. The CFA test protocol specified the use of a second blower to maintain laminar air flow at the surface of the test mold, with the air velocity ran ging from 50 to 100 feet per minute. Instead of using a second blower, the AQMD Gel Coat Testing Pr ogram used a baffle which was placed in front of the mold, as an alternative procedure to d ivert the air flow to maintain the specified range of air velocity at the surface of the test mo ld. (for a detailed description regarding the test spray booth dimensions and modifications, and lamin ar flow air measurements, please see Attachment A).

Test Mold Configuration and Size

The testing mold was similar in dimensions and conf iguration to the CFA test mold (for more detailed information concerning the test mold and t he air flow over its surface, please see Attachment A).Final Staff Report

Proposed Amended Rule 1162 

### 6 July 2005 Gel Coat (Liquid) Tip Pressure Measurement

The CFA test protocol does not specify the measurem ent of application pressure (pump or gun tip). The CFA test report contains pump pressure m easurements (exit pump pressure equals pump gauge pressure multiplied by pressure ratio). The composite industry expressed concern regarding the use of pump pressure in developing a definition for the nonatomizing spray application technique for gel coats. Their concern included length of the hose and pump ratios and how they can differ between composite manufactu ring facilities. Staff believed that the pressure at the tip of the gun, as applied, would b e a valid method to define nonatomizing spray application technique for gel coats. Staff conduct ed field studies to compare the exit pump and tip pressure measurements. These studies indicated that while changes in the spray hose length and diameter changed the exit pump pressure, they s howed no impact on the tip pressure of the gel coat spraying application equipment. The spray gun tip pressure represents a more accurate measurement of the pressure at which the gel coat m aterial is applied and that same pressure can be compared to a regulatory standard for compliance determination. Accordingly, staff chose to implement the tip pressure measurement in the AQMD Gel Coat Testing Program.

To implement the tip pressure measurements as requi red under the Gel Coat Testing Program, all spray guns tested were modified to include an adapt or installed before the tip of the gun to attach a liquid pressure gauge. The adaptor and the gauge were used only during the tip pressure measurements immediately prior to spraying/testing. The pressure gauges were precision, compact liquid pressure measurement units, and were calibrated according to the National Institute of Standard and Testing (NIST) standards.

Gel Coat Application Temperature

The composite industry in the AQMD typically operat es at ambient outdoor temperatures; most

facilities are not well insulated and are not air c onditioned. To address the diurnal temperature changes throughout the year, most operators are hea ting their gel coat materials to maintain more consistent spray applications. Field surveys condu cted by the AQMD during August and September 2002 determined that applying heat to gel coat materials reduces viscosity, minimize porosity, enhance materials coverage/wetting and im prove adhesion to the substrate. The Gel Coat Testing Program protocol requires that the app lication temperature of the gel coat material

be maintained between 80 and 90 o F, which were higher than the CFA/CMTI gel coat app lication temperature range of 69 to 80 o F.

VOC Emissions Measurement Equipment - Test Methods

I n addition to the U.S. EPA Test Method 25A, the AQM D Gel Coat Testing Program included additional, simultaneous VOC emissions sampling, as per SCAQMD Test Method 25.1. The AQMD protocol requires VOC emissions testing in tri plicate. The average of the two test methods results are represented in this report.

Some gel coat materials contained both styrene and methyl methacrylate. During the spraying/testing of these gel coats, additional gas samples were collected into evacuated canisters and were analyzed for both styrene and methyl metha crylate using U.S. EPA Test Method 18.Final Staff Report

Proposed Amended Rule 1162 

### 7 July 2005 Gel Coat Film Samples and Analyses

The CFA protocol did not include a requirement for qualitative or quantitative analyses for surface quality. The AQMD protocol required duplic ate samples to be collected simultaneously with the VOC emissions testing. A discussion of the sampling procedure, sample recovery and surface quality analyses can be found under the Sur face Quality Testing Methods section of the AQMD Gel Coat Testing Program. (Attachment A)

Pre-Test Spray Pressure Adjustments and Setting

Spray equipment manufacturers were directed to oper ate their equipment and apply gel coats at the lowest operating pressure settings, they believ ed was necessary to achieve an acceptable surface quality required by the composite industry. Prior to each nonatomizing gel coat spray test, AQMD staff observed the pre-test spray pressu re adjustments conducted by each spray gun manufacturer to determine the minimum gel coat spra y pressure to achieve the surface quality required by the composite industry. Each spray equ ipment operator commenced spraying gel coat at low pressure which produced a narrow spray pattern and surface with often accompanied gel coat sagging or streaming down the test surface . A sag or running is an indication that the application pressure is too low and that too much g el coat is applied at one point on the surface, resulting in an uneven surface that would not be ac ceptable to an end-user. The gel coated surface is the surface of the finished product that is seen, such as the top coat on a painted automobile. Paint running down the side of the car would be unacceptable. The operator would then gradually increase the spray pressure to the m inimum pressure setting that would achieve a spray surface that had a uniform coverage of gel co at at the thickness that would be acceptable to the end user. In summary, the pre-test spray press ure adjustment determined the minimum nonatomizing spray pressure below which the gel coa t surface quality will be unacceptable to the

end-user.

The average nonatomizing spray pressures used in th e AQMD Gel Coat Testing Program was higher when compared to the nonatomizing spray gel coat pressures used in the CFA/CMTI tests to develop the Unified Emission Factor for gel coat s (UEF 2001). This was unexpected since the gun manufacturers have stated that they have made i mprovements to their nonatomizing spray equipment since 2001. The CFA/CMTI and the AQMD te sts measured the nonatomizing gel coat spray pressure at the exit of the pump and the tip of the spray gun, respectively. Based on AQMD field observations, the exit pump spray pressu res of the CFA/CMTI tests were converted to spray tip pressures using the following equation : Estimated Spray Tip Pressure = Exit Pump Pressure x 0.65. The average measured pressure at t he tip of the spray gun was 440 pounds per square inch where the calculated tip pressure for t he CFA tests was 417 pounds per square inch.

AQMD Gel Coat Testing Program Results

As previously stated, the AQMD collected VOC emissi ons and gel coat film samples from August through October 2004 (Attachment A). Table 1 is a comparison of the VOC data collected, stated as an emission rate, and the emis sion rate that the UEF (2001) table would predict for the same gel coats that were tested by the AQMD. The AQMD emission rates listed summarize the emissions data for the four spray equ ipment manufacturers that sprayed four different gel coats using air-assisted airless and nonatomized spray equipment. The average measured pressure at the tip of the spray gun durin g the AQMD tests was 440 pounds per squareFinal Staff Report

Proposed Amended Rule 1162 

### 8 July 2005 inch whereas the calculated tip pressure for UEF da ta was 417 pounds per square inch. Surface quality testing, as part of the testing program, de monstrated that there was no measurable difference when using air-assisted airless and nona tomized spray equipment.

Table 1 shows that there were no discernable differ ences between the VOC emission rates of the air-assisted airless and nonatomizing applications when the nonatomizing is used at an application pressure high enough to achieve an acce ptable surface quality.

The AQMD Gel Coat Testing Program also included the collection and analysis of cured spray gel coat film samples. The samples were sent to Ca lifornia Polytechnic State University, San Luis Obispo for analysis. Surface quality analysi s included porosity and water resistance tests (using ANSI Z124), orange peel test (using Distinct ness of Image (DOI) orange peel panels), and Gloss (using ASTM D523). Surface quality analysis showed no significant differences between the air-assisted airless and nonatomizing applicati ons (for more detailed information, please see Attachment A).

The data collected through the Gel Coat Testing Pro gram demonstrates that it was technologically infeasible to apply gel coat materi als with nonatomizing spray application equipment at pressures needed to achieve the UEF em ission factors at the industry surface quality requirements.

Table 1

VOC Emission Rates Comparing Unified Emission Facto rs (UEF) and AQMD Testing Program for Gel Coat Air-Assisted Airless and Nonat omized Applications

VOC Emissions lb/Ton (Pounds of VOC per Ton of Sprayed Gel Coat)
Atomized Application Nonatomized Application Gel Coat Monomer

Content

% UEF AQMD UEF AQMD

Clear 40.9 460 438 268 457

San Bright White 30.8 274 373 177 306

Midnight Blue 32.9 293 233 196 209

Sandable Gray 27.3 243 223 145 207Final Staff Report

Proposed Amended Rule 1162 

### 9 July 2005 Granite-Filled Clear Gel Coat Spray

During the development of PAR 1162, composite facil ities which spray granite-filled clear gel coat to create granite-like surface expressed conce rns about the feasibility to comply with the nonatomizing spray application technique requiremen ts of Rule 1162. The larger diameter of the granite material in the clear coat could not pass t hrough the smaller diameter of the nonatomizing spray gun nozzles. Staff observed field tests wher e granite-filled clear gel coat was sprayed by a local spray equipment manufacturer using high-volum e, low-pressure (HVLP) spray equipment at an air pressure less than 10 psi. HVLP is a com pliant application technique listed in PAR

1162.



### EMISSONS INVENTORY AND EMISSIONS FOREGONE

Prior to November 17, 2001 Rule 1162 amendment, com posite fabricators applied gel coats using atomized spray applications such as air-assis ted airless and high-volume, low pressure spray application equipment. The Rule 1162 amendme nt in 2001 required fabricators to use the nonatomizing spray application technique for gel co ats and resins. The VOC emissions reduction associated with the nonatomizing spray ap plication technique of gel coats was

calculated based on the difference between the emis sion rates for the atomized and nonatomized spray application equipment listed in the UEF table (2001).

Current PAR 1162 deletes the requirement of nonatom izing application of gel coats. Therefore,

the VOC emissions reduction associated with the non atomizing spray application of gel coats (as part of November 17, 2001 Rule 1162 amendment) ar e now VOC emissions foregone.

Emissions Inventory of the Nonatomizing Spray Appli cation of Gel Coats

The emissions inventory/foregone associated with th e nonatomizing spray application of gel coats are calculated based on the following:

• The emissions inventory of gel coats is based on t he 1998-99 emissions inventory of composite operations in the AQMD. That inventory reflects a usage of 2,206.1 tons per year of gel coats.

• The emissions inventory of gel coats includes clea r and pigmented gel coats. Clear gel coats include marble clear gel coats and other clear gel coats. Pigmented gel coats include white and off-white gel coats and non - white gel coats.

• The emissions inventory of gel coats is based on c ompliance with the July 1, 2003, monomer content requirements for gel coats as follo ws: marble clear gel coats (40%), other clear gel coats (44%), white and off-w hite gel coats (30%), and nonwhite gel coats (37%). It also based on the ato mized application of gel coats.

• Clear and pigmented gel coats represent 15% and 85 %, respectively, of the total gel coats usage in composite operations in the AQMD dur ing 1998-99.

• White/off-white, and non-white represent 85% and 1 5%, respectively, of the total pigmented gel coats usage in composite operations i n the AQMD during 1998-99.

• Marble clear gel coats and other clear gel coats r epresent 35%, and 65%, respectively, of the total clear gel coats usage in the AQMD during 1998-99.Final Staff Report

Proposed Amended Rule 1162 

### 10 July 2005 • The emissions reduction of the nonatomizing applic ation for marble clear gel coats, other clear gel coats, white and off-white pigmente d gel coats, and non-white pigmented gel coats are calculated using the 2001 U EF (see Attachment B).

• The nonatomizing emissions reduction of gel coats is calculated using the gel coat emissions inventory and the emissions reduction eff iciency for the nonatomizing application of gel coats.

(1) Emissions Inventory From Gel Coats

Table 2 lists the VOC emissions from gel coats base d on the current Rule 1162 monomer content, and subcategories of gel coat materials af ter July 1, 2003, without the use of nonatomizing application technologies.

Table 2 VOC Emissions Inventory of Gel Coats Based on July 1, 2003 Monomer Content and without Nonatomizing Applicati ons

Specific Type of GelCoat, & SubCategory Allowed

Monomer Percentage in

Current Rule

after July 1, 2003
(%) Unified Emission

Factor a
(in pounds of styrene per tons of gel coat) Units

Adjustment

Factor
(1 ton = 2000 pounds) Estimated

Annual Total

Gel Coat Usage (in tons per year) Percentage of

Estimated Annual

Total Gel Coat Usage per Type & Sub-Category Projected VOC

Emissions From

Gel Coats (in tons per year)

Clear, for

marble

resins 40 (439 ÷ 2000) x 2206.10 x 0.15 x 0.35 = 25.42

Clear, for

other resins 44 (522 ÷ 2000) x 2206.10 x 0.15 x 0.65 = 56.14

Pigmented,

White and

Off White 30 (267 ÷ 2000) x 2206.10 x 0.85 x 0.85 = 212.79

Pigmented,

Non-White 37 (377 ÷ 2000) x 2206.10 x 0.85 x 0.15 = 53.02

a) UEFs for Open Molding of Composites, July 23, 2001 ( see Attachment B) TOTAL 347.37

(2) Efficiency of Nonatomizing Application of Gel C oats

The efficiency of gel coats nonatomizing applicatio ns are calculated using the (E atm ) the emissions of atomizing application and the (E

non. ), emissions of nonatomizing application, for each gel coat as follows:

Efficiency of Nonatomizing Application = (E atm. – E
non. /E atm.) x 100

(A) Clear Gel Coats:

(I) Marble Resins (40% monomer content) (439-259/439) x 100 = 41%Final Staff Report

Proposed Amended Rule 1162 

### 11 July 2005 (II) Other Resins (44% monomer content) (522-296/522) x 100 = 43.30%

(B) Pigmented Gel Coats:

(I) White and Off-white (30% monomer content) (267-169.36/267) x 100 = 36.57%

(II) Non-white (37 % monomer content) (377-232/377) x 100 = 38.46%

The emissions reductions of the nonatomizing applic ation of gel coats are calculated using the emissions inventory and nonatomizing application ef ficiency of each gel coat. Table 3 illustrates the emissions inventory and reduction of gel coats.

Table 3 VOC Emissions Inventory and Emission Reductions fro m Gel Coats

Gel Coat /Monomer Content Atomizing

Emissions Inventory (tpy) % of Nonatomizing

application Efficiency Nonatomizing

Emission

Reductions (tpy)

Marble Gel Coats/40% 25.42 41.00 10.42

Other Gel Coats/44% 56.14 43.30 24.31

White and Off-White Gel Coats/30% 212.79 36.57 77.82

Non-White Gel Coats/37% 53.02 38.46 20.39

Total 347.37 132.94

The VOC emissions inventory associated with the non atomizing spray application technique of gel coat is 132.94 tpy or 0.43 tpd. Therefore, the emissions reductions foregone due to the deletion of the requirement of the nonatomizing spr ay application technique of gel coat is 0.43 tpd.

Emissions Foregone Resulting from Proposed Exemptio n

Calculation of the Emission Rate of the Air Spray A pplication

The UEF (2001) table does not specifically list gel coat emission rates for air spray equipment. Additionally, staff has not identified any other so urce of published emission rates for gel coat using air spray equipment. However, the emission r ate for the air spray application can be calculated using the emission rates of the air-assi sted airless spray, referred to “gel coat application” in the UEF (2001) table, the transfer efficiency of both the air spray and air-assisted airless spray applications and the following assump tions and analysis:

• Each composite part requires one gallon of gel coat

.Final Staff Report

Proposed Amended Rule 1162 

### 12 July 2005 • 100 gallons of gel coat sprayed using air air-assis ted airless application (40% transfer efficiency) to produce 40 composite parts.

• 100 gallons of the same gel coat sprayed using an a ir spray gun (24% transfer efficiency) on the same composite parts will produc e 24 parts.

• To complete the spraying of the other 16 parts (40 -24) using an air spray gun, the operator needs to increase his usage of gel coat ma terials.

• The amount of gel coat materials required to spray the 40 parts using air spray is calculated to be 166.7 gallons (100 gallons x 40/ 2 4).

• The amount of gel coat materials required to produc e 40 composite parts using air spray and air-assisted airless spray applications a re 166.7 and 100 gallons, respectively.

• The VOC emission of both air spray and air-assisted airless spray applications is proportional to the gel coat materials usage

Therefore the relationship between the emission rat e of the air-assisted airless spray (E 1 ) and the emission rate of the air spray application (E 2 ) can be illustrated as follows:

E 2 = E 1 x 1.67

where:

E1 = The air-assisted airless emission rate of the UEF table(2001), in pounds of VOC per pound of gel coat sprayed using the gel application

E2 = The spray emission rate, in pounds of VOC per pound of gel coat sprayed

The emission rates using air-assisted airless spray (E1) and air spray (E2) application equipment for pin striping/multi color gel coat (37% monomer content) are 0.1885 and 0.3148 pounds of VOC per pound of sprayed gel coat materials.

Emissions Foregone Due to Pin Striping Exemption

Pin striping is a spray application technique used to apply one or more narrow bands, marks or streaks of gel coats onto the surface of boats, amu sement park structures and other composite products for decorative or identification purposes. The gel coat used for pin striping may be different in color or texture than the surrounding areas of the composite product.

In the pin stripe spray application procedure, the operator will mask off a specific area to define the bands, marks or streaks dimensions on the spray mold of the composite product. After the application of the striping gel coat(s), the operat or will continue the build up of the composite products (spray gel coat, resin and fiberglass).Final Staff Report

Proposed Amended Rule 1162 

### 13 July 2005 The proposed pin striping exemption allows pin stri ping gel coat spray onto pleasure watercraft, amusement park fixtures and structures, using cup-g uns or other air spray application equipment.

• Affected sources include twenty facilities (seven b oat manufacturers, three amusement parks, and ten additional pin striping fa cilities staff has identified based on the potential future need to conduct pin stripin g spraying within the composite industry universe in the AQMD).

• Exemption limited to one gallon of gel coat per day per facility.

• A hand-held cup gun provides the best performance f or pin striping or thin line application, minimizes the amount of solvent needed for clean up whenever a change in color is needed (as compared to air-assisted air less spray gun or any other spray application listed in PAR 1162.

The calculation of VOC emissions foregone resulting from the limited usage exemption of pin striping to the requirement of lower emitting gel c oat application technology is summarized in

Table 5.

Table 5

VOC Emissions Foregone Due to the Exemption Air Spray Versus Air-Assisted Airless Spray

Pin Striping

Category Existing
Source Potential

Sources

Gel Coat Pigmented Pigmented

Monomer Content Percent 37 37 Exemption, Gallons per Day per Facility 1 1 Average Pounds per Gallon 10.65 10.65 Exemption, Pounds per Day Per Facility 10.65 10.65 Difference in Emission Rate (E 1 -E 2 ) 0.1263 0.3148

Number of Affected Sources 10 10 Emission Foregone, Pounds per Day 13.45 33.53

The total VOC Emissions Foregone due to the Propose d Exemption = 46.98 pounds per day or 0.02 ton per day.

Therefore, the proposed amendments, including the d eletion of the requirement of nonatomizing spray application of gel coat and the pin striping exemption will result in VOC emissions reductions foregone of 0.45 tpd.Final Staff Report

Proposed Amended Rule 1162 

### 14 July 2005 

### COST IMPACTS

There will be no cost impacts associated with the p roposed amendment because the existing equipment can be used by the industry.



### ENVIRONMENTAL ASSESSMENT

The proposed project consists of two parts: rescin ding the nonatomized gel coat application technique requirement and introducing a n exemption for gel coat pin striping operations. The AQMD was the lead agency and prepa red a Final Supplemental Environmental Assessment (SEA) and Final EA for the July 8, 2005 modifications to Rue 1162. The Final SEA and Final EA were prepared pur suant to CEQA Guidelines §15252 and the AQMD’s certified regulatory program (AQMD R ule 110). The purpose of the Final SEA and Final EA was to describe the proposed project and to identify, analyze, and evaluate any potentially significant adverse en vironmental impacts that could have resulted from adopting and implementing the propose d amendments to Rule 1162.

The Draft SEA (SCAQMD No. 050316JK, dated March 16, 2005) was prepared for rescinding the nonatomized gel coat application tec hnique requirement because this proposal was considered to be a modification of a p reviously approved project. The Draft EA was circulated to the public for a 45-day review and comment period from March 17, 2005 to May 3, 2005. The only environmen tal topic where significant adverse impacts were identified was air quality. Rescindin g the nonatomizing gel coat application technique requirement would permanently forego the previously expected 853 pounds of styrene emission reductions per day, which exceeds the AQMD VOC significance threshold of 55 pounds per day. In ad dition, acute and chronic noncarcinogenic risk associated with styrene emissi ons would exceed the AQMD’s hazard index significance threshold of 1.0. Theref ore, rescinding the nonatomized gel coat application technique is significant for air q uality. Minor modifications have been

made to the Draft SEA such that it is now a Final E A.

A Draft EA (SCAQMD No. 050504JK, dated May 4, 2005) was prepared for the proposed gel coat pin striping exemption because th is modification was outside of the scope of impacts analyzed in the Draft SEA. The Dr aft EA was circulated to the public for a 30-day review and comment period from May 5, 2005 to June 3, 2005. No environmental topics were significantly adversely a ffected by the exemption. The analysis concluded that the gel coat pin striping e xemption could result in an increase in total VOC emissions by as much as 46.9 pounds per d ay, which is below the AQMD VOC significance threshold of 55 pounds per day. T he chronic and acute hazard indices were estimated to be below 1.0, which is the AQMD s ignificance threshold for noncarcinogenic risk. Therefore, the exemption wou ld not substantially increase the severity of the air quality impact or change any of the conclusions in the Final SEA.Final Staff Report

Proposed Amended Rule 1162 

### 15 July 2005 

### Although evaluated in a separate CEQA document, mod ifying the project to include the gel coat pin striping exemption would not add a new significant environmental impact, substantially increase the severity of an environme ntal impact, nor alter the conclusions

relative to the Draft SEA. Because of the focused nature of the proposed project evaluated in the Draft SEA, a second CEQA document (Draft EA) was prepared to allow the public and public agency decision-makers an opp ortunity to review and comment on the gel coat pin striping exemption. The AQMD did not receive any comments on either the Draft SEA or Draft EA during the public review and comment periods. Copies of the

EA’s have been included as an attachment to this re port.

SOCIOECONOMIC ANALYSIS

The proposed amendment to Rule 1162 deletes the req uirement of the nonatomizing spray application of gel coats, which results in no addit ional costs to the affected sources because the existing equipment can continue to be used. Theref ore, there is no socioeconomic impact analysis has been prepared.



### COMPARATIVE ANALYSIS

As required by Health and Safety Code Section 40727 .2, the purpose of this analysis is to identify and analyze any federal or other AQMD rule s that apply to the same equipment or source type as the proposed amendments. In additio n to PAR 1162, the composite operations in the AQMD are also subject to Rule 1132 and the Nati onal Emission Standards for Hazardous Air Pollutants (NESHAP) for Reinforced Plastic Composit es Production (40CFR63, Subpart WWWW) and for Boat Manufacturing (40 CFR Part 63, S ubpart VVVV). A comparative analysis of these requirements with the proposed am endments is summarized in Table 6.



### CONCLUSIONS AND RECOMMENDATIONS

Staff has determined that there are no significant differences between the VOC emission rates of the air-assisted airless and nonatomizing applicati ons when the nonatomizing is used at a pressure high enough to achieve an acceptable surfa ce quality. Therefore, it is staff’s

recommendation that Rule 1162 be amended to delete the requirement of the nonatomizing spray application technique of gel coat. In addition, st aff proposes to add language to clarify that a hand-held spray gun can be used for touch-up and re pair for gel coat and resin applications. Finally, a small use exemption has been added for p in striping gel coat.Final Staff ReportProposed Amended Rule 116216July2005Table 6Comparison Analysis of PAR 1162, Rule 1132 and 40 CFR Part 63 Subparts VVVV and WWWW RequirementsPAR 1162RULE 113240 CFR PART 63Subpart VVVV40 CFR PART 63Subpart WWWWObjectiveControls VOC and HAP emissions.Further controls of VOC and HAPemissions beyondRule 1162.Controls HAP emissions.Controls HAP emissions.ApplicabilityApplies to all composite operations.Applies to composite facilities,which emit>20 tpy of VOCs andutilize paint spray booth(s) in theiroperations.Applies to boat manufacturingcomposite facilities, whichrepresent major source of HAPs.Applies to the production ofreinforced and non-reinforcedplastic composite, as well asintermediate compounds.Compliance Options-Pollution Prevention Technologies-Add-on Control-Pollution Prevention Technologies-Add-on control-Combination between PollutionPrevention Technologies and Addon Controls.-Compliant materials-Add-on Control-Point Value Averaging-HAP limits listed in Table 1 forsources < 100 tpy- 95 % control required for sources≤100 tpy-Allows average weighted HAPemissions limits.Compliance Effective Dates-July 1, 2002: Nonatomizingapplications of resins and lowermonomer content of gel coatsJuly 1, 2003: Lower monomercontent of gel coats and resins-January 1, 2002: Nonatomizingapplication of resins (gel coatsexcluded) and lower monomercontents of gel coats.-July 1, 2004: Reduction of VOCemissions by 65 % of Rule 1162limits in effect as of January 19,2001.-August 22, 2001: New facilitiesmust comply with the regulationrequirements.-August 22, 2004: Existingfacilities must comply with theregulation requirements- April 21, 2006: Existing majorsource- April 21, 2003: New majorsource (constructed afterAugust 2, 2001)- Upon Start Up: New majorsource (constructed afterApril 21, 2003)- After three year of the change:Existing area source become amajor source- Upon the change: New areasource become a major sourceEquipment RequirementRequires nonatomizing technologiesfor resin applications.Requires nonatomizing applicationtechnologies only for resins.Allows atomizing andnonatomizing applications.Allows atomizing andnonatomizing applications.Final Staff ReportProposed Amended Rule 116217July2005Table 6Comparison Analysis of PAR 1162, Rule 1132 and 40 CFR Part 63 Subparts VVVV and WWWW Requirements(Cont’d)PAR 1162RULE 113240 CFR PART 63Subpart VVVV40 CFR PART 63Subpart WWWWMonomer Content by weightClear Gel Coat-For Marble Resin 40 %(VOC)-Other resins 44 % “Pigmented Gel Coats-White and off-white 30 % “-Non-white 37 % “General Purpose Resins-Marble Resins 10 % “-Tub/Shower Resin 20 % “-Lamination Resins 35 % “-Others 35 % “Specialty Resins-Fire Retardant 38 % “-Corrosion Resist. 48 % “-High Strength 40 % “44 %(VOC)N/AN/A30 % “37 % “35 % “N/AN/AN/AN/A42 % “48 % “48 % “48 %(MHC)*N/AN/A33 % “40 % “35 % “N/AN/AN/AN/AN/A39 % “N/A(MHC)*: Maximum HAP Content44 %(MHC)*N/AN/A30%37%30%N/AN/AN/AN/A>50%33%33%(MHC)*: Maximum HAP ContentFillersOffers fillers as an option to complywith the monomer contentrequirement of the applicable resins.N/AN/AN/AVapor SuppressantsRequires that tub/shower resins to bevapor suppressed.N/AN/ATable 3 includes equations tocalculate the emission rates ofvapor suppressed resinsClosed Molding SystemRequires<4 % weight loss ofpolyester resins during polymerizationN/AN/AN/APultrusion OperationRequires<3 % weight loss ofpolyester resins during polymerizationN/AN/AReduce total HAP emissions by atlease 60% by weightFinal Staff Report

Proposed Amended Rule 1162 

### 18 July 2005 

### DRAFT FINDINGS

Before adopting, amending or repealing a rule, the AQMD shall make findings of necessity, authority, clarity, consistency, non-duplication, a nd reference, as defined in Health and Safety Code Section 40727. The draft findings are as foll ows:

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 1162 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 th at Proposed Amended Rule 1162 is in harmony with, and not in conflict with o r contradictory to, existing statutes, court decisions, or federal or state regulations.

Non-Duplication – The AQMD Governing Board has determined that Pro posed Amended Rule 1162 does not impose the same requirements as any e xisting state or federal regulation, and the extent they overlap with NESHAP requirements are ne cessary 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.

Necessity - The AQMD Governing Board find and determines tha t it is necessary to amend Rule 1162 to delete the requirement for nonatomizing spr ay application of gel coats which has been

shown to be infeasible.



### COMMENTS AND RESPONSES

The following comments were received during the rul e development process, including the public workshop held on April 12, 2005.

Comment 1

Based on the AQMD Gel Coat Test findings, can the i ndustry continue to use the gel coat nonatomizing emission rates in the UEF (2001) table to calculate the gel coat emissions inventory of composite facilities?

Response 1

The AQMD Gel Coat Test Program results demonstrated that the four spray equipment operators could not operate at pressures equal to or less tha n those pressures used to develop the UEF nonatomized emission factors for gel coat and achie ve an acceptable surface quality. In fact, the results showed no significant difference between th e emission rates of the nonatomized and conventional spray applications of gel coats. As a result, the gel coat nonatomized emissionFinal Staff Report

Proposed Amended Rule 1162 

### 19 July 2005 rates of the UEF (2001) table can not be used to ca lculate emissions for composite facilities in the AQMD.

Comment 2

The definition of the “air-assisted airless spray” and the “electrostatic application” should be

consistent with those definitions listed in both Ru le 1107 and Rule 1136.

Response 2

Neither Rule 1107 nor Rule 1136 defines air-assiste d airless spray in the rule. The definition of the electrostatic application in PAR 1162 is consis tent with the same definition in both Rules

1107 and 1136.

Comment 3

GRACO has conducted several studies concerning the application of gel coat using the electrostatic application technique. The results of these studies were published in the Composite Manufactures Association (CFA) journal (copy of the publication was submitted to staff for review).

Response 3

The proposed amended rule includes a requirement to apply gel coat with lower emissions application technology, which includes electrostati c application. Staff will continue to assess the feasibility of the electrostatic application of gel coat.

Comment 4

Attempting to reduce the VOC emission through chang es in the chemical composition of gel coat materials, such as through the use of vinyl toluene , will require a great deal of testing to assure the integrity of the composite products. Such test s are beyond the scope of the gel coat surface quality tests included in the AQMD test program and may include chemical and mechanical resistance tests, thermal shock tests as well as ot her tests.

Response 4

Neither Rule 1162 nor the proposed amendment advoca tes a specific chemistry for gel coats. Therefore, testing for different formulations was n ot within the objectives of the AQMD Gel Coat Testing Program. Staff is soliciting suggest ions to mitigate the VOC emissions reduction foregone from gel coat applications resulting from the proposed amendments. Reducing the VOC monomer content of gel coats may be one way to mitigate the emissions foregone.

Staff would like to emphasize that the objective of AQMD Gel Coat Testing Program was to determine the minimum range of pressure values at t he tip of the nonatomizing spray gun that produces gel coat sprayed products with surface qua lity that is no less than the surface quality achieved when using an atomizing spray gun in accor dance with the composite industry

standards and achieves the emissions rates stated i n the UEF (2001) table for composite manufacturers operating in the AQMD. The testing p rotocol required the use of the same gel coat in each gel coat category to determine the ope rating pressures of each of the four different nonatomizing and the air-assisted airless spray gun s. The gel coat formulation was not part of the testing program. Furthermore, the surface qual ity tests performed in the test program including porosity, gloss, orange peel and water re sistance were specifically used to compare theFinal Staff Report

Proposed Amended Rule 1162 

### 20 July 2005 surface quality of the nonatomizing and the air-ass isted airless spray applications and not to determine the performance of the gel coat materials used in the test program.

Comment 5

The manufacture of high quality molds is critical t o manufacture of composite products. Any defect or substandard surface quality of a mold wil l produce the same defect on the surface of all composite parts produced by that mold. Additional ly, the amount of tooling gel coat to produce molds manufactured in the AQMD represents approxima tely 1 to 1.5 percent of the total usage of gel coat in the composite industry. Based on our e xperience, the atomized air spray gun is the only technology currently available to produce a mo ld of acceptable quality when using typical tooling gel coat.

Response 5

Staff acknowledges the importance of the surface qu ality of the mold for composite products manufacturing. The surface quality of the mold det ermines in large part the surface quality of the finished composite product. The manufacture of molds is a sophisticated fabrication process, which is currently limited to two major composite operations in the AQMD.

One facility, one of the largest mold manufacturing facilities in the nation, builds molds for different composite manufacturers. Staff contacted the company and verified that they apply a specific gel tooling gel coat formulation using hig h-volume, low-pressure spray application equipment. This is one of the compliant applicatio n techniques in the rule.

The second facility is a large fabricator of bathwa re products. This facility has developed the expertise to build molds for their own composite pr oducts. This facility informed staff that they use the standard compliant tooling gel coat and hav e determined that they must use an air atomized spray gun to obtain the surface quality ne cessary for the mold. Staff has verified that this facility has submitted an application for a Pe rmit to Construct and Operate an air pollution control system (concentrator/afterburner) to comply with the requirements of Rule 1162 and

other rules.

Therefore, no amendment is necessary or proposed si nce alternative compliance techniques are

available.

Comment 6

Pin striping is used to apply small amount of diffe rent pigmented gel coat on boats and structures in amusement parks for decorative or identification purposes. Current practice is to use an air spray gun with a small cup (less than a quart) cont ainer attached to the base of the air spray gun. It is not technologically feasible to use an airles s, air-assisted airless, or other lower emitting application technology that uses a larger container (typically a 55 gallon drum) to apply pin striping. A hand-held cup gun also minimizes the a mount of clean-up solvent needed to clean up the spray equipment (small cup container versus a l ength of supply hose) whenever a change in

color is needed.

Response 6

Staff agrees that the amount of gel coat used speci fically used in pin striping operations at any one facility is very small. In addition, the proce ss of applying several pin stripes of different color gel coat using the spray cup gun will use les s clean-up solvent as compared to the clean up of the air-assisted airless spray gun or any other spray applications listed in the PAR 1162. StaffFinal Staff Report

Proposed Amended Rule 1162 

### 21 July 2005 has proposed an exemption from the spray applicatio n requirement of PAR 1162 for pin striping applications provided that the total usage of gel c oat does not exceed one (1) gallon per day per facility.



### REFERENCES

South Coast Air Quality Management District, “Draft Final AQMD Gel Coat Testing Program Report” February 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.

R.A. Haberlein, “Technical Discussion of the United Emission Factors for Open Molding Composite,” Engineering Environmental, July 17, 200 1.