### ATTACHMENT VI

COMPARISON OF PROPOSED RULE REQUIREMENTS WITH OTHER AIR POLLUTION CONTROL REQUIREMENTS

Health and Safety Code Section 40727.2 requires air districts to compare the requirements of a proposed revised rule with other air pollution co ntrol requirements. These other air pollution control requirements include federal regu lations, Best Available Control Technology (BACT), and any other district rule appl ying to the same equipment or process. The proposed amendments to Rule 67.0 are based on t he Air Resources Board Suggested Control Measure for Architectural Coatings (SCM). The proposed amendments establish more stringent VOC content limits than those found in the United States Environmental Protection Agency’s (EPA) National Architectural Co atings Rule. Architectural coating operations are exempt from permits and, therefore, not subject to Best Available Control Technology requirements. No other District rules h ave air pollution control requirements that would conflict with Rule 67.0 requirements.

Comparison with EPA’s National Architectural Coatin gs Rule There are several significant differences between t he proposed amended Rule 67.0 and the National Architectural Coatings Rule, which became effective on September 13, 1999. The National Rule only applies to manufacturers and imp orters of architectural coatings while Rule 67.0 has, in the past, and will continue to apply t o manufacturers, distributors, retailers, and users of architectural coatings. The National Rule generally has less stringent VOC limits than Rule 67.0. For example, the VOC content limits in the National Rule for the three largest categories (flats, non-flats, and industrial mainte nance coatings) are 250, 380, and 450 grams per liter, respectively. The VOC limits for the sa me categories in the proposed amendments to Rule 67.0 are 100, 150 (excluding high-gloss nonfla ts), and 250 grams per liter, respectively. The National Rule includes 16 additional specialty coating categories not included in the state SCM nor the proposed amendments to Rule 67.0. ARB has analyzed these additional national categories and found it was not necessary to add th em to the SCM because either: (1) they are included in other specialty coating categories in e xisting district rules; (2) they are not architectural coatings; or, (3) they are not sold i n California. The District has reviewed the additional National Rule categories and concurs wit h ARB’s analysis.

Comparison of Air Pollution Control Requirement Ele ments Health and Safety Code Section 40727.2.(c) requires review of the following elements in the comparative analysis:

• Averaging provisions, units, and any other pertinen t provisions associated with

emission limits.

• Operating parameters and work practice requirements

.

• Monitoring, reporting and recordkeeping requirement s, including test methods, format, content, and frequency.

• Any other element the district determines warrants review.-2-

The coating (emission) limits in proposed amendment s to Rule 67.0 are stated in units of grams of VOC per liter of coating, which are identi cal to the units in the state SCM and the

EPA National Rule.

There are no air pollution control requirements inv olving operating parameters in any of the rules subject to this analysis. The proposed amend ments to Rule 67.0 do not include the state SCM’s work practice requirement to close coating an d solvent containers when not in use. However, this requirement is already addressed unde r existing District Rule 67.17.

There are no monitoring or recordkeeping requiremen ts (except for the optional manufacturer averaging provisions) in the proposed amendments to Rule 67.0. ARB reporting requirements have been included for manufacturers to report sale s of the following specialty coatings: clear brushing lacquers; rust preventative coatings; spec ialty primers, sealers and undercoaters; recycled coatings; and bituminous coatings. In add ition, manufacturers of coatings containing perchloroethylene or methylene chloride must report sales in California for the prior year. These reporting requirements are not required by EP A’s National Rule but were included in the

state SCM.

The proposed amendments to Rule 67.0 include test m ethods needed to determine VOC content and other coating characteristics. These t est methods do not conflict with test methods

cited in the National Rule.

The District has determined there are no other air pollution control requirements of proposed amended Rule 67.0 subject to review in this compara tive analysis.